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12-3857
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, CIVIL DIVISION NO.. OJ U? S Plaintiff, vs. JACQUELINE ACO, Defendant. TO: DEFENDANT(S) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF-OR AA DEFAULT JUDGMENT MAY BE ENTEREI AGM ST YOU. ATTORNEI7FOR PD{INTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: P.O. Box 639 Maugansville, MD 21767 AND THE DEFENDANT(S): 2006 Connie Drive Enola, PA 17025 ORNEY FO CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 2006 Connie Drive, Enola, PA 17025 ATTORNEYFOI D4 ,?F TYPE OF PLEADING 8'l !P P [ F p CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF: Susquehanna Bank, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 CS) a $I b3.7:5 a l a W4 / a 55& 12[+ a-7 (D q qO IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, CIVIL DIVISION Plaintiff, NO.: VS. JACQUELINE ACO, Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFOMRATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, Plaintiff, VS. JACQUELINE ACO, Defendant. CIVIL DIVISION NO.. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR. ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, Plaintiff, vs. JACQUELINE ACO, Defendant. CIVIL DIVISION NO.. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Susquehanna Bank, by its attorneys, James, Smith, Dietterick & Connelly LLP, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Susquehanna Bank, which has its principal place of business at P.O. Box 639, Maugansville, Maryland 21767. 2. The Defendant, Jacqueline Aco, is an adult individual whose last known address is 2006 Connie Drive, Enola, Pennsylvania 17025. 3. On or about July 15, 2010, Defendant executed a Note in favor of Plaintiff in the original principal amount of $138,710.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about July 15, 2010, as security for payment of the aforesaid Note, Defendant made, executed and delivered to Plaintiff a Mortgage in the original principal amount of $138,710.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on July 29, 2010, as Instrument Number 201020622. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto and made a part hereof. 5. Defendant is the record and real owner of the aforesaid mortgaged premises. 6. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. 7. On or about May 9, 2012, Defendant was mailed a Notice of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P. S. §101, et seq. A true and correct copy of said Notice is marked Exhibit "C", attached hereto and made a part hereof. 8. The amount due and owing Plaintiff by Defendant is as follows: Principal $ 135,697.22 Interest through 6/13/2012 $ 2,099.81 Late Charges $ 78.76 Satisfaction Fee $ 50.50 Attorney's Fees $ 1,300.00 Title Costs $ 410.00 TOTAL $ 139,636.29 plus interest on the principal sum ($135,697.22) from June 13, 2012, at the rate of $20.65533 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $139,636.29, with interest thereon at the rate of $20.65533 per diem from June 13, 2012 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. JAMES, Dated: l ?' ? ?' BY: Scott A.. i teri PA I.D. # 55650 uire Kimberly A. Bonner, Esquire PA I.D. # 89705 Attorneys for Plaintiff P.O. BOX 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY LLP THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" 1, n NOTE Loan#:1022878 July 15, 2010 Clearwater FL [Date) [City] Istatel 2006 Connie Drive, Enola, PA 17025 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay ONE HUNDRED THIRTY-EIGHT THOUSAND SEVEN HUNDRED TEN AND 00/100 Dollars U.S. $138.710.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is Susquehanna Bank. I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 5.500% The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment an the 1" day of each month beginning on September 2010. I will make these payments every month until i have paidall of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on August' 1, 2040, [ still owe amounts ureter this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." 1 will make my monthly payments at 4185 West Market Street, York, PA 17408 or at a different place if required' by the Note Holder. (B) Amount of Monthly Payments my monthly payment will be in the amount of U.S. $ 787.58 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that t am doing so. I may not designate a payment as a Prepayment if I have riot made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I own under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to these changes. to ATISTATE RXEO RATE NOTE • Sr" Famly - rarmle Mae/Freddie Mac UNIFORM INSTRUMENT Frxm 3200 1101 rr VMPSN (1001)01 Kluwer rMemial Services Page 1 Ct 3 Loan#:1022878 5. LOAN CHARGES if a law, which applies to this loci and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceed permitted limits will be refunded to me. The Note Holder may goose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amotmt of any monthly.payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once an each late payment. (B) Default if I do not pay the full amount of each monthly payment on the date it is die, I will be in default. (C) Notice of Default if I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I we on that amount. That date must be at least 30 days after the date an which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Hold will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immedlately In full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if i give the Note Holder a notice of my different address. Any notice that must be given to. the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Nose Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. a. OBLIGATIONS OF PERSONS UNDER THIS NOTE if more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount awed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. MULTISTATE FiYEU RAZE NOTE ^ Single FartNg . Fammi0 Mr VrmWie MM UKIFORM MSTRUMENT Font 3200 1101 VMnN (1001).01 R.S Kkiwer F rvlnciit X83 Pap Z of 3 Loan: 1022878 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. in addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "5ecvity Instrument"), dated the same date as this Note, ;protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall riot beexercised by Lender if such exercise is prohibited by Applicable Law. if Lender exercises this option, Lender shalt give Borrower notice of acceleration. The rice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower faits to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security instrument without further notice or demand on Borrower. WITH TF#dE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. ' f f`ry' + (Seal) (Seal) Ja AG -Borrower -Borrower 1-- (Seat) (Seal) -Borrower -Borrower (Seat) (Seal) -Borrower -Borrower [Sign Original Only) E7 Refer to attached Signature Addendum for additional parties signatures MULTISTATE FIXED RATE NOTE , Single Famiy - Fannie MaerFredit MU UNIFOiS`I MSTRUtAENT FWM 32001!01 YMP" (106!1},81 VMP WOWIeIw ?3a3 S Nhrwer FNeneiat Services r Loan #: 1022878 ADDEND TO NOTE AUTO-DEBIT PREFERRED RATE PROGRAM Note Amount: $138,71010.0 Date: July 15, 2010 Preferred Rate Feature: "Cfta interest rate is a:PrOormd rate reflectfrtga discount equal' to .25% per annum. , This preferred; rate Is offered in consideration of my agFeornent that al I requia0y Scheduled payments will be paid by automatic debft.fmm my designated Susquehanna checkth.q car savings accou nt. If I fait to provide this consideration, uniess otherwise required by law, the interest rate will increase .25% (the "Rate Increase Event"). Example .of Effect OfArnr ual Percentage Rate Increase: Should the iriterouEate increase by.25% per annum pursuant to the conditions fl or such increase outlin.ed in the paragraph above en'tbted- Preferred Rate Feature", a I I rights to receive the Preferred Rate Feature wlII be f©r4ver terminated. Upon th ocm:-ence of any rate Increase, my payment amount can be increased. l wili be notlfled in writing at least 25, but not more than 12o days .before the due date of a payment at a° new level, Thia rib ice will contain information about the iriterestnte, payment amount and lQan: bal=e. I/We agree. to :the terms of this Agreementand acknowledge receipt of a completed copy of this-Addendum. Witness I Attest: l3orro I acque?# Sus*MhM=.Aiidendur to Note Auto-Dehit Prererred Rate Program Addendem Revised 311 bW EXHIBIT "B" L. -- EA.... 11011 Prepared By. Steptm to Das Loan Closer Susquehanna Mortgage 307 international Circle, Suite 600 Hunt Valley, MD 21030-1376 Parcel Number: 10-14-0842-022a Premises: 2006 ?Connie Drive, Enola. PA 17025 `I 6 `7 xz-^4D - f e [Space Above This Line For Recording Date] MORTGAGE ? Loan #: 1022678 DEFINITIONS Words used in multiple sections of this document are defined below and other words are defined in Sections 3. 