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Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(71738-6929
MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.: , a~
PATRICIA COX a/k/a PATRICIA A.
COX, DECEASED and
AMY L. FELTON, ADMINISTRATRIX
FOR THE ESTATE OF PATRICIA A.
COX, DECEASED
DEFENDANTS
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice aze served by entering a written appeazance 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 claims 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.
U
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IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA
Le han demandado a usted en la cone. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dial de plazo al
partir de la fecha de la demands y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o
sus objectiones a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la torte tomara medidas y puede entrar
una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la petition de demands. LISTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARR LISTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
LISTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
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.
SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE THE
VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30)
DAYS OF THE RECEIPT OF THIS NOTICE, COUNSEL FOR PLAINTIFF WILL
ASSUME THE DEBT TO BE VALID.
IF DEFENDANT(S) NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN
VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S) PROVIDE
COUNSEL FOR PLAINTIFF WITH A WRITTEN REQUEST 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 THE 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 REQUESTS 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/OR RECEIVED A DISCHARGE, THIS
IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A
LIEN ON REAL ESTATE.
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Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
PATRICIA COX a/k/a PATRICIA A.
COX, DECEASED and
AMY L. FELTON, ADMINISTRATRIX
FOR THE ESTATE OF PATRICIA A.
COX, DECEASED
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
_-1(~~ ~V' l~
NO.. ' o~
CIVIL ACTION-LAW-MORTGAGE
:FORECLOSURE
COMPLAINT
AND NOW, comes Members 1 S` Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1
Plaintiff, Members 1St Federal Credit Union ("Members 1St"), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Defendant, Amy L. Felton, is the Administratrix for the Estate of Patricia A.
Cox, deceased, having a last known address of 1102 Market Street, Unit 7,
New Cumberland, PA 17070.
3. Defendant, Patricia A. Cox a/k/a Patricia Cox (hereinafter "Cox"), died on or
about November 8, 2009, an adult individual, and letters of Administration
were issued to Amy L. Felton by the Cumberland County Register of Wills on
or about November 17, 2009 to Register of Wills file no.: 21-09-1065.
Defendants Amy L. Felton, Administratrx for the Estate of Patricia A. Cox,
deceased, and Cox are collectively referred to herein as "Defendants."
4. On or about August 9, 2006, Cox borrowed from and agreed to repay to
Members lst$35,000.00 (the "Loan"). The Loan is evidenced by a Closed-
End Note, Disclosure, Loan and Security Agreement dated August 9, 2006
(the "Note") executed and delivered to Members 1St by Cox. A true and
correct copy of the Note is attached hereto as Exhibit "A" and made part
hereof.
S. As security for the Loan, Cox executed and delivered to Members 1St a
mortgage ("Mortgage") on all that certain condominium situate in the
Borough of New Cumberland, Cumberland County, Pennsylvania, known and
numbered as 1102 Market Street, Unit 7, New Cumberland, PA 17070 (the
2
"Property"). A description of the Property is attached hereto as Exhibit "B"
and made part hereof.
6. On or about September 11, 2006, the Mortgage was recorded in the
Cumberland County Recorder of Deeds Office at Mortgage Book 1965, Page
2197. A true and correct copy of the Mortgage is attached hereto as Exhibit
"C" and made part hereof.
7. The Mortgage has never been assigned by Members 1St and is still held by it
as a valid and subsisting obligation of Defendants.
8. Pursuant to the terms and conditions of the Note, Cox agreed to pay to
Members 1St monthly installments of principal and interest in the amount of at
least $391.59 each, which monthly payments were subsequently adjusted to
$391.33 each, beginning on September 16, 2006 and continuing on or before
the sixteenth (16th) day of each month thereafter.
9. The death of Cox constitutes an event of default under the Note and the
Mortgage and payments due under the Note and the Mortgage are currently
past due for July 16, 2012 through November 16, 2012, as more particularly
described, in part, in the Act 91 Notice attached hereto as exhibit "D" and
made part hereof.
10. Members 1St gave written notice of its intent to foreclose Pursuant to the Act
of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. sue., and in
particular section 403 thereof, and of Defendants' rights in accordance with
the Homeowners' Emergency Mortgage Assistance Act, Act of December 23,
1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. sec ., by letter dated
3
11
12
13
14
September 21, 2012, addressed to Defendants at Defendants' last known
address via certified mail, return receipt requested. A copy of the said notices
are attached hereto as Exhibit "D" and made part hereof.
U.S. Postal Form 3877 evidencing the mailing of said Notices is attached
hereto as Exhibit "E" and made part hereof.
Simultaneously, Members 1St forwarded to Defendants the same Notices as
set forth in paragraph 10 above addressed to Defendants at Defendants' last
known address by United States mail, first class, postage prepaid, bearing the
return address of Members 1St. The Notices forwarded to Defendants in said
manner have not been returned to the offices of Members 1St as undeliverable
or otherwise.
The amount due to Members 1St under the Mortgage and the Note is in the
amount of EIGHTEEN THOUSAND FOUR HUNDRED SEVENTY-ONE
AND 42/100 ($18,471.42) dollars itemized as follows:
a. Outstanding principal $16,814.13
b. Interest to November 27, 2012 379.01
c. Late fees 78 28
d. Attorney's fees 1,200.00
e. Total due to Members 1St $18,471.42
Cox also agreed under the terms and conditions of the Note that in the event
of default there under Cox would pay, in addition to the amounts set forth in
paragraph 13 above, costs incurred by Members 1St as a result of the
institution and prosecution of these legal proceedings.
4
15. The obligation owed to Members 1 S` continues to accrue interest at the rate of
$2.8285 per day, through the date of payment and continues to accrue
attorney's fees.
16. Members 1 S` is not seeking a judgment of personal liability (or an in personam
judgment) against Defendant(s); however, Members 1S` reserves the right to
bring a separate action to establish that right, if such right exists. If one or
more of Defendants have received a discharge of personal liability in a
bankruptcy proceeding, this action in Mortgage Foreclosure is not an attempt
to reestablish such personal liability discharged in bankruptcy, but only to
foreclose the mortgage and sell the Property in accordance with Pennsylvania
law.
