HomeMy WebLinkAbout13-0249KEEPER WOOD ALLEN & RAHAL, LLP
210 WALNUT STREET
PO BOX 11963
HARRISBURG, PA 17108-1963
FULTON BANK, N.A.
Plaintiff
v.
STACY BUXTON AND ERIC BUXTON
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
No. ~ 3- a~ ~ ~~i~~l
MORTGAGE FORECLOSURE
NOTICE
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 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 INFORMATION ABOUTAGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NOT FEE.
PENNSYLVANIA LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
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KEEPER WOOD ALLEN He RAHAL, LLP
210 WALNUT STREET
PO BOX 11963
HARRISBURG, PA 17108-1963
FULTON BANK, N.A.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
STACY BUXTON AND ERIC BUXTON
Defendants
CIVIL ACTION -LAW
NO.
MORTGAGE FORECLOSURE
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mss adelante en las siguientes paginas, debe tomar accion
dentro de los proximos veinte (20) dias despues de la notification de esta Demands y Aviso
radicando personalmente o por medio de un abogado una comparecencia escrita y
radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falls de tomar accion Como
se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier sums
de diners reclamada en la demands o cualquier otra reclamation o remedio solicitado pro el
demandante puede ser dictado en contra suya por la Corte sin mss aviso adicional. Usted
puede perder dinero o propiedad u otros derechos importantes pars usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS
QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS
QUE CUALIFICAN.
PENNSYLVANIA LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 s. Bedford Street
Carlisle, PA 17013
(717) 249-3166
Attorney fo la ntiff s)
KEEPER WOOD ALLEN & RAHAL, LLP
210 WALNUT STREET
PO BOX 11963
HARRISBURG, PA 17108-1963
FULTON BANK, N.A.
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
STACY BUXTON AND ERIC BUXTON
Defendants
COMPLAINT
CIVIL ACTION -LAW
NO.
MORTGAGE FORECLOSURE
1. Plaintiff Fulton Bank, N.A. is a national banking association, with an office at 200 N.
Third Street, Harrisburg, Pennsylvania 17101.
2. Defendants are Stacy Buxton and Eric Buxton, adult individuals, whose last known
address is 2506 Mallard Way, Mechanicsburg, Pennsylvania 17055.
3. Defendants are the owners of a tract(s) or parcel(s) of land with buildings and other
improvements thereon located at 1 Commercial Drive, LowerAllen Township, Cumberland County,
Pennsylvania (the "Premises"). The Premises are more fully described hereinafter.
4. On or about March 10, 2010, Defendants, for good and valuable consideration,
executed and delivered a Note (the "Note") to Plaintiff. A true and correct copy of the Note is
attached hereto, made a part hereof and marked Exhibit A.
5. On or about March 10, 2010, Defendants executed an Open End Mortgage in favor
of Plaintiff (the "Mortgage"), which Mortgage was duly recorded in the Office of the Recorder of
Deeds, in and for Cumberland County, Pennsylvania, at Instrument Number 201006124. A true and
correct copy of the Mortgage is attached hereto, made a part hereof and marked Exhibit B.
6. The failure of the Defendants, among other things, to pay when due and payable the
payments under the Note constitutes a "default" as defined under the terms of the Mortgage.
7. The Defendants have failed and refused, among other things, to make payments due
and payable under the Note.
KEEPER WOOD ALLEN 8c RAHAL, LLP
210 WALNUT STREET
PO BOX 11963
HARRISBURG, PA 17108-1963
8. The terms of the Mortgage provide that upon the occurrence of a default by the
Defendants, the Plaintiff may accelerate and demand immediate payment of all sums due under the
Mortgage.
9. The sum presently due and payable to Plaintiff by Defendants which is secured by
the Mortgage is computed as follows:
a. Unpaid Principal
b. Accrued Interest through
01/14/13
c. Late Charges through
01/14/13
d. Attorney's Fees
TOTAL
$ 298,620.47
$ 9,054.46
$ 744.36
$ 29,862.00
$ 338,281.29
10. Notice of the availability of mortgage assistance under the Homeowners Emergency
Mortgage Disclosure Act of 1993 ("Act 91 ") was not required.
11. Notice of Intention to Foreclose pursuant to Section 403 of Act 6 was not required.
WHEREFORE, Plaintiff demands judgment in the sum of $338,281.29 togetherwith interest
as may accrue from and after January 14, 2013, and costs of suit, and for foreclosure of the
Mortgage and judicial sale of the Premises.
Date: January 14, 2013
KEEPER, WOOD, ALLEN &RAHAL, LLP
By:
Eugene E. Pepins y, Jr.