11, 13, 16. 20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 16. (A) "Security instrument" means this document, which is dated July 15, 2010 together with all Riders to this document. (B) "Borrower" is JACQUELINE ACO, SINGLE WOMAN Borrower is the mortgagor under this Security Instrument. =IsytVANtA,S*40 FaniIly-Fames MMIFfeddie MOC UNIFORM INSTRUMENT WdWS KkwW Financial ServPCas Poge i? tam au 1ri r,u r VMPfi( 1 ~ Loan #:1022878 (C) "Lender" is Susquehanna Bank Lender is a Corporation organized and existing under the laws of Pennsylvania Lender's address Is 4185 West Market Street, York, PA 17408 Lender is the mortgagee under this Security instrument. (D) "Note" means the promissory note signed by Borrower and dated July 15, 2010 The Note states that Borrower owes Lender ONE HUNDRED THIRTY,EIGHT THOUSAND SEVEN HUNDRED TEN AND 00/100 Dollars (U.S. $ 138,710.00) plus interest. Borrower has promised to y this debt in regular Periodic Pa and to pay the debt in full not data Au ust 1, 2040 ([: "Property" means the property that is described below under the heading "Transfer of Rights in the Property." "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due under the Note, and all sums due under this Security instrument, plus interest. (G) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicable]: Adjustable Rate Rider Condominium Rider Second Home Rider Balloon Rider Planned Unit Development Rider 1-4 Family Rider VA Rider Biweekly Payment Rider X Other [specify]: Leval Description (H) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final, non-aapppealable udicial opinions. (1) "Commun1 Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on 8arrower or the Property by a condominium association, homeowners association or similar or ganization. (J) "Electronic Funds 'Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic insvumenLc puter, or magnetic tape so. as to order, instruct, or authorize a financial institution to debit or credit an account. Such term includes, but is not limited to, point-of-sale transfers, automated teller machine transactions, transfersinitiated by telephone, wire transfers, and automated clearinghouse transfers. (K) "Escrow items" means those items that are described in Section 3. (L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the PENN 6YtVAN'tA $;n9e FBtr?Ir-FaMH! MBEdFtedtliC WC UMIFORM, IN5iNUWFEt ?pV ,2 R 5 WaRms Kluwer Fmmraat Services Loan #: 1022878 Property: (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissionsas to, the value and/or condition of the Property. (M) "Mortgage Insurance" means insurance protecting Lefler against the nonpayment of, or default on, the Loan. (N) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument. (O) "RESPA" means the Real Estate Settlement Procedures Act (12' U.S.C. Section 2601 et seq.) and its implementing re elation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject mattes. As used in this Security Instrument, "RESPA'" refers to all requirements and restrictions that are Imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under RESPA. (P) "Successor in interest of Borrower" means any patrttyy that has taken title to the Property, whether or not that party has assumed Borrower's obligations underthe Note and/or this Security instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this Security instrument and the Nate. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located in the County [Type of Recording Jurisdiction) Of Cumberland (Name or Recording Jurisdiction): See legal description attached hereto and expressly made a part hereof. which currently has the address of 2006 Connie Drive tweet/ Enola icityl, Pennsylvania izip codes 17025 ("Property Address"): PvEMp?Y4.VANIA•Stn9td Fft".Fare* elFreddte MaC UNIFORM tNSTRUµEN7 Form 3039 1101 VMP Rau R %*An KkNW FUMCMI Services gage, Loan #: 1022878 TOGETHER WITH all the improvements now or hereafter erected on the property, and ail easerr"t% appurtenances, and fixtures now or hereafter a part of the, property: All replewrients and additions shall also be covered by this Security instrument. Alt of the foregoing is referred to in this security instrument as the "Property;` ` BORROWED COVENANTS that Borrower is lawfully seised of tip estate hereby VGnveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrancesof record. Borrower warrants and will defend generally the title to the Property against all claims and demands, stil ject to any encumbrances of record. THIS SECURI'T'Y INSTRUMENT combines uniform covenants for national use and non-uniforrn covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property U 1FORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest Escrow Items, Prepayment Charges, and Late Charges. Borrower shail pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the NM. Borrower shall also pay funds for Escrow Items pursuant to Section 3, Payments due under the Note and this Security Instrument shall be made in U.S. currency. However, if any check or other instrument received by Lender as payment under the Now or this Security instrument is returned to Lender unpaid, Lender may require tha€ any or all subsequent payments due under the Note and this Seotaity instalment be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other lot8tion as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any paym$nt or partial payment if the payment or partial payarrts are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient-to bring the Lean currem without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do sir within a reasonable period of time, Lender shall either apply such funds or return them to Borrower, if not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Leader shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under ft Note; (c) amounts due under Section 3. Such payments PENII&YLYANLFShVe Pan*-Fanaa Maplcraddle Mot UNIFORM INSTRUMENT Form 30391101 YNIP 6 VMPGIPA). (090 fthers XIUWar Flrwlpal Ser&m Page 4 Loan #: 1022878 shall be applied to each Periodic Payment in the order in which it became due, Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay arty late charge due, the payment may be applied to the delinquent payment and the late charge, if more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrow to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceads,:or Miscellaneous Proceeds to principal due under the Note shall not extend tar postpone the due date, or change the amount of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note is paid in :full, a sum (the "Funds") to provide for payment of amounts due fox: (a) taxes and assessments and other items which can attain priority over this Security instrument as a lien or ermumbrance on the Property, (b). leasehold payments or ground rents on the Property, if any, (c) premiums for any and all insure required by Lender under Section 5: and (d) Mortgage Insurance premiums, If any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments gall be an Escrow Item. Borrovwer shall promptly furnish to tender all notices of amounts to be paid under this Section. Borrower' shall pay Fender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Items for which -payment of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time-period as Lender may require. BoxrowWs obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 9. if Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender, may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required cruder this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and PPAYLYAHWSk#e Family-Fwwk MsWT"AAe,Mec UNIFORM Od$TRUMENT Form 9079 1111 WdWs Nwwer Finamal ser4ces Loan #:1022878 reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Horne Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lend shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to rake such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds.. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. if there is a shortage of Funds held in escrow, as defined under RESPA, Lender shalt notify Borrower as rehired by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. if there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4_ Charges; Liens. Borrower` shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if any, and Community Association Dues. Fees, and Assessments, if any. To the extern that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the Ilen in a manner acceptable to Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending. but only until such proceedings are concluded; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4, Lender may require Borrower to pay a one-time charge for a real estate tax verification andlor reporting service used by Leader in connection with this. Loan, 5, Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and any aENk5YLVANM-Single Fwmiy-ronow welF eddie Mac VNIFORM INSTRUMENT Form 30391101 !! VM?pr' (Z Wokers Kknver Financial Services Loan #:11022$7 other. itaZwd$ Including, but not limited to, earthquakes and floods, far :Mich Lender requires `insurance.. This insurance sh:ti.l be mahSta#0 in the ..arnourfts. hcluding dedt t ill revels} and for the periods chat Lender requires. What Lender requires uarit to the..precediog seiitesces can change-during the,urm of the Loan. The inWrance carrier providing thainsuraaceshdl tie chosen by. Borrower subject to Lender's right to disapprove. Borrower's xhorce, Wch right short not be .exercised bl'treasonably. Lender may require Bw.dwer ,to pa , in connection Y&h this Loan, either fa) a oneAlme chxge or flood done t#eterrrunatitrtL certifiWon and tracking services: or (b) a one-time charge for floor zom :determination and certification my1ce.s and subsequent charges each .time oremappings or similar changes occir Mich reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of ary fees imposed by the Federal Emergent Management Agency in connection with the review of any flood zone determination rsestti ft-frbrn an ojetton Boaower. If Borrower fails to-:maintain -art of the coverages desa.. ? ove, Lender ritay obtain insurance cower ? e, at. Lender's optl .and .Borrower's expense. Len r.is? under no obligation to. purr. ese any path Vpe or amount cif coverage. Therefore, suit coverage. sFiatl. -cow Len ett #., Wt might or -mid mat protect -Borrower, .Borrower's eec? city in the Prwetty. or the coreents of the tar aperty, a t any risk, hazard or I€abili Intl nil tit.:prov€de greater or ?leseer l Q?+e<age than was ' viot,tn effect. 8oit?ower acknowledges that this cos of the insurance cp?versga. so olxatrled rnigght:5 nrkarr y exceed the .09 of Insurance . t. Biatr!t+uuer could have :obta1dW,. An. arno rifts disbursed. by L8R1er under this Section 6 sVll become at. fionaa debtnf Borrovil r 3ewrad bythis Security Instrurnartt 1`liese airiounts sliafl bear Interest at the NW. rate from the date of disburseii'ter t and shall bd Oayable- :wiith such 'rote at, 0n.viotice from Lender tti Borrower requesting payment. .All insurance policies required by Lender and renewals of such .policies shall. be subject to Lender's right to disapprove such policies, shall include $. standard mortgage clause, arid: sbail name Lender as mortgagee and/or as an additiorial loss payee. leader shall have the right. to. hold the policies and renewal certificates. If lender requires, Bormwer -shall promptly give to Lender att receipts of paid. premiums and renewal notices. if Bm. ower obtains any loon of insurance coverage, not otherwise required by Lender,. for damage to, or destmction of, the Property, such policy shafl include a :standard mortgage clause and shall name Lender as mortgagee and/or as an.additional loss payee. In the event of loss, Borrower shall give prompt notice to the Insurance carrier and Lender. Lender may make proof of loss. If not made promptly by Borrower.. Unless Leander and Borrower wise agree in writing, any insurance ,proceeds, whether or-nat the underlying instrance was required by Lender, shall be applied to restoration or repair of t'be Property, if the restoration or repair is econadnically Feasible and Lender's security is not lessened. miring such repair and restoration period, Lender shall have the right to hold such insurance proceeds uiatil tender has had an opparttaiity to inspect such Property to ensure the work has been completed to Lender's satisfaction, prdvided that such inspection shall 'e undertaken promptly. Lender may disburse proceeds for the irs aitd restoration in a single payment or In a series of progress payments as -the work is completed. Unless an agri .e Tent is made in writing or Applicable Law requires'interest to be paid on such 'insurance proceeds, Leriider shall not be required to pay Borrower any interest or earnings o ..st. proceeds. Fees fear public adjusters, or other third parties,. retained by Borrower shall not be paid.out of the Insurance proceeds and shall tie the.sole obligation of'Beirrolwer. If fern M034??1/opO17? PE?i?Yt4ANfA-Singe Famuy.Fanrie MaelPreddie UltG ON"RUIN5TRUMENT Pe i.at?- 1NalWS-51~ Fkancial SOMMS Loan.#:1022678 9.-Protection of Lender's Interest inthe Property and'Ri hts Under this sscurity Instrument. If (a) Bor fells-to perform the co Agots and agreermots contained in trity Iristriument, (b) there Is a [ego! proceeding shaft mot signlftcMitly affect Lender's interest In the' Pigxrty and/or rights under this Security instrurnerk •(such as a proceeding In bank probate. for condemnation or for eittne, for err€orrAment of a Hen Mich may attain prity over-t s Security Instrument or to enforce laws or regulations), or (c) Borrower has abandondrl the Property, then Deader may do and pay for whatever is reast le or appropriate to protect Leader's interest in the Prroperty and rights under this Security instnmdrit, Incl6ding< protectunq and/or assessing the vaiiie of the. Properly, and securing and/or repairing the Property. Lender s actions can include, but are not limited to: (a) paying any sums'secured by a lien which has priority over this Security lnstiurieftty (b) appearing M court; and (c) paying masoflable attorneys' fees to protect its interest in the property andlor'rrghis under this Security Instrument, including its secured position in a bankruptcy proceeding: Securing the Property includes, but is not limited to, entering the F.rgi 'ertrtyy to make repairs, chat c lckk5, replace. onboard up doors .arid windows, drain water from pi elhmnate building or older code. Vitiations or dangerous eootiltlons, and have utilities turned on or off. Aldw* Lender may take:acton under this Section 9, Lender does not have to do so end is not under any duty or obligation to do'sgi It is agreed that Lender incurs no liability feu not taking any or all actionsatiftnzed under. this` Section 0. An amounts di5 liy Lender under this Section :g shall become additional debt of Borrower secured r>i this Seixa9tyt?i lint These amounts ."If bear interest at the /!dote rate from the date of disburse Ent and shall be payable, with sucR interest, upon notice from Lender to Borrower requesting payment, i If Security Instrument is on a leasehold, Borrower snail with all the provisions of the lease. tf Borrower ac Tres fee title to the Property, the leasehole in=fee title shall not merge unless Lender agrees to. the rrierger in writing. 1€Y.m ge Insurance, If Lender required Mortgaqq?..Insurance as a condition of making the. Loan, Borrower shall a y the premiumm required to rMirtain NU TT in effect. if, for aaiy reason, the lri??ran? coveraqe required .by Lep f u ses to be ayait le from the nnorE Ir e Ins urer that ? ea vi such instance and fev?er w& rred to ake ate[y desi ayrnents ot pprre to prei?MIS for kmortgagb lnsurant?: Borroviie shat! theemiuifis re ed ?o obtain cvv r sutrdaneiaiiY equivalent tt3 the M Sa In raraca previously In effect at a cost stbstantE'a?iiy equri+afent to the it to Botrower of the Insaatitie- If In ei`feet, from :an Bit mo a Irtwrer selected b. Lender. If sr C , Il etfuivalent lulu Insurance coverage is not oval e, Borrower sliali co inue to pay to Le-Wer the arnoiait of the toly designated psay;fients that were due when tha insurance cov?pe ceased to be in effect. Lender will acre t, 'use and retain these payments as a non-refundable loss deserve In lieu of Mortg?ia insurance. Suc? loss reserve shall be non4efu ridable, notwithstandirig the- fact that the Loan is ulppaid In full, and Lender shalt not be requited to pay BorroW0..any interest or eamings on stick loss r e Lender can no longer .require. loss resetp nts If Mora Ir?rranee coverage (in the arnourit and for the period that Lender requires) provided?',?an InstM - ted by Lender again .brc . available, is obtained, and Lender re res Sepat l ifesEg at pa cots toward the premrlurts for e Insurance. If Lender. required Mo Ins, - as a ?or itro€t cf mein . the Loan and Borrower s mired to make separately deli at $d p i ents tawaid the pmmlums Mortgage instlraprk, .i3ottrower shad pa_y the premiums aired to maintain M hasurance in effect, or to provide a non-refundable ss r eser e, urnlender"s requirementforoortgage Insurance ends in accordance with any written agreement between