17. As set forth above, Members 1 S` has made demand upon Defendant(s) to
make payment of the amounts due to Members ls` under the Mortgage and the
Note. However, as of the date hereof, Defendant(s) continue(s) to fail and
refuse to pay such amounts to Members 1 S`
WHEREFORE, Plaintiff, Members ls` Federal Credit Union, demands judgment
against Defendants, Patricia Cox a/k/a Patricia A. Cox, deceased and Amy L. Felton,
Administratrix for the Estate of Patricia A. Cox, deceased, in the amount of EIGHTEEN
THOUSAND FOUR HUNDRED SEVENT-ONE AND 42/100 ($18,471.42) DOLLARS
plus interest at the rate of $2.8285 per day, through the date of judgment entered on this
complaint and at the legal rate thereafter until the date of payment, additional attorney's
fees and costs of suit as well as other costs and charges collectable under the Mortgage
and for foreclosure and sale of the mortgaged property.
i~wY ~~~titiy ~,av~iii~~cu, ( #
C.+ / j
Date: ~~- iG- ~ rZ- ~,• T' ,/~_
arl M. Ledebohm, Esq. ~
~5upreme Court ID # :59012
,~'~ P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
6
St
5D00 Louise Drive, P.O. Bax 40
Mechanicsburg, PA 17055
MEMBERS t•
rwwawnl+er
PRINGIrn~nwwn,
aORROMER u NAMI
PATRICIA COX
CO•BORROVVI:n~a rwAE
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed: The amount of Total of Payment3: The amoum
RATE: The coal of your credit as a The dollar amount the credH wW credit provkfed to you or on your you will have paid aHer you have
yearly rate. ' cost you. behalf. made ell payments ea scheduled.
6.14 9'0 . S 11,969.70 • S 35.000.00 S 46,989.70
VadabN RaM: II your loan hu ^ vaMbia nb n Indkaled above trte Amual Perantpe Rab may Menaw dunnp Ne terrrt q Mda Iransaedwt H the (Indes) changes. TM
credit union veil add • marpfn q b the Yedea valor. TM nb will rhanpe tnonW y on IM tint day or tM n7onth
TM nn wtl never M hi
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months and the Arvtual Pertenbpe Rate Inusawd M 27i aHer one year, tM Wrm of your loan would irwease by two month
•PnNmd Ret: II undced, the bdowinp applMe to your loan:
Aulomatk Payment OMeourl3W Rab: BWVas you Mw speed tO make your requred moMMy pryllNmt Nrouph an aubmalk Ntluttiort Imm your CMcklnarSavbpc
ant
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Fixed Rate Pnbmd Leans. H your ban k a Ifxsd nb ban and you gwlify for a prabrred nb, your ANNUAL PERCENTAGE RATE veil M die pMsned ANNUAL
PERCENTAGE RATE d4doaed above for as bn ore year proNrtsd stbe nmeins M seas.
NumMr rN Payment Amount of Paymen4 Payment Frequenry When Payment An Due Property Inauranu: You tray obtain property
instranlx hom anyone you warn that IS acceptable to
Payment 119
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your ehana aMrdr depont in the cndR union, and:
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AMOUNT FINANCED S 35,OD0.00 Amount Pald to others on your behalf (Describe)
AMOUNT GIVEN TO YOU DIRECTLY S 35,000.00 So'0° To M^1e1o1• We
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oo 7
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SECURITY INFORMATION
MAKE MODEL YEAR I.D. NUMBER
OTHER (Describ@): 1102 MARKET STREET UNIT 7 TYPE VALU
and/or Deposits of I S I I S ,
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than one Mnower, wa apse tltaf aY the rond'nions q the loan and a«udy aprNmerde powmkta dlie Iwn chap apPIY W Mth jointly and sewndy. You ackreoWletla that you Mve
r«ehrod a copy q 1M ben and s«udty apnemerMa ertd dl«beure attemenl. Co-signer: H you an dpnlnp ore wslpnar, you aeknowladps nuipl q Ms ngice b eo-sprtsr
ewNained on papa 2.
BO SIGNATURE OAT C0.MAKER 'OTHER OWNER ••C0.51GNER DATE
X (SEAL) X (SEAL)
^ C0.MAK R ^ •OTNER OWNER ^ ••C0.51GNER pATE ^ C0.MAKER ^ 'OTHER OWNER ^ ''COSIGNER DATE
X (SEAL) X (SEAL)
^ C0.M R ~ 'OTHER OWNER ^ ••C0.SIGNER DATE ^ C0.MAKER ^ 'OTHER OWNER ^ ''COSIGNER DATE
~( _ _ (SEAL) X (SEAL)
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oaavAnp eusaasro,lsnd;torn MaNrrendWeebrelute my(ouh eYtrt••try for Weunrwe: vEg y!O
t. (Applrable b IN ytwares Nwrede prey) YJe you M uMer pe 70 on dls sUndU« msaelM des q yw Idart9 ^X ^
2. (Appllwbw w deeEMr oewnP sett wN You N Utdel ape 70 en die wtewAW me11nY OaN q Yow IDan AID w pnNntlr wortkp ^ ^ ^ ^
W •ddewWe yw Name a WspN ar PmM i« 7tl ion w mon Pw weY erld hw ee~ w wonJrp hx ]0 derv «man before IfY• daN1 x X
N yw W N newe• i 2a,ddbA7 do 1W W WMp queoprWwn mnn dN w emwend W order to tlehrmbe NlproYlry. ^ ^ ^ O
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WYI rep M Insured. N mY OdrtpPw'~IY ar t erleWer •Yei b euutlM s. we uMerelMW IIIN we xe eMpile br msVwY'1 uD W en emouly rq gpeylp 31.00.
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or -/eneewa q oYlln ceeWleYp any ee.l.nwy fate MemlMlon or tww.Me /w Ih. purP~~• W rnYMedY1d, Irlrenneapt aenoerrryp •ny r~ meNrlel terNO ealnmhe a h•1rduWnt MeunnN Kt,
wtrtcn le . alms end sugetu wch penes W arlaerrll end cWll pnsMlN. Do not npn INe applWtbn r wy ~pplcaW. spec.. r+ NenIL epplketbn WN net e» uNd a oonl.q n ul a 0ww
eMnk epsees Mw Nt bMrl eompMlM, IM dNbr Iw net elpned end debd IM epplleNlon end f the eppNCatlen hN nor bevel wYnNNe. ~ ~
CREDIT INSURANCE APPLIED FOR: NOTE: ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE.
^ Yes ~ ND Single Credit Life ~ Total Premium ^ Yes X
^ No Credit Disabilty ~ Total Premium
^ Yes Q Na Joint Credit Life
IrdiCJ.n whkh appNrange): ^ Appkunt ^ Co-Appliewl i 0.00 Indicate which epplicanQs): ^ Apgieant ^ Co-Applicanl ~ :0.00
You en WwM efer hN aw IroY a raereee for reiew • d...s Y I,r4wur.,., ea. rw...~~~..