Borrower and PENT YLYANIA-Single Fordlr•Fanrae Maefrreddk Mac UNIFORM INSTRUMENT Form 3039 T101 ViM1P VMP9(PA) (0901) Wdtm Kluwer Finanml Sarvim Page 9 Loan #: 1022878 Lender providing for such termination or until termination :is required by Appiicoble Law, clothing in this section 10 affat.Is Borrower's obligation to pay nterest.at the rate.prova n the Note. Ail Insurance reimburses Lender (or any entity that i Kdlases the -Vote) for certain losses It may ineui Borrower does not repay the loan as agreed. Borrower is not a patty to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such iruurance in farce from time to time, and may enter into agreerpents with other parties that Share or modify their risk, or reduce losses, These agreements are on terms and conditions that are satisfactoryto the mortgage insurer and the other". (or partles) to these agreements. These agreements may require the moinsurer to make payments using any source of funds that the mortgage Insurer may have available (=I may include funds obtained from Mortgage Insurance premiums), As a result of these Wements, Lender, any purchaser of the Dote, another insurer, any reinsurer, any other entity, or any affiliate of any of the foregoin may receive {direct-y or indirectly) amounts that derivefrom (or might be characterize-- as) a portion Doff B.orr? :es payments for Mortggage Insurance, in each a for sharing or mt d"tfyiiig the mortgage lrmAm s risk, or reducing dosses. ff such agreement Iuov that an affiliate of Lender takes a share of the. iTSStmr's risk 'in "exchange for a share of the prein te. -paid to the insurer, the airangement Is t1£tWarmed: - aptive reinsumnce." Further; (a) Any such agreements will not affed ft amounts that Borrower has agreed to pay for increase the amount Mortgage Insurance, or an. other terms td the Loan. Such agreements Will not Borrower will owe for -Mortgage Insurance, and they will not entitIO.Borrower to any refund. (b) Arty. such agreements will ridt.aftsect the rids Borrower has - if any with respect to the Mortgage Insurance under the Homeowners Protection Act of 1988 or any offw law. These rights may include the right to receive certain dlsclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage 'I nsurance terminated auitorrraticaily, andfor to receive a refund of any Mortgage Insurance premiums that were unearned at the time of such Cancellation or termination, 17. A. sstgt?ment of Miscellaneous Proceeds, Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be aid to Lender. If the Property is maged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. Duringg repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender ftas had anoppor unity to inspect such Property to ensere the work has been completed to Lender's satisfaction, provi'dedtthat such inspection shall be undertaken promptly. Lender may pay for the repaft's and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires Interest to be paid on such Miscellaneous Proceeds, Lender shall not be recluired to pay Borrower any interest or eamfrigs on such Miscellaneous Proceeds. If the restoration or repair Is not economically feasible or Lender`s security would be lessened, the M3sceTianeous Procoods shall be applied to the suns secured by this Security Instrument, Mother or not then due, with the excess, if any, paid to Borrower, Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the.exces% if any, paid to Borrower. W NSYLVANihSIogM Fam6y Fawk MaPJFreeK- Wt -UNifDAPA;NSrRUUENT Form 3039 Iml e® PW47Q ". WuwerFinandal Servteas Loan C 1022838 In the event of a partial taking destruction, or loss in value of the Property in which the fair market value of the Propertg aninediately fare the partial taking, destruction, or lo?s in value is equal to or greater than the amunt of the sums secured by this Security instrument immediately before the partial raking, destruction, or loss in value, unless B(Trrower and Lender otherwise agree in writing, the sums secured t this Security Instrument shall be rem the amount of the Miscellaneous Proceeds multlpIied` LO, oWing fraction: (a) the total arr? of the sums secured immediately before the aY taki estruction, loss in value divided 6y (b) the fair market value of the Property immediatela the partial taking, destruction, or loss in va ue. Any balance shall be paid to Borrower. In the even of a partial takingg,, destruction, or loss in value of We Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and LerxW otherwise agree in writing, the Miscellaneous Proceeds. shall be applied to the sums secured b this Security instrument whether or not the'surns are then due. if the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Sec<b ity instrument, whether or not then due ""Opposing Party" means the third party that owes Borrows Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceedin , whether civil or criminal, is begun that, in Lender's judgment, could result In forfeiture of the Prop 9 ty or other material impairment of Lender's interest in the Property or rigghts under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a ruling that in Lender`s j ment, precludes forfeiture of the Property or other material impairment of Lender's interest in the Prop y or rigf tinder this Security Instrument. The proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and shalLbe paid to Lender. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured b this Security Instrument ranted tender to Borrower or any Successor in Interest of Borrower shall not operate to release the tiability of Borrower or a Successors in Interest of Borrower. Lender shall not be required to commence proceedings against anyessor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or any Successors in interest of Borrower. Any forbearance by Lender in exercising any right or remedy #ncludii?g, without lirrikation, Lender's acceptance of paymatts from third persons, entities or Successors in interest i3oriolnter or in amounts less than the amounCthen due, shall not be a waiver of or preclude the exercise of arty riclhCor remedy. 13. }oint and Several Liability; Co siggners; Successors and Assigns Boland. Borrower covenants and agrees that i3cerawer's obligations and liatiitity shall be joint arul several. However, any Borrower who ca-signs this Security InstnimenE but does not execute the Note (a "co-signer"): (a) is co-signing this PCI4" YLVAN)A,5WgW FonAy-Fawie Mw/Freddle Mac UNIFORM INSTRUMENT Forth 30781101 vWIMPAi 10207) WOWS Kiuwer FW4M181 S&Wes Page 11 ota.(x Loan#:1022878 Security Instrument only to mortga ,grant and convey the cosigners interest in the t?roperty under the terms this Security Instrument: (?} is not personally obligated to pay the sums secured by this Security Instrument: and (c) agrees that Lender and any other Borrower can agree to extend:, modify, forbear or matte any, accommodations with regard to the terms of this Security Instrument or the Note without the co-signers consent. Subject to the provisions of Section 18, any Successor in Merest of Borrower who assumes Borrower's oblic?tions under this Securitcyy instrument in writing, and is approved by Lender, shall obtain all of Borower's rights and benefits urxt"er this Security Instrterient. Borrower shall not be released from Borrowers obligations and liability under this Security instrument unless Lender agrees to such release in writing. The covenants and agreements of this Securittyy Instrument shall bind (except as provided in Section 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, far the purpose of protecting Lender's interest,in the Property and rights under this Secna'ity Instrument, ineiudirxl, not limited to' attorrueys, fees, property inspection and valuation fees. In regard to any other fees, the absence of express authorit}? m this Security Instrument to charge a specific fee to Borrower shalt not be construed as a proizibition on the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security Instrument a by Applicable Law. If the Loam is subjetx to a law which sets maximum loan ctraru)es, and that law is finally interpreted so that the Interest or other loan charges milecteti or to be collected in connection with the Loan exceed the permitted limits, then: (a) any suuc loan Cha a shalt be redtrced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose, to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge, 15. Notices, All notices given by Borrower or Lender in connections with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrument shall I?ie deemed to have been given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptlyy notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrowers change of address, then Borrower shall only report a change of address through that specified procedure, There may be only one designated notice address under this Security Instrument at any one time. Any notice to tender shall be given by deliverer it or by mailing it by first class mail to Lender's address stated herein unless Lender has designated another address by notice to Borrower. Any notice in connection with this Security Instrument shall not be deemed to ave been given to Lender until actually received by Lender. If any notice required' by this Security instrument is also required under A liable Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security instrument. z"iYLVaNWSWp Eamiiy1amae JAWfteddie MOC UNIFORM INSTRUMENT Fwm 3D3 D 9ry Wakens k'knver Fkwt" Services WE ge l2 Loan A 1022878 16. Governing Law; Severability, Rules of Construction. This Security Instrument shall be governed.by federal law and the law o_fthe,jurisdidtion In which the Property is located. All sights and obli?attor contained in this Secui`t Instrument are subject to an requirements and liniltations of App iI cable I,= Applicable Law m! expplicitly or Implicitly allow the :parties to agree by contract or it might be silent, but such silence shah not be construed as a prohibition against agreement ley contract- in the event that arty provision or clause of this Security Instrument or the Dote conflicts with Applicable I.aw, such -con lict shall not affect other provisions of this Security lnstiaurnent or the Note Which can be given effect without thtt-confllcting provision. As used in this Security Instruitterht: (a) words of the mascvtine gender shall mean and include core rdnq neuter words or words of the fetntnirte gender; (b) words in the singular shall inean and include the plural end vice versa; and (c) the word "may" glues We discretion without any obltgatoon to take any action. 17, 6orrower's. Copy. Borrower shall be given one copy of the Note and or this Security Instrument. 18. Transfer of the Property or a Benefic4al Interest in Borrower. As used in this Section 18, "Interest in the Property" means any legal .or. beIvficial interest in the Property, Including, but not limited to, those beneficial Interests transferred in a.bgnd for deed. contract for deed, instaltrrim. t sales contract or escrow agreernent, the intent of'Ofth it the transfer of title by.Borronrer at a Althure date to a purchaser. If ail or any part of tfte Froperiyy or. any Interest in the Property. s old or transferred {or if Borrower Is not a natural person and a beneficial interest I' Borrow is scild °a transferred} without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security instrument. However, this option shalt not be exercised by Lender it such exercise Is prohibited by Applimble Law. If Lender exer±cises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not ims than 34 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this. Soaccu'ity instrument. if Borrower fails to pay these surns prior to the expiration of this period, Lender may invoke any remedies permitted by this Security instmment withoiX further notice .or demand on Borrower. 19. Borrower"s Right to Reinstate After Acceleration: If Borrower meets certaln conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of: (a) Five deys before sale of the Property p rsuant to any power of sale conte3rhed in this Security rnstrument, (h} sucft other period as Applicable Laing might speafy for the termination of Borrower's right to reinstate; or (c) entry of a.?i'tldgrrxint en#oresra9 this Security Instrument. Those conditions are that Borrower: (a) pays Lender all s?[lttts which 'then would be due under this Security Inswmerit and the Note .as if no acceleration had occurred; {6) sores any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attdrne'y-? fees, . roperry inspection and vakmtion fees, and other fees incurred for the se of protacting l_ender's ientarest In the. Property and -rights under this Security instrument; and (d) kes such aWain as Lender rray reasona l???++ require fo assure that Lender's Interest in .the Propert? and rights tinder this Seciti'ity Instrument and >3orrower's obligation to pay itie sums secured by this Sebxity instrument, shall continue uncha ed. Lender may require that 8o MW pa such reinstaterrant sums and expenses in one or more of the allowing Forms, as selected by Leixiei (a) assb: click money n order; (6) certified check, bank check, treasurer's check or cashiers check, provided any upon 1VjYtYANIA•5MW6 Fsrny,FoMie MNIFreCAelAM UNiFDRFiI INSTRUMENT Farm 9039 tl01 vMP9(48 (090 WdteM Maw PSa RdW Servkes Paget 3 w?- Loan #: 1022878 an institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower. A sale might result in a change In the entity (known as the "Loan Servicer") that collects Periodic Pay alts lute under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security lnstrumenL and Applicable Law. There also might be one or more nges of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should ba made and any other information RESPA requires in connection with a notice of transfer of servicirg. IF the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the Nate, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other partY's actions pursuant to this Security Instrument or that alleges that the other party has breached any provis on of, qtr .airy dut owed by reason of, this Security Instrument, until such Borrower or Lender tray notified the Duller party with such notice given In compliance with the requirements of Section 15) of such alleged trreach and a the other party hereto a reasonable period after the giving of such notice to take corrective action. if Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances damned as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides; volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b ' Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (c) "Environmental Cleanup" includes any response action, remedial action, or removal action, as defined in Envirorxnental Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any hazardous Substances, or threaten to release any Hazardous Substances, on or in the Aroperty. Borrower Mall not do, nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b) which creates an Environmental Condition, or (c) which, dui; to the presence, use, or release or a Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of PENVYLVANIk-"e family-ia"M M30IFYO the Met UNWORM INSTRUMENT ram 3039 1101 VMAPOPA) tO9O7) VMP Pap -1 d. ow Wchers Kluwer fhtarKlal SultiaCeS Hazardous Substances that Greer?ally recograta maintenance of the Property (including, but ruts tin Borrower shall promptly give Lender written or other action byy, any governmental Hazardous Subst xe or Envimn Environmental Condition, including release of any Hazardous Substance Hazardous Substance which adverse b any governmentai or regulatory o any a?dous Substance affectsn9 remedial actions in accordance with Lender for an Environmental Cheanu NON-UNIFORM COVENANT 22. Acceleration: Remedies. L amour c must l5e 3orower to acceler nay require immet ther demand and i dried to collect all c )ut not limited to, ?w Lender further covenant and notice to Borrower prior t t in this Security lnstrtur Law provides btherwi% 51 the actiori required to ct any other Lender at n}iiarwpv.` 23. Release. Upon payment of all sums secured by this Security Instrument, this Security. Instrument and the estate conveyed shall terminate and become void. After su occurrence, Lender shall discharge and satisfy this Security InsWrnlent Borrower shall pay a recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriffs sate or other sale pursuant to this Security Instrument. 26, Purchase Money Mortgage. if any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument sha be a purchase money mortgage, 27. interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. PE?? "MtkSt4e Faft*j.Fam* MoeMfedM Mot UWF'ORM INSTRUMENT Form 3wo vat Mfl s V~A)TS ' paw W Wdws lfiMV Fkt jm swvcos Loan .#: 1022878 i be appropriate to normal residential uses and to to, hazardous substances in consumer products). ce of (a) any investigation, claim, demand, lawsuit mental Low of wh?ch rower has actual knowledge, (b) any , and (c) any condition caused by the presence, use or release of a ly affects the value of the Property. If Borrower learns, or is notified authority, or any private party, that any removel or other remediatinn the Property is necessary, Borrower shaft promptly take ell;rssary Environmental Law,. Nothing herein shall create any obligation on or regulatory agent or private parry Involving the Property and any but not limited to, any spilling, leaking, discharge, release or threat of Loan #: 1022878 This is a contract under seal and may be enforced under 42 PA. C.S. Section 5529(b). BY SIGNING BELOW. Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. Witnesses: (Sean -Borrower (Seal.) -Borrower (Seal) -8mewer (Seal) -Borrower (Sea!) Borrower (Seal) -Bor vAv (Seal) -Borrower P%W§YLVANrA-"e Fa 1i 4panla.fAaelFreddie MacUMFOR1s 0 STRUMEN7 VMP NN wcow, mAver of anm sej*as Rim 3030 7107 Y0.AP P(PAY? 09 Loan #: 1022878 COMMONWEALTH OF PENNSYLVANIA. County ss: On this, the 15 day of July 2090 personally appeared before me, the undersigned officer, Jacqueline Aco, {min to me (or satisfactorily proven) to be the person(s) whose name(s) islare subscribed to the within instrument and acknowledged that helshelthey executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: NOTARIAL SEAL AXIE B 0TEFATI0 Notary Pubac LOWER ALLEN TNIP., GUMBERLAtM 0M My Gometlsslan t xpiras Nov 25, 2013 Title of of mr Certificate of Residence I. I- , do hereby certify that the correct address of the within-named Mortgagee Is 4185 West Market Street, York, PA 17408-5933. Witness my hand this 15 day of July 2010. fit... _ rgent of ftiso ippe ? PEN,jYLVAHUI•ShP FamiyFanne Mae#feod"ie Mac UNIFORM INSTRUUENT Famf 3D39 1g1p071 VMP ??' ,t0r ear WdM% Kluwer Flnandai Servkcs 10-01319'612 EXBISIT "A." ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PRNNSYL'VANIA, BOUNDED AM DESCRIBED AS FOLLOWS BEGINNING XT A POINT ON THS NORTHERN LINE OF MICHAELE 'DR2VH, SAID POINT SEIM 101ATED AND REF.ERENCBD SOUTH 81 DEC 30 f WEST. 225 .'00 . FEET FROM THE XORTIMBST CORNER OF THE INTERSECTION OF MICH"LE AJW DAWN DA3VE3; THENCE ALONG THE NORTHW W LINE OF MICHASLE.DRIV79 SOUTH 81 DEG 30! WEST, 82.92 FSBT TO THE POINT Aans THE NORTIMEN LINE OF MXW=LB DRIVE rNTERSECTS THE EASTERN LINE OF CONNIE DRI7Z) TWNCE ALONG THE EASTERN LINE OF SAID CONNIS DR= NORTH 28 DEG 301 WEST, 187.45 FEET TO TUN SOUTHERN Ia"I'll OF I.S.00 'PERT RIGETI' OF WAY; THENCE ALONG SAID RIGHT Olf WAY NORTH 81.DRG 301 SA:ST, 150.00 FEET TO THE .Di=TMRST CORM 2, 0 THENCE ALONG THE NESTE" LINE OF SAID LOT NO. 20 SOUTH 08 DEG 30' FAST, 175.0 FEET TO A POINT OU THE NO 9x LIM OF MICS1=Z DRXVE, TRM..PeLACE OF BEGINNING. BEING TOT NO. 2.1 (ERRONEOUSLY'9TATED AS LO'T'21 AND 22 IN PRIOR DEED) ON PXM 'OF LOft OF FROPURTY OF .-SAX L. MG'CO?BS AND ESTM$t MCCOMBS RECORDED IN MrAN BOOK 7., PAGE 19. BEING THE Wa= PROPERTY CONVEYED TO TAYLOR, BEAN & WHITAKER MORTGAGE CORP. BY DEED FROM THOWAS R.-KbINE, SHERIPr OF THE COUNTY OF CUMBERLAND, PA. RECORDED 03/23/2007 INDEED BOOK 279 PAGE 1220, IN THE OFFICE OF THE RSCORDER OF DEEDS OF CUNBERLAND COUNTY, PENNSYLVAWTA. t/ ROBERT P. ZI EGLER RECORDER OF DEEDS CUMBERLAND COUNTY I COURTHOUSE SQUARE CARLISLE, PA 17413 717-240-6370 Instrument Number - 201020622 Recorded On 7/29/2010 At 11:36:39 AM * Instrument Type - MORTGAGE Invoice Number 69436 User 111) - KW * Mortgagor - ACO, JACQUELINE * Mortgagee - SUSQUEItA.NNA BANK * Customer - FIRST AMERICAN TITLE INS * FEES STATE WRIT TAX. $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $39.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $90.00 * Total Pages - 19 Certification Page DO NOT DETACH This page is now part of this legal document, I Certify this to be recorded in Cumberland County PA o ? - RECORDER t) D D5 4- raac * - information denoted by an asterisk may change during the verification process and may not be reflected on this page. 1111111111111111111111 EXHIBIT "C" . ?i CERTIFIED MAIL 9171" 9991 7030 6680 3584 Date: May 9, 2012 TO: Jacqueline Aco RE: Mortgage Loan # XX185224 Susquehanna Susquehanna Bank P.O, Box 639 Maugansville, MO 21767-0639 Toll free 888.722.7270 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Susquehanna Bank now Susquehanna Bank, (hereinafter we, us or ours) on your property located at 2006 Connie Drive Enola, PA 17025 A. IS IN SERIOUS DEFAULT because you have not made monthly payments and other charges for April 1. 2012 thru May 1, 2012 as follows: Principal Amount Due: Interest Amount Due: Attorney Fees: Appraisal Fees: Title Search: Force Placed Insurance: Escrow: Other: Late Charges: $ 331.98 $ 1,243.18 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 402.70 $ 0.00 $ 39.38 TOTAL AMOUNT TO CURE THE DEFAULT $ 2,017.24 The total amount now required to cure this default, or in other words, get caught up with your payments, as of the date of this letter is $2,017.24. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable.) 0.00 2459591-1 E, You mgy cure this default within THIRTY (30) DAYS of the date of this letter, by having to us the above amount of $2,017,24, plus any additional monthly payment and late charge which may become due if payment is not made by June 11, 2012. Such payment must be made either by cash, cashier's check, certified check or money order and sent to: Susquehanna Bank C/o Susquehanna Loan Center P.O. Box 639 Maugansville, MD 21767-0639 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) 0.00 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage pa my tints. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original. mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. IIf the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. Such suit against you personally may also result in your mortgage being foreclosed and your mortgaged property being sold at Sheriffs sale. If we start the lawsuit to foreclose your mortgage, or if we sue you personally for the unpaid balance and all other sums due under the mortgage which may also result in foreclosure and sale of your mortgaged property, you have the right to assert in either of those lawsuits the nonexistence of a default or any other defense you may have to acceleration and foreclosure. If you have obtained an Order of Discharge from the United States Bankruptcy Court, which includes this debt, we are not attempting to obtain a judgment against you, nor are we alleging that you have any personal liability for this debt. We may, however, take action against the property pledged as collateral for the debt, which may include repossession and/or foreclosure of the property. If you have not cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the 2459591-1 I Sheriffs foreclosure sale You may do so by pUing-the total amount of the unpaid monthly payments plus any late or other charges then due as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately September 6, 2012. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: Name of Lender: Susquehanna Bank Address: _C/O Susquehanna Loan Center, P.O, Box 639, Maugansvilie, MD 21767-0639 Phone Number: 888-722-7270 ext. 27222 Fax Number: 240-313-1563 Contact Person: Deborah E-Mail Address: LoanCtr-Collections(asusquebanna.net This payment must be in cash, cashiers check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interests in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Susquehanna Bank offers consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided without cost to our customers. You may be eligible for a loan workout plan or other similar situation. If you would like to learn more about these programs, you may contact the Susquehanna Bank Collections and Recovery Department 1-888-722-7270. WE ARE VERY INTERESTED IN ASSISTING YOU. Attention Servicemembers and dependents: The Federal Servicemembers' Civil Relief Act ("SCRA") and certain state laws provide important protections for you, including prohibiting foreclosure under most circumstances. If you are currently in the military service, or have been within the last nine (9) months, AND joined after signing the Note and Security Instrument now in default, please notify us immediately. When contacting Susquehanna Bank as to your military service, you must provide positive proof as to your military status. If you do not provide this information, it will be assumed that you are not entitled to protection under the above-mentioned Act. 2459591-1 I For your benefit and assistance, there are government approved homeownership counseling agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling agencies, please call (800) 569-4287 or by visiting http://www.hud.gov/offices/hsg/sfh&cc/hes.efin. You may also contact the Homeownership Preservation Foundation's Dope hotline at (888) 995- HOPE (4673). This matter is very important. Please give it your immediate attention. Deborah, Collector II Susquehanna Bank 1-888-722-7270 ext. 27222 2459591-1 MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOl PROVIDE FOR INSil-If" _ onc-aaecrea Susquehanna Bank Received From: Attn: Collections PO Box 639 ' `. Maugansville, MD 21.767-463 4 Y One piece of ordinary mail addressed m: Ca -i ?tv ?0061 ?1,19 f) ?;el ?? PS Form 3817, Mar. 1989 3599 ?a r) ^J f ?? cn rV n m _ o, ti N? tr) O? ? ?? a A r O w N G ED ipi I.? „? 