APP - B IGNATURE DATE OF BIR7H DAT CO•APPLICAN NATURE DATE OF BIRTH DATE
X 07` ~ X
WITN DA
T
E ECONDARY E E ICIARY (APPLICAN SECONDARY BENEFICIARY (C4APPLICANT)
j
1
MHGda-gea.77 A
MMC-07-0Y00.7]USER-NpRD F. ~7 76a Rev tqt
ompwwr, Inc. AI rldhn reserved.
Exhibit ~~A"
BORROWERS NprMi ~ LOAN NUMBER ACCOUM NUMBER GATE t)R LOAN
PATRICIA COXM~ 765217 ~ D$l0g/2000
IN THfS€S 80RROWER(S)T+rE WORDS 'CRE017 UNION• MEANS MEM8ER5 1$T FEDERAL CREOIT UNION. THE WORDS 'YOU,•'YOUR' ANO 'YOURS' MEAN THOSE
NAMED n
LOAR AGREEMENT
PaymanWFlnanca Charpas: Fw value receivatl, you promise to pay, at
the Credd Urdon's otflce, al! amounts due. All payments shall ba made
pursuant to the disclosure stattsmant on age 1 of this dolaartent. Ytw
understand that Ure finance charye and tats) of paymanb shown on page t
of IMa doctanent are based an Ute ttsstanptron that as Yulaliment payments
will be made on Ute scheduled due dates, and , g you have puaUfied for
preferred rtle that yoU rnnthue b saticly the tbrtdifions of that Dreferred
rate. It you tall to pay arty InstaMrttent by Ole time it b due, you will pay
addlUOnal infera6l on the Overdue amourN.
Allocation of PayrtroMS arM Additional Paymanb: Psymanb and
credits shall be appped in the idlwidrtp order: any amounts past due; any
fees or charges owing, inehxlinp arty insurance premlurrts; accrued irNereat
or finance charyas; outstanding principal. Payments made In addition to
regularly scttedguied payrttents shaft be appaed M the same order.
Prefsnsd RaU: If you qualif(yy for p pretertad rate as disclosed on pago 1 of
this tloarnent w w a sepuafe ptsNrred rata addendum, you wWenhurtl
that you must meet the conditbru disclosed fo border to quaUfy for the
yrefeP ed tarred atd.rtlyar ~ t moat ~e r:ond ytoirr tale will keep
increase, thereby eMending the terms of your loan. You promise to continue
making payments and b meet as obligaUans under this reemant oven If
you no longer receive the preferred refs.
Late Charges: If you make a late payment, you agree to pay a late dwrge
If one ~ disclosed on pegs t of ttNa aeument.
Property Iltsuranco: It you obtain a roan secured by a motor vehlGe or
other tangibb propery, you moat obtain insurance wtdeh proleds the audit
union kom Onanaal bss. The amount ono cover a of the property
insurance must be aaspl~bb to the aeda unbn~uch a poaq must
provide at least fro, tneR, combined addllional arvenpQes and collisbn
insurance. II must contain a Losi Payable riauae endbrsernenl naming the
credit union as lien hdder. Yau may obtain This insurance from any agent of
Poo'1 choice and tlired the agent to sand Ifre credit union a copy of the
Debtor Responslblgty: You promise to notlty t:retlil union of any change M
your name address or emplo nL You promise not b apply for s ban If
you know there Is a reaspprrobabufty rust you wig be unable to repay
yyour obligation acctxding to the terms of Oro aedrt exterobn. You promise
to inform credit urrbrt of arty new inltxmalion whbh relMes to your ability to
,nVOrmaUo^ o~iwip Win. Yooou~ea1aN~se~~ tO~seb false w Inacwrala
i Y 8 rig yotr ueditvrorlMneas,
credit standing, or uedit capacity.
Default: YOU shell be corutdered kr default it any of the lollowing oeeur. 1)
ll you break any promise made under Ihib Loan Agreement or under the
Sactmty Atabement: a [21 If you do not use the rnorrev the credit union
at the aernr urstar s upuun moor mrnuur r'u' rwrn:a, uo.aao nr~ ~.a.,
immetiiatety due and payable, era! you must Imnredlataty ppay to the credit
union at thst time the total unpaid balance, as wag as the Flntmt:a Chsrge
to date, any fate Gorges and coats of coaection permitted trtder law,
inGudingg reasonable atiorrte~s teas, chat the oredil union msy Incur, up !o
20 % of the unpaitl prktdooaalI and Interest. Costa of cdlaclion inGUde, Dtn are
not limited to, repossessbn tees, appraisals, anvirOnmenlN eke
assessments, cewahy dsmags tnwrance ~ovefraagg~e~~ and attorney's fees for
env adfan taken by an atiomev In order to cdkelTMs loan w preserve w
Sututory Lbn: U you are in dafaug, federal law gives the uedil union lire
right to apply the balance of auras anNw dividends In our account(s1 al
the tune o lauq to aaUsN 1Ms ben. Once you, are In dyefault, the ueddd
union may exerdse chit rl t without further rtotrx to you.
Delay In EMOrcamMt: Credit Unbn may delay enfordng any of the uedit
union rights under ihia agreement without losing itrtun.
Irregular PaymanbugTtu uedit unbn may accept late payments or paNal
credi~unbn righb urx7er fhb agroemantnl m fuN, without losing any of the
Co-makore; II you era siggNng this agreement as a co-maker, you agree 10
be equally responsible vnlh the borrower, bui Itte uedo motion may sue
either w 6oln of you. The credM union does rid have to nollly you that tMa
agreement has riot been paid. The uedll union may extend the terms of
payment arW release arty security without wtitykp or releasing you from
responatbilily on This agreement.
Contractual Plrope M BneM: You pNdps as yow aMns Nd dspoelb In the
credit uMOn, inctudinp fuW n •ddhbm, N eacuAy for this loan, it use you
drfault. tM ersdn union may apply 1MN aMres end dapoalb b Ms pryrmnt
or as soma dos at tM rim of dsfeW4 Hreludlnp cosh M oellrofbn and
nueruDN atbrnyr's Ms, Mat tM eradil Wderr may Incur, up b IDy. of Ms
unpaid prlnclpal and InterNt No Ben or dpM b bnprNe • lbn on sham •nd
dspalb shag aPMY b arty dYour •Mns which msy M held rn an 'Yndlrldwl
Retlrsment AccounC' or "Krogh pun.`
8100 Y/a9
You ors being asked to uarsnttee this debt. Think carefully before you Oo. tf the borrows doesnY pay the debt. you will have to. Bs sure you can afford to
pay it you nave to. and that yw want to accept this responsiWlity.