4 } Ile ' _ ?• .... Lr, O It ?s?3lIN? C-0 W IA ?R tLl ylQ0 ?' - W LO r4 • C,l?C teak-• CS 14 L£+ w++ W W I'J Lr) 0 LO 1..4 m L) IN x Q W L LJ t?.•- .!? _n ZZQ _u JZd M C.0 C) V C3 z rq ? W ' Er ? .?. ? ?p tE'y co to o ! Ca CD > m U t? j Mp?GM G ...? ? I C d J ti M f/J Co z 3 a y L° I 0 C¢7 a - M to cn a O Q CO a: ? ! 1 is t i i USPS.comg - Track & Confirm English Customer Service U9Ps Mobile Page 1 of 1 Register I Sign In jaaPLn USPS,i:otri JS TrdCk Paukag[3,5 ??ps-c? Quick Too!s Ship a Package Send Mait Manage Your Mai! Strop Bu siness Solutions Track & Confirm w?1 i•_:.?. u. , ?ac:aTe.? YOUR LA8EL NOVEiER SERVICE STATUS OF YOUR ITEM DATE4 TVA.. LOCATION }EXAMES a First-Chas Maiir Delivered June 04, 2012. 11:08 am : MAUGANSVILLE. MD 21767 Expected Delivery By. 91 ti 99999i743aSSS036a May 11, 2012 Certified Mail Return Recelpt Electronic "co Left JUns02, 2012,. 11:41 am MAUGANSVILLE, M021T67 processed through June 01, 2012, 832 Pm BALTIMORE, MD 21233 uSPS Son Facility Unclaimed May 29,2012,12'40 Pm ENOLA, PA Notice Left May 11, 2012, 10:18 am ENOLA, PA 17025 Electronic Stopping Into . May 11, 2012 Received Processed at LISPS May 11,.2012. 4,38 am HARRISBURG, PA 17107 Origin Sort Facility Acceptance May 10, 2012, 11:19 am LITITZ, PA 17543 Check on Another Item v%mars your label (or receipt) number? LEGAL ON USPS.COM ON ASOUT.USPS.COM PtivRcy Governme".1 Services : Abnlt LISPS Home Ts±ntts of V., , Buy Stamos 8 Shoo a iJCVSsmom > FOiA , Print a Label wAft Postage , Mail Sarvlcs k1F3ates, by FP'.Fp A tE.C *M C,ttsionter $9 JIC4 > Fomti $ PWAr, YXS? ` Site Index OTHER LISPS SITES Baslnrss sha?iP.r Gatoway t Pa4r' iRSpectors , Insor {;and-3l . Postal E,cFI:Fer , u'Pinpr;?`=' .'C12 S Al RV; Its RoM"vett https://tools.usps.com/go/TrackConfirmAction.action 6/13/2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, Plaintiff, VS. JACQUELINE ACO, Defendant. CIVIL DIVISION NO.. VERIFICATION I, Christina Frederickson, on behalf of Susquehanna Bank, depose and say subject to the penalties of 18 Pa.C.S.A., sec.4904 relating to unworn falsification to authorities that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. Date: By. Christina Frederickson I g IU; r. !m . Susquehanna Bank, r k Plaintiff(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Jacqueline Aco Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request an appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for the conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfull ub ' e - By: Date ScottA. Die Brick, Esquire PA I.D. # 55650 Kimberly A. Bonner, Esquire PA LD #89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Susquehanna Bank, Plaintiff(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Jacqueline Aco, Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the property which is the subject of the mortgage foreclosure action; 2. Defendant lives in the subject real property, which is the Defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in the Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Signature of Defendant's Counsel/Appointed Legal Representative Signature of Defendant Signature of Defendant Date Date Date Susquehanna Bank, Plaintiff(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Jacqueline Aco, Defendant(s) : Civil CASE MANAGEMENT ORDER AND NOW, this day of 2012, the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for. Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for scheduling a Conciliation Conference, it is hereby ORDERED and DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised Conciliation Conference on at .M. in at the Cumberland County Court House, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which the service of the completed Form 2 is to be made may be expected. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the timeframe set forth herein or such other date as agreed upon by parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceeding shall be terminated. The defendantiborrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty moths; and the institution of bankruptcy proceedings. All proceedings in this matter are stayed pending the completion of the scheduled Conciliation Conference. BY THE COURT. FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete. your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different) City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: State: Zip: Home: Cell: Office: Other: Email : # of people in household: How long? First Mortgage Lender: _ Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: State:_ Zip: Yes ? No ? Listing date: Price: $_ Realtor Phone:_ Yes ? No ? State: Zip: Home: Office: Cell: Other: How long? Date You Closed Your. Loan: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $_ Automobile #1: Model: Amount owed: Value: Automobile #2: Model: Amount owed: Valuer Other transportation (automobiles, boats motorcycles): Model: Year: Amount owed: Value_ Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: _ Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food _ 2° Mort a e Utilities Car Payment(s) Condo/Nei . Fees Auto Insurance Med. not covered Auto fuel/re airs Other pop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax:- Year: Year: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Vt Copy of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) Phone: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor tp MIN, T Susquehanna Bank vs. Jacqueline Aco t?f5l2 JUL -3 AM 8, 24 ,UMBERLAND Pc,-NN;YLVA4- 4A Case Number 2012-3857 SHERIFF'S RETURN OF SERVICE 06/22/2012 08:40 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2012 at 2040 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Jacqueline Aco, by making known unto herself personally, at 2006 Connie Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.00 June 28, 2012 RYAN BURGETT. DEF SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, CIVIL DIVISION Plaintiff, vs. JACQUELINE ACO, Defendant. I Hereby certify that the last known address of Defendant(s) is/are: 2006 o e Drly~ ola, PA 17025 No.: 12-3857 CIVIL ISSUE NUMBER: TYPE OF PLEADING: ~:, : , t. ~~iaT~~OP~OTA~~r° '~'~2 A~l~ 2~ ~ 3~ 15 m~1~~9ER1~,4 COUNTY ~ENNSYL ANIA PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF: Susquehanna Bank, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 Scott A. Dietterick, Esquire Attorney for Plaintiff JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 (1,µi ~ll~~ ~ a' ' ~# I33 3 ~~~ ~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, CIVIL DIVISION Plaintiff, NO.: 12-3857 Civil vs. JACQUELINE ACO, Defendant. PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIlt/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Jacqueline Aco, in the amount of $141,220.95 which is itemized as follows: Principal $ 135,697.22 Interest through 8/23/2012 $ 3,566.33 Late Charges $ 196.90 Satisfaction Fee $ 50.50 Attorney's Fees $ 1,300.00 Title Costs $ 410.00 TOTAL $141,220.95 plus interest on the principal sum ($135,697.22) from August 24, 2012, at the rate of $20.6553 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure an~ sale of the mortgaged premises. J. By: (,/ Scott i Atto ey for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 23 ; Sworn to and subscribed before me ' ~ day of August, 2012. Notary Public My Commission Expires: 3 - ~ ~a~ C(NviMONWEALTH CAF PE?NNSYI VANIA NU"fARIAL SEAL DENISE L. FOSTER, NOTARY PUE3LIC CITY OF HARR[SE3URG, DAUPEEIN COUNTY MY COMMISSION EXPIRES MARCH (IS, 2Q13 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, CIVIL DIVISION Plaintiff, NO.: 12-3857 Civil vs. JACQUELINE ACO, Defendant. NOTICE OF ORDER DECREE OR JUDGMENT TO: Jacqueline Aco ( )Plaintiff (XXX) Defendant ( )Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ~/°1 )~ ~Ji.Z ( ) A copy of the Order or Decree is enclosed, or (XX~~) The judgment is as follows: $141,220.95 plus interest on the principal sum ($135,697.22) from August 24, 2012, at the rate of $20.6553: per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosur d sale of the mortgaged pr ' es. ~- ~.µ . Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, CIVIL DIVISION Plaintiff, NO.: 12-3857 Civil vs JACQUELINE ACO, Defendant. IMPORTANT NOTICE TO: Jacqueline Aco 2006 Connie Drive Enola, PA 1.7025 DATE OF NOTICE: July 13, 2012 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST ~'OU. UNNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAK THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK, CIVIL DIVISION Plaintiff; NO.: 12-3857 Civil vs. JACQUELINE ACO, Defendant. AVISO IMPORTANTE A. Jacqueline Aco FECHA DEL AVISO: July 13, 2012 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEL PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE L'N ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICII~TA ABAJO INDICADA PARR QUE LE 1NFORMEN DONDE PUEDE CON5EQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 ..