You may Mve to pay up to the fuU amount o1 the debt if the borrower tloes not pay. You may also hwe to pay Isle tees or eosadion costs, which increase this
amount.
The asdilor can co11eG Ihls debt from you without Out trying to wlbG from Itte borrower. The credllor can use lire same colledlon rttelhoda against you that
can be used against Ire borrower, such as suing you, gamrshMg your wages, etc. If Ihis debt Is ever in defatat. that faa may bescome a part ofyour uedit
record. This notice h not the contraG Ihsl makes you liable for t dehl.
SECURITY AGREEMENT
1. To Neun sevmsnt of I
My
momy AaouMhdd poleg,t rpulrMmnb en e W Medl, or an non-purchNo
2. Yov rNN not Wrtpe the boson d, sell or Inns/eI the wxstsnl unless you haw
Uts aradN union's prior wMten catasM
J. You Warrant TNheatnYOUIMMw oood 1111+ b 1~Maxgwaolalm4 lroe d aB ~4wriy idansu
njap~ker~obw+iti+dr W dMla ooaauNNniltw~lro hu ~gnaa~Ih~app~oi?+dM~~~t rU~1plnl~dnien al dP~
,. Wa~gqrn~iasbl~NW~ti~ d Ua r Wh unions r~eQWit an0~ i~fn i Y
opener adorhMnas Nkd pary~tyy tlakm ~~y ppy~ ppp~y WoPem
5. sn ouM aal~sfaday b Ihi I~~mTgrLis'~wRa.. W o~ro71v ~~ in i farm and tlf Pmol
or such IMUranu urWY~wlf sh~ima ow~end b audit u4ngkuirn~" es enNt wbd6ron
ri not ors , otilaM Inwnnn W Warn aow~n ant add IM aql of~iud~ b ths~
sums owed. Beat Wp tNUrMYnst N pre COrWatl urgl paid. You hrnMr
a~aipn b IM aadl union ate fight b rsosrw Br of uy Insurancq' an
ouch pppa~ry, arM disU arty tMUnr b pry Ihoaipows~da d~v b ersd~
unirn: You pta uadk union b sndaw drry cheek or clue prov to
eerie crMil unio such rnwrsnu, and apply cross proesWS b tlts sums owed b
You funMr wlhorks Ina updh union p pmvldr yow Insursnrw Servke Cenrsr
rdY1 rite necaawry iMOnntbn Ior vsrilKeaon d atleRWb oowraps.
You a dppse But IMUnnca w Nv sxbnabn IMnwl, pbud ate aadit
union a yrItlroW-bsneflt b you ind'rvidualy but b primarily for tM pm coon of the
crodk unwt,
6. Should the petllt unbn INl et any pmtrrMt nor riy Dr.Nnbd h..
drmiroshad in value, a for qty on hN tlut a~naf Nwily is n isd, ou
Ba u~il uroen rbi:li nnwaawaryW"io pWrouci)tliiyaadil unbn ipdaiMW ~Hde~
loss.
F. 43TBg 1102
AvvRO srrr..,.. rM., n4rars
Page 2 of 2
TM Crsdl unbns~bd{Ihit1tenpbyn Mad NYOUr ABOmav-krFaa b pMmrn an
see~wtyrty r~ilsr~p~whkhwtMS fapnmrd txeayarbay b Wo act ere tMEnent and tXe
I IMn Is mps dun one bonowartyour obaoakona vrd+r Mis apnsmant ors
loinl and Nw Ncn bein Wwrry nsponibb to ru1Bp tM terms d rule
apnsrtnnl. y
heliras w diiupn~snl not ony binds You, but Your axeculon, adminiatmm~,
AL.l. THAT CERTAIN. Unit, being Unft B-2 a/k/a No. ~' (the "Unit'), of Marketplace
Townes, A Condominium, located in New Cumberfand Borough, Cumberland County,
Pennsylvania, which Unit is designated in the Dmdaratiean of Marketplace Townes, A
Condominium (the "Declaration of Condominium} retarded In the Recorder''s 4fRr~ of
Cumberland -County ~at Boo1c•; 71& page 4808 and Pieta and Plans ass recorded in the
Recorder's Ofhce of Cumberland County in Book 84, Page 43, an October 34, 2001.
TOGETHER with an undivided 5.8823S9rO interest in Common Elements as more
particularfy set forth in the afpregaid Declaration of Condominium and Plats and Plans,
• as amended aforesaid.
TOGETHERwith the right to usla any limited common elgmerrts applicable to the Unit
being conveyed herein, pursuant to the Declaration of Condominium, as amended.
tHE ABOVE DESCRIBED premises are conveyed under and subject to an easement to
the owner of the properly located at ~(?8 EFeventh Street, New Cumberland, Pennsylvania, his
heirs and assigns, for a one story bkx~c buiklyng which encroaches an lire easement area to
make repairs, replacement and, msintenanve thereoo and yard arost over that certain trail of
land desaibed ewe extending nortltwardly to said ab4va desctit~sd `Sutton' Trail" for s die#ance
of 15 feet and beir~ 37 Beet in Width throt~hout, until the ors story block twildir~ which
encroaches on saki eaaremenE area is totally demdishsd by any cause whatsoever.
R IS UMDER3TOOD and agr®ed tf~at the above described promises may have had or
has eaaemerrts and rights in strosts, aNeys and alleeyways, whether unopened, undedk~tad,
vacated or papa; stroets on plans for arms between 11'" and 12"' Streets and Market and
Bridge Streets, New Cumberland, Pennsylvania and that all such easerrter~ta, rights and
intenssts are conveyed by the Grantor with the exception of rights and easements reserved for
Grantor, themsehres, their heirs and assigns, for current or future rya! estate interests in other
property bounded by the above streets but not conveyed on Chia deed with the above desaibed
prrrmis~. ;
THE Grantee; for and on behalf of the Grantee and the Grant+ee's hairs, personal
representatives, successors and assigns, by the acgeptanoe of this Dei~ti, covenants and agrees to
pay such charges for maintenance, repairs, replaasrnerrta and other expen~ in Connedlah With
the Common Elerrren~; and any'Lirmited Common Elemer-ts appurtenant to said Unit, as may be
assessed against him, her, them, it, ar said Unit; from time to time by the Executive Board of the
Marketplace Townes Condominium Assaaatiari in, accordance with the Uniform Condominium Act
of Pennsylvania, -and further covanartbs and agrees lh~it the Unit convsyrd by thl$ Deed shall be
subject to a lien for all amounts so asse~aecl except insofar as Sacfian 3407(c) of said Uniform
Condominium Act may relieve a sylluenit .Unit ; of lia~illty for prior unpaid assessments.