--_ JAMES DATE: July 13, 2012 & CONNELLY BY: `~~. -! ~ ~ Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire PA LD. #89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~4tip~tr nt ~~rtabrr~~~~4 Ca , ~;i i ~AiiF e4~j' }~ pF~IGE 4F TtsE S~ERiFF Susquehanna Bank vs. Case Numbe Jacqueline Aco 2012-3857 SHERIFF'S RETURN OF SERVICE 06/22/2012 08:40 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June ; 2012 at 2040 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and NoticE Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Jacqueline Aco, by making known unto herself personally, at 2006 Connie Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true correct copy of the same. RYAN BURGETT, DE SHERIFF COST: $43.00 June 28, 2012 SO ANSWERS, R ANDERSON, SHERIFF (c) CountySuite Shenft. TeieoscNt. Ir. of d T_, _ ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-3857 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUSQUEHANNA BANK Plaintiff (s) From JACQUELINE ACO (1) You aze directed to lery upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You aze also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $141,220.95 L.L.: $.50 Interest FROM 8-24-12 TO DATE OF SALE - $2,127.49 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $194.25 Other Costs: Plaintiff Paid: Date: 8/27/2012 ~ ~ ~ ~ J ..IJf~~S.Cr~,LL David D. Buell, Prothon tary (Seal) Depu REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE Address: JAMES SMITH DIETTERICK & CONNELLY LLP P.O. BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 r T IN Z~ CIOIfJRT QF OC~I P7~EAS OF C~N~ERLArID C~O[RdI'Y, PaH~SYLVAAII A Susquehanna Bank CIVIL DMSION File No. 12-3857 Civil {Plaintiff) Amount Due 141 2 0.95 v Interest from 8-24-2012 to $ . 2,1 7.49 date of e Jacqueline Aco At ty' s Coma ~-, ~ ~`` COStS (D f d -per '"~ ~..-.,s e en ant{s) ~ N ~ TO THE PROTHONOTARY OF THE SAID COURT: ii c --G =' --i a ~, The undersigned hereby certifies that the below does not arise out of a l ~-~ instal.Lnent sale, contract, ar account based on a confession of judgment, but t s~ ~: it-is based on the appropriate original proceeding filed pursuant to Act 7 of ~~ ax amended; and far real property pursuant to Act 6 of 1974 as amended. ~ ~ T PRADCIPE FDR II~C[TIZON Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) See Exhibit "A" attached. PRADCI:PE FL3R A7.TT ~IC[Q Issue writ of attachment to the Sheriff of County, for d bt, interest and costs, as above, directing attachment against the above-named garnishee( ) for the following property (if real estate, supply six copies of the description; supply our copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody ar control of said garnishee(s). (Indicate) Index this writ against the garnishee(s) s pendens ag st real estate of the defendant(s) described in the attached exhibi ~ pq~; August 24, 2012 qa4 , S°~d a~ y3~oo to u ~, ~~D~~uu a. (~s a a~ ~ 1~, v~ ~ Telephone: liti~ 5~3-3280 S'~1C v+'' Supreme Court ID No.: 556. ~~ ' Sp Lt_ Signature: Print Name: Address: James Smith Dietterick & Connelly LLP P O Box 650, Aerehey PA i Attorney for: Plaintiff Ck,Y ~'ssio-~ Q~a,9`~`i~P ~r~~ of ~ ~TsS LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Northern line of Michaele Drive, said point being located and referenced South 81 Deg 30' West, 225.00 feet from the Northwest corner of the intersection of Michaele and Dawn Drives; thence along the Northern line of Michaele Drive South 81 Deg 30' West, 82.82 feet to the point where the Northern line of Michaele Drive intersects the Eastern line of Connie Drive; thence along the Eastern line of said Connie Drive North 29 Deg 30' West, 187.45 feet to the Southern line of 15.00 feet right of way; thence along said right of way North 81 Deg 30' East, 150.00 feet to the Northwest corner of Lot No. 20; thence along the Western line of said Lot No. 20 South 08 Deg 30' East, 175.0 feet to a point on the Northern line of Michaele Drive, the place of BEGINNING. Being Lot No. 21 (erroneously stated as Lot 21 and 22 in prior Deed) on Plan of Lots of property of Max L. McCombs and Esther McCombs recorded in Plan Book 7, Page 19. HAVING thereon erected a dwelling house being known and numbered as 2006 Connie Drive, Enola, Pennsylvania 17025. BEING the same premises which Selene Rmof Reo Acquisition II, LLC, a Delaware Limited Liability Company, by Deed dated June 22, 2010 and recorded on July 29, 2010 in and for Cumberland County, as Doc# 201020621, granted and conveyed unto Jacqueline Aco, a Single/Married/Unmarried Person. Parcel No. 10-14-0842-022A Exhibit "A" IN THE COURT OF COMMON PLEAS OF ~ .. CUMBERLAND COUNTY, PENNSYLVANIA -- ~-,~ N SUSQUEHANNA BANK, Plaintiff, vs. : JACQUELINE ACO, Defendant. Zrn ~ ~; ~. ~ CIVIL DIVISION ~ ~ : 12-3857 Civ~a NO - 7 ~~ . z = ~ zc~ ~~ ~ ~ c : Cam, ~.a , -{ N ~' -~, ~; ~ ~-.. AFFIDAVIT PURSUANT TO RULE 3129.1 Susquehanna Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 2006 Connie Drive, Enola, Pennsylvania 17025: 1. Name and Address of Owner(s) or Reputed Owner(s): JACQUELINE ACO 2006 Connie Drive Enola, PA 17025 2. Name and Address of Defendant(s) in the Judgment: JACQUELINE ACO 2006 Connie Drive Enola, PA 17025 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: SUSQUEHANNA BANK Plaintiff 4. Name and Address of the last record holder of every mortgage of record: SUSQUEHANNA BANK Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. 7 Name and Address of every other person who has any record interest in the property and whose interest maybe affected by the sale: UNKNOWN SPOUSE OF JACQUELINE ACO DEPARTMENT OF REVENUE COMMONWEALTH OF PA 2006 Connie Drive Enola, PA 17025 PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which maybe affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. JAMES, DATED: ~ I o~t'I I ~ BY: Scott ~. ietteric s Pa. I.D. 5 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY LLP ___ _ _ ~ ~. ~ ° ' ~ R ~ "', 7c~ ~ rt R IN THE COURT OF COMMON PLEAS OF z ~ ~ -~.~ ~ , CUMBERLAND COUNTY, PENNSYLVANIA ~r C ~' ~" J o~ - SUSQUEHANNA BANK, Plaintiff, vs. : JACQUELINE ACO, Defendant. 'Z ~ ~~ o -~ CIVIL DIVISION ~~ ~ ~ r, c G? --~ : 12-3857 Civih ~ NO ^' . NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVA1yIA RULE OF CIVIL PROCEDURE 3129 Jacqueline Aco 2006 Connie Drive Enola, PA 17025 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 5, 2012, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 2006 Connie Drive Enola, Pennsylvania 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-3857 Civil THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Jacqueline Aco A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to beheld, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Cumberland County Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff s Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DI~`'TE~I~ & CONNELLY LLP DATED: `"~~ ~~- BY: S~tt A~i~tferick, Esquire P . I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF T __ __ LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Northern line of Michaele Drive, said point being located and referenced South 81 Deg 30' West, 225.00 feet from the Northwest corner of the intersection of Michaele and Dawn Drives; thence along the Northern line of Michaele Drive South 81 Deg 30' West, 82.82 feet to the point where the Northern line of Michaele Drive intersects the Eastern line of Connie Drive; thence along the Eastern line of said Connie Drive North 29 Deg 30' West, 187.45 feet to the Southern line of 15.00 feet right of way; thence along said right of way North 81 Deg 30' East, 150.00 feet to the Northwest corner of Lot No. 20; thence along the Western line of said Lot No. 20 South 08 Deg 30' East, 175.0 feet to a point on the Northern line of Michaele Drive, the place of BEGINNING. Being Lot No. 21 (erroneously stated as Lot 21 and 22 in prior Deed) on Plan of Lots of property of Max L. McCombs and Esther McCombs recorded in Plan Book 7, Page 19. HAVING thereon erected a dwelling house being known and numbered as 2006 Connie Drive, Enola, Pennsylvania 17025. BEING the same premises which Selene Rmof Reo Acquisition II, LLC, a Delaware Limited Liability Company, by Deed dated June 22, 2010 and recorded on July 29, 2010 in and for Cumberland County, as Doc# 201020621, granted and conveyed unto Jacqueline Aco, a Single/Married/Unmarried Person. Parcel No. 10-14-0842-022A Exhibit "A"