This covenant shall run with and bind the land or Unk hereby carnrey~,d and all subsequent owners
thereof.
Known and numbered as 1102 Market Street, Unit 7, New Cumberland, PA 17070
Being the same premises which Timothy Nogg, by his deed~dated January 26, 2006 and
recorded in the Cumberland County Recorder of Deeds Office at Deed Book 272, Page 5039,
granted and conveyed onto Patricia Cox.
Being Tax Parcel #:26-23-0541-323-UB-2
..
Exhibit "B"
~, ~ 0 ~ Prepared By: Members 1st FCU
5000 Louise Drive
Mechanicsburg, PA 17055
Return To: When recorded mail to:
First American Title Insurance Co.,
Lenders Advantage
1100 Superior Avenue, Suite 200
Cleveland, Ohio 44114
ATTN: NATIONAL RECORDINGS
MORTGAGE
Made 08/09/2006
RC~BER1~ P. ~iEGLER
,E~CRD~P, OF DEED
:%L'F,!RERLAND COiJ11TY-'~ ~
2006 SAP 11 ~~l 10 04
Between
PATRICIA COX
( erelna er ca ed "Mortgagor"
And
MEMBERS 1ST FEDERAL CREDIT UNION (hereinafter called "Mortgagee")
~ p(~~pp~l ~ ~
Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter
called the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of
$ 35,000.00 ,lawful money of the United States of America, and has provided therein
for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with
interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and
containing certain other terms and conditions, all of which are specifically incorporated herein by
reference;
Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the
payment of the same and interest as aforesaid, together with all other sums payable hereunder or under
the terms of the Note, does grant and convey unto Mortgagee,
All that certain property of the Mortgagor located in BOROUGH
NEW CUMBE 1 AND Cumberland County, Pennsylvania
PLEASE SEE ATTACHED EXHIBIT "A" PGnC nJ(. ~~~~- o~loa-~ ~~ ~-~[~23
which currently has the address of 1102 MARKET STREET UNIT 7
NEW CUMBERLAND Pennsylvania [Street]
17070
[CItY] [Zip Code]
us~~
Acct No _ _
_ _ _
AppID Page 1 of 4
Exhibit "C"
BK19~5PG2f9
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof.
To Have and To Hold the same unto Mortgagee, its successors and assigns, forever.
Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby
granted and conveyed shall become void.
This Mortgage is executed and delivered subject to the following covenants, conditions and
agreements:
(1) The Note secured hereby`shall evidence and this Mortgage shall cover and be security for any
future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall
be added to the principal debt.
(2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and
discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water
rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt
secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all
mechanics' liens which may be filed against said premises and which shall or might have priority in lien
or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax,
including interest and penalties thereon, if any, now or hereafter becoming payable on the Note
evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor. and Mortgagee as their respective interests may appear,
and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shat] maintain all buildings and improvements subject to this Mortgage in good and
substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
Acct No _ AppID 16521 1
Page 2 of 4
~~~965PG2198
(4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to
maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the
principal debt secured hereby, and collect the same as a part of said principal debt.
(5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the
mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this
Mortgage.
(6) In case default be made for the space of thirty (30) days in the payment of any installment of
principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the
other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional
loans or advances and al] other sums paid by Mortgagee pursuant to the terms of the Note or this
Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice
become immediately due and payable, and foreclosure proceedings may be brought forthwith on this
Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with
costs of suit and an attorney's commission for collection of five percent (5%) of the total indebtedness or--
$200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said
proceedings, waives stay of execution, the right of inquisition and extension. of time of payment, agrees
to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions
from levy and sale of any property that now is or hereafter may be exempted by law.
(7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall
terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage.
Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this
Mortgage, 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.
The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall
inure to, the respective parties hereto-and their respective heirs, executors, administrators, successors and
assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each
shall be joint and several.
Acct No
APPi~ 165211
Page 3 of 4
~u19f~5~G~~99
Witness the due execution hereof the day and year first above written.
PATRICIA COX
Commonwealth of Pennsylvania )
ss:
County of )
O this, the 9TH day of AUGUST ,2006 ,before me,
the undersigned officer, personally appeared
satisfactorily proven to
me to e t e person(s) whose name(s) is/are subscribed to the within Mortgage, and acknowledged that
he/she executed the same for the purposes therein contained.
In Witness Whereof, I hereunto set my hand and official seal.
My commission expires:
w,eiivlvt~wt:ALd~H ur Yt;iViVSYLVANI
Notanal Seal
Jody L. Travis, Notary Public
OppPrAilen Twp., Cumberland County
My Commission Expires ,kept. 29, 2008
Member. PPnnsvl~ani~ A ,r;n^iarinr~ nr tVt,terla
Members l5T Federal Credit Union, Mortgagee within named, he by 'fees t its residence
is 5000 Louise Drive, Mechanicsburg, PA 17055.
By
Acct No AppID 16521 1
Page 4 of 4
~~~ ~6~R~~'~~
EXHIBIT A
SITUATED IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA:
ALL THAT CERTAIN UNIT, BEING UNIT B-2 P,/K/A NO. 7 (THE
"UNIT"), OF MARKETPLACE TOWNES, A CONDOMINIUM, LOCATED IN NEW
CUMBERLAND BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH
UNIT IS DESIGNATED IN THE DECLARATION OF MARKETPLACE TOWNES,
A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") RECORDED IN
THE RECORDER'S OFFICE OF CUMBERLAND COUNTY AT BOOK 716 PAGE
4608 AND PLATS AND PLANS AS RECORDED IN THE RECORDER'S OFFICE
OF CUMBERLAND COUNTY IN BOOK 84, PAGE 43, ON OCTOBER 30,
2001.
TOGETHER WITH AN UNDIVIDED 5.88235 PERCENT INTEREST IN COMMON
ELEMENTS AS MORE PARTICULARLY SET FORTH IN THE AFORESAID
DECLARATION OF CONDOMINIUM AND PLATS AND PLANS, AS AMENDED
AFORESAID.
TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS
APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE
DECLARATION OF CONDOMINIUM, AS AMENDED.
THE ABOVE DESCRIBED PREMISES ARE CONVEYED UNDER AND SUBJECT
TO AN EASEMENT TO THE OWNER OF THE PROPERTY LOCATED AT 209
11TH STREET, NEW CUMBERLAND, PENNSYLVANIA, HIS HEIRS AND
ASSIGNS, FOR A 1 STORY BLOCK BUILDING WHICH ENCROACHES ON THE
EASEMENT AREA TO MAKE REPAIRS, REPLACEMENT AND MAINTENANCE
THERETO AND YARD AREA OVER THAT CERTAIN TRACT OF LAND
DESCRIBED AS EXTENDING NORTHWARDLY TO SAID ABOVE DESCRIBED
"SUTTON" TRACT" FOR A DISTANCE OF 15 FEET AND BEING 37 FEET
IN WIDTH THROUGHOUT, UNTIL THE 1 STORY BLOCK BUILDING WHICH
ENCROACHES ON SAID EASEMENT AREA IS TOTALLY DEMOLISHED BY ANY
CAUSE WHATSOEVER.
10060796
-',_, _'_j~ ~~~is to }~e recorded
. _.
._„
~~ ~ ~ ~~ ~.~~I ~ ~ ~ ~ ~i1
_. 't~~~'~;r ~' ~r~Pds
EXHIBIT A
(continued)
Permanent Parcel Number: 26230541323
PATRICIA COX, A SINGLE WOMAN
1102 MARKET STREET UNIT 7, NEW CUMBERLAND PA 17070
Loan Reference Number
First American Order No: 10060796
Identifier: FIRST AMERICAN LENDERS ADVANTAGE
~~~~~~~~~~~~~~~~~~~~~~ COX
10060796
FIRST AMERICAN LENDERS ADVANTAGE
MORTGAGE
Rev. 9/2008)
Date: September 21, 2012
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
his is an official notice that the mortgage on your home is in default. and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached images.
The name, address ~i phone number of Consumer Credit Counseling Agencies serving your
Coun are listed at the end of this Notice. If ,you have any_~uestions.,, ou may call the
Pennsylvania Housing,Finance Agency toll free at 1-800-342-2397. (Persons with im ap fired
hearing_can .call !7171780-18691.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACIbN EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACIbN OBTENGA UNA TRADUCCIbN INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Exhibit "D"
HOMEOWNER'S NAME(S): THE ESTATE OF PATRICIA COX
PROPERTY ADDRESS: 1102 MARKET STREET UNIT 7
NEW CUMBERLAND. PA 17070
LOAN ACCT. NO.: - 0003
ORIGINAL LENDER: Members I'` Federal Credit Union
CURRENT LENDER/SERVICER: Members l" Federal Credit Union
.HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGTBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
• ]F YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you
must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST bCCUR WITHIN THIRTY-THREI;,_(331 DAYS OF THE DATE OF THIS
NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT" EXPLAMS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONS IIV(ER EDIT OLINS ,T.IN A ..N I , -- If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names, addresses and telephone numbers of designated consumer credit counselin~a~encies for the county
in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face
meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTAN -- Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign.
and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA
and received within thirty (30) days of your face-to-face meeting with the counseling agency
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED' ABOVE, IN THE SECTION CALLED
"TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YGUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE
STOPPED.
Page 2 of 5
AGENCY A TION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it up to date.
NATURE OF TH . D ~AI1~ --The MORTGAGE debt held by the above lender on your property located at:
1102 MARKET STREET UNIT 7
NEW CUMBERLAND PA 17070
IS SERIOUSLY 1N DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due: $44.02 for 7/]6/12, $391.33 for 8/16/12 and $391.33 for 9/16/12.
caner charges (explain itemize):
TOTAL AMOUNT PAST DUE:
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable):
HOW TO CUR_F. TAF. nrFe><rr.T _youu may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 826.68
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (3U)
DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and
sent to:
Members 1" Federal Credit Union ATTN: Jennifer
5000 Louise Drive
Mechanicsburg, PA 17055
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.)
Page 3 of 5
jF YOU DO NOT CUuF. THF. DF.FALTL.T--If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice +~p ~Pnnar c~rends +o exercise its rigJl+s ±o accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon xour mortgaged ~ronerty.
IF THE MORTGArF IS FORF.Ci.C1SF.D UPON -- The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to.the amount you owe the lender,
which may also include other reasonable costs. If you cure the default within the THIRTY f- 013 DAY neriod. you will
not be re9 sir .d o ~y a orn .Y s fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SAi.E -- If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the r~ht to cure the default and
prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past
due Qlus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performm~ any other
requirements under. the mort~afae. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
Feui TFC'r r~ccrRi F 4HFRiFF'4 4AL.E DATE -- It is estimated that the earliest date that such a Sheriffs Sale of
the mortgaged property could be held would be approximately Three (3) months from the date of this Notice. A
notice of the actual 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 or action will
be by contacting the lender.
NAmP of i.nnrlnr• Members la` Federal ('redit Union
s~t.~rPQQ• 5000 Louise Drive
Mechaniccbure• PA 17055
Phone Number• (7171506-5429 or (8001 283-2328 Ext. 5429
Fs~.r Nnmhar• (7171795-5207
('nntnrt Pa+rann• .TQIInllf r
F.-Ms.il Ar~rlrece• Qerrvi(a~memberslst.org
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You may or XX may not (CHECK ONE) sell or transfer your home to a
buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's
fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
Page 4 of 5
YOU MAY ALSO 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.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• ~TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
tFill in a list of all C.oan~ce!i ,~~enrivc hcfvd i„ Anse»dtr ~' Fnu TuF COUNTY in which the proner~ ~c
located. acing additional,~age~„~'necessarv).
Certified Mail # 91 7199 9991 7031 1202 1238
Page 5 of 5
• 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.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• ~ TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
(Fill in a list of all Counseling Agencies listed in Anpend~Y C FOR THE COUNTY in which the pro er, i~
located. using additional paPgc.~f necessarv).
Certified Mail # 91 7199 9991 7031 1202 1245
Page 5 of 5
Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565
Relief Act and Urban Development (exp 4/30/2007)
Notice Disclosure Office of Housing
i e ag 1 Rights and Prot . tionc Jnder the RA
Servicemembers on "active duty" or "active service," or a dependent of such a
servicemember may be entitled to certain legal protections and debt relief pursuant to the
Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA).
Who Mav Be _F,ntitled to i, .gal Protections Under the ~ A~
• Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard,
and active service National Guard;
Active service members of the commissioned corps of the National Oceanic and
AtmQSpheric Administration;
• Active service members of the commissioned corps of the Public Health Service;
United States citizens serving with the armed forces of a nation with which the United
States is allied in the prosecution of a war or military action; and
Their spouses.
What i,egal Protections Are ~ervicememb rs Fntitl d To nder th SC'RA'-
The SCRA states that a debt incurred by a servicemember, or servicemember and spouse
jointly, prior to entering military service shall not bear interest at a rate above 6 percent
during the period of military service.
The SCRA states that itn a legal action to enforce a debt against real estate that is filed
during, or within 90 days after the servicemember's military service, a court may stop the
proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or
seizure of real estate shall not be valid if it occurs during, or within 90 days after the
servicemember's military service unless the creditor has obtained a court order approving the
sale, foreclosure, or seizure of the real estate.
The SCRA contains many other protections besides those applicable to home loans.
How Doe A ~ rvi m mber or D tzendent Rearrest Relief Jnder th 4C'RA~
• In order to request relief under the SCRA, a servicemember or spouse, or both, must
provide a written request to the lender, together with a copy of servicemember's military
orders. The Lender providing this Notice is Members 1 s` Federal Credit Union, ATTN:
Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The
phone number is toll free (800) 283-2328.
IiQw Does a Servi m mber or Denendent Obtain Information Ahnut the C~"R s `-
The U. S. Department of Defense's information resource is "Military OneSource".
Website: httD://www.militaryonesource com
The toll free telephone number for Military OneSource are:
o From the United States: ] -800-342-9647
o From outside the United States (with applicable access code): 800-3429-6477
o International Collect (through long distance operator): 1-484-530-5908
Servicemembers and dependents with questions about the SCRA should contact their
unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal
assistance office locator for all branches of the Armed Forces is available at
htto://leealassistance law of mil/content/locator nhp
form HUD-92070
(2/2007)
Comprehensive Housing
~ r
Y~~~u:.- t~~~~tN~ F1WxP1zrE ~~~~~~ Counseling Agencies
Agencias de Consejo al Clients para Vivienda
Cumberland County
'CCCS of Western PA -York
55 Clover Hill Road
Dallastown PA 17313
888.511.2227 ! 888.511.2227
www.cccspa.ora
Community Action Commission -Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
vaww. cactri county. ora
Harrisburg Fair Housing Council
2100 N 6th St
Harrisburg PA 17110
717.238.9540
Housing & Redevelopment Authority -Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907 / 717.249.0789
www.cchra.com ~
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
www.ruralisc.org/pathstone~a. htm
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
www.adamscha.ora
~ NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you.
Report last updated: 4/30/2012 9:03:04 AM Page 1 of 1
Form 3877 Page:1
W 'way.
._._.._.., ..,....,, .,,,,, ,,,,,,,,~~,,. r•erm~t rvurnoer. MAC Geri. Ver, Num. -
Members 1st Federal Credit Union 9223844001 SendSuite -MAC v6.25.6.25.L
5000 Louise Dr equence Number:
MECHANICSBURG, PA 17055 0001124
Pc ID #/ Addressee Name Pasta~e F=S ES Insured Due Total
Article # Delivery Address Ty,~te Fee Value Sender Charge
,ti
2900000082609 PSECU
9171999991703178342704 P.O,Box67013
Harrisburg, PA 17106
74MMnnstoa,~_- _ _--
0.650 C 2.950 0.00 4.750
ERR 1.150
0.450 C 2.950 0.00 4.550
ERR 1.150
0.650 C 2.950 0.00 4.750
ERR 1.150
Page Totals: 15
Cum Totals: 8.150 61.500
18 9.500 69.650
73 800 83.300
Form 3877 (Facsimile) SendSuite -MAC v6.25.6.25.L
.Exhibit "E"
Form 3877
. <,,~ ` Page: 2
~temt~ers 1st Federal Credit Union
1000 Louise Dr '
v1ECHANICSBURG, PA 17055
9223844001
0001124
SendSuite -MAC vti.25.6.25.L
'c ID #/ Addressee Name Postage ES ES
lrticle # Delivery Address Insured Due Total
Type Fee Value Sender Charge
~.~
.~C~~N~ OS6U'~Go
CC'
SAP 2 ~ 201' '' ~~':.
...~
,.
ge Totals: 3
1.350 - 12.300
m Totals: 18 13.650
9'~0 73.800
83.300
~tal Number of Pieces Received;
gnature eceiving mployee
<<
USPS CERTIFICATION
~A~ ~!~
T Q o ~ ~ fril~~
~U ®~~ wr~ravapv~s
~-' 0 2 1M ~ ~
q~u U00425t'g58 ~ cp ~,`
MAILED FROM ZIP CODE 1 ?055
arm 3877 (Facsimile) SendSuite -MAC v6.25.6.25.L
11/16/2012 10:03 7179320317 KARLLEDEBOHM PAGE 08/19
MEMBERS I s~~~ I~'EDERAL
CREDIT UNION
: IN TFIE COURT QF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTII'F
v~.
PATRICIA C03C aJk/a FATRICIA A.
COX, DECEASF'D and
AMY L. FET.,TON, ADMINTSTR.ATRIX
FOR TIDE ESTATE OF I'ATRICIA A.
COX, DECEASED
DEFENDANT(S)
. NO..
CIVIL ACTION-LAW-MORTGAGE
:FORECLOSURE
VERI.i+'~CATION
I, Arlanda Dintarz~.an, Collateral Liquidat9on Specialist for Members Ist Federal
Credit Union, being authoriTed to do so on behalf of Members 1 ~ Federal Credit Union,
hereby verify that the statem~ts made in the foregoing p.ter~ding are true attd correct to
the best of my i.z~formation .k~-~owledge and belief I understand that false staterrxents are
made subject to the penalties of I8 Pa. C.S.A. Section 4904, y~elating to unsworn
faisiixcasion to authorities.
Members 1. Ae Federal Credit Union
~ ~ ~~~~~
Arlanda Di».taman., Collateral
.Liquidatio». Specialist
7
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(71738-6929
MEMBERS 1" FEDERAL
CREDIT UNION
~~';";^
:< < < ~; ~
-,
_ ,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs.
PATRICIA COX a/k/a PATRICIA A.
COX, DECEASED and
AMY L. FELTON, ADMINISTRATRIX
FOR THE ESTATE OF PATRICIA A.
COX, DECEASED
DEFENDANTS
. NO..
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
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 acourt-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 appointment of a legal representative at no chazge
to you. Once you have been appointed a legal representative, you must promptly meet
with that legal representative within twenty (20) days of the appointment date. During
that meeting, you must provide the legal representative with all requested financial
information so that a loan resolution proposal can be prepazed on your behalf. If you and
your legal representative complete a financial worksheet in the format attached hereto,
the legal representative will prepaze 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 azrangements with your lender before the mortgage
foreclosure suit proceeds forwazd.
If you are represented by a lawyer, you and your lawyer must take the
following steps to be eligible for a conciliation conference. It is not necessary for you
to contact MidPenn Legal Service for the appointment of a 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 a 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 (b0} 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 forwazd.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND
TAKE THE STEPS REQUIRED BY THIS NOTICE.
THIS PROGRAM IS FREE.
f'7 ,,' ~:
~~ 1~ ~~
Date: November 16, 2012 ~ '~ ~' ~! .~ ~?~
M. Lade hm, Esq.
Supreme Court ID #59012
PO. Box 173
dew Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
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: State: Zip:
Phone Numbers: Home:
Cell:
Email:
# of people in household: How long?
First Mortgage Lender: _
Type of Loan:
Loan Number:
Second Mortgage Lender:
Type of Loan:
Loan Number:
State: Zip:
Yes ^ No ^ Listing date: Price: $_
Realtor Phone:_
Yes ^ No ^
State: Zip:
Home:
Cell:
Office:
Other:
How long?
Date You Closed Your Loan:
Office:
Other:
Total Mortgage Payments Amount: $
Date of Last Payment:
Primary Reason for Default:
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: yew;
Amount owed: ~ Value:
Automobile #2: Model: yew;
Amount owed: Value:
Other transportation (automobiles boats motorcyclesZ Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description knot 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
Mort a e Food
2" Mort a Utilities
Car Pa ens Condo/Nei .Fees
Auto Insurance Med. not covered
Auto fuel/re airs Other ro . a ment
Install. Loan Pa ment Cable TV
"Child Su ort/Alim. S endin Mone
Day/Child Care/Tuit. Other fix enses-
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:
2
Emai 1:
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, regazding your lender or lender's loan
servicing company:
Lender's Contact (Name);
Servicing Company (Name):
Contact: Phone:
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. UWe
understand that Uwe amaze 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:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the market)
F
n ~ ~ F.,. - ee1 y~ k`k ,
] ~,J IJ L{ 1 1 '
t `- !' 1
Karl M. Ledebohm, Esquire ~ u
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
V s.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 2012-07016
PATRICIA COX a/k/a PATRICIA A.
COX, DECEASED and
AMY L. FELTON, ADMINISTRATRD~
FOR THE ESTATE OF PATRICIA A.
COX, DECEASED
DEFENDANTS
CNIL ACTION -~ LAW
MORTGAGE FORECLOSURE
PRAECIPE TO SETTLE. DISCONTINiTE AND END
To the Prothonotary:
Please mark the docket in the above captioned case settled, discontinued
and ended without preiudice.
Date: November 26, 2012
Karl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
PATRICIA COX a/k/a PATRICIA A.
COX, DECEASED and
AMY L. FELTON, ADMINISTRATRIX
FOR THE ESTATE OF PATRICIA A.
COX, DECEASED
DEFENDANTS
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 2012-07016
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 27~' day of November,
2012, I served a true and correct copy of the Praecipe to Settle, Discontinue and End in
the above captioned matter upon the following by first class mail, postage prepaid,
addressed as follows:
Amy L. Felton, Administratrix
For the Estate of Patricia A. Cox, deceased
1102 Market Street, Unit 7
New Cumberland, PA 17070
itt~~~l V ;
Date: November 27, 2012
'~ Attorney for Plaintiff
t Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
SHERIFF'S OFFICE OF CUMBERLAND COUNTY =~ r._~ `~=
Ronny R Anderson rn ~~-% -.~- ~~,
-?
Sheriff ~ ` ~ `~ ,
Jody S Smith ~~t ti,~ u~ r~
~' ° -~.:, ~ ~
~a ,
Chief Deputy ` ~- ~ `=-?
~
Richard W Stewart ~ ~~ ~~~ ~
.x- c '" ~
~ ~~~
°-
.. - .. ~.
., (`J
Members 1st Federal Credit Union
Case Number
vs.
Patricia Cox (et al.)
2012-7016
SHERIFF'S RETURN OF SERVICE
11/26/2012 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this Complaint in Mortgage
Foreclooure upon defendant Occupant is returned not served per request from attorney Karl M.
Ledebohm.
11/26/2012 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this Complaint in Mortgage
Foreclosure upon defendant Amy L Felton Administratrix for the Estate of Patricia A. Cox, Deceased is
returned not served per request from attorney Karl M. Ledebohm.
SHERIFF COST: $44.00
November 26, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
~. ~. / ~. ^/ 2?=. ~ 23 ~ . 5 7179320317 KARLLEDEBOHM PAGE 02/ 02
KARL M. LEDESOHM
ATTORNEY-AT LAW
P.O. BOX 173
New Cumberland, PA 17070-0173
Phone: 717-938-G929
Fax: 71.7-932-0317
"Of Counsel; Richard P. Mislitsky, Esq.
NovembEr 24, 2012
(via Fax only: 240-6397)
Chief Deputy Jady Smith
Office of the Sheriff.
Cumberland County Courthouse
One Courthouse Square
Cazlisle, PA 17013
RE: 1V1(embers 1'~ Fedee-al Credit Union vs. Patricia A. Cox, deceased and
A.my L. Felton, Administratxix for the Estate of Patricia A. Cox, deceased
Docket No.:
Dear Deputy Smith.:
P1easE stop any service efforts with regards to the complaint filed in the above
captioned matter.
Please provide an appropriate return to my office along with any refund of the
Service Advance.
Please contact me with any questions.
V
Karl M` Lcdebohm,
CC: Arianda Dintaman, Collateral Liquidation Specialist
KML:11
'Also practices independently as Richard P. Mislitsky, Esq.