Attorney I.D. #23702
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8051
Attorneys for Plaintiff
KEEPER WOOD ALLEN 8c RAHAL, LLP
210 WALNUT STREET
PO BOX 11963
HARRISBURG, PA 17108-1963
VERIFICATION
The undersigned, James W. Pesavento, hereby verifies and states that:
He is Vice President of Fulton Bank, N.A., Plaintiff herein;
2. He is authorized to make this Verification on its behalf;
The facts set forth in the foregoing Complaint are true and correct to the best of his
knowledge, information and belief; and
4. He is aware that false statements herein are made subject to the penalties of 18
Pa. C.S. ~ 4904, relating to unsworn falsification to authorities.
~-2._-
W. Pesavento
Dated: January/~, 2013
NtlIAIYGIIiIIlIIIII~pIWII ~~~ ,~ (~
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Borrower: Stagy Buzcon Lender: Fulton Bank, N.A.
Eric Buxton Dowmown Harrisburg Office
2608 Mallard Way One Penn Square
Mechanicsburg, PA 17055 Corporate Address
Lancaster, PA 17802
Prinoipal Amount: 5316,000.00 Date of Note: March 10, 2010
PROMISE TO PAY. Staoy Buxton and Eric Buxton ("Borrower") jointly end severally promise to pay to Fulton Benk, N.A. 1"Lender"), or order, in
lawful money of the United States of America, the principal amount of Three Hundred Flfteen Thousand & 001100 DoUsrs I531S,000.OOy,
together with interest on the unpaid principal balance from March 10, 2010, undl paid in full.
PAYMENT. Subject to any payment changes resuhing from ohangee In the Index. Borrower will pay this ben In acoordence with the following
payment schedule:
8 consecutive momYtly payments ai Interest, beginning on April 10, 2010 end continuing on the 10th day of each month thereafter,
folowed by 233 consecutive montl[ly installments on account of principal and interest in the amount of $2,481.21 each, baglnning on
October 10, 2010 end cominuing on the 10th day o1 each month thereafter. One Bnel payment of ell unpaid principal and all unpaid
accrued interest shall be due and payable on March 10, 2030; provided, however, Lender shell have the aptlon et aech five {5) year
anniversary from the date hereof, to declare the emirs then outstanding principal balance and all accrued unpaid interest to be due end
payable thirty (30) days following written notice to the Borrower that Lender Is oxercleing such option.
INTEREST RATE. The interest rate applicable hereunder Is the annual fixed rate of 6.9B% for a period of 80 months from the date hereof,
followed by rite annual variable rate of 1.00°h above the Index, as hereinafter deflnad.
Unless otherwise agraetl or required by applicable law, payments w(II he applied first to any accrued unpaid Interest; then to principal; then to
any late charges; end then to any unpaid coileetion costs. Borrower will pay Lender at Lender's address shown above or at such other place es
Lender may designate in writing.
VARIABLE INTEREST RATE. The interest rate on this Note Is subject to change from time to time based on changes In an Index which ie the
Fulton Bank, N.A. Prime Reta Ithe "Index"I. The index Is not necessarily the lowest rate charged by Lander on its loans and Is sat by Lender in
its sole discretion. If the Index becomes unavellable during the term of this loan, Lender may designate a substltuta index after notifying
Borrower. Lender will tell Borrower the current Index rate upon Borrower's request. The Interest rate change will not occur more often then
aech day. Borrower understands that Lander may make loans based on other rates as well. Interest on the unpaid principal balance of this Note
will be calculated as described in the "INTEREST CALCULATION METHOD' paragraph using a rate of 1.000 percentage point over the Index.
NOTICE: Under no circumstances will the interest rate on this Note be lase than 5.000% par annum or more than the maximum rate allowed by
applicable law. Whenever increases occur in the interest rate, Lender, at Its option, may do one or more of the following: IAI Increase
Borrower's payments to ensure Borrower's loan will pay off by Ire origlnel final maturity date, 181 increase Borrower's payments to cover
accruing Interest, ICI increase tfie number of Borrower's payments, and fD1 continue Borrower's payments et the same amount and increase
Borrower's final. payment.
INTEREST CALCULATION METHOD. Interest on this Note to computed on a 365/380 basis; that is, by applying the ratio o} the Interest rate
over a year of 360 days, multlpllsd by the outstanding principal balance, multiplied by the actual number of days the principal balance ie
outstanding. All interest payable under this Note is computed using this method.
PREPAYMENT PENALTY. Upon prepayment of this Note, Lender Is entitled to the folowing prepayment penahy: Tha Borcower shell have the
right to prepay the whole or any pert of the principal and Interest Mraundar provided that: let st the time of prepayment no ovem of default
hereunder shall have occurred; Ibl any prepayment during any fixed rate perbd shall be accompankd by a prepayment penalty equal to two
(2%) percent of the amount; icl any partial prepayment shell be applied to the unpaid prinoipai balsnoe, and no prepayment shell reduce the
amount of the scheduled Instsllmenta nor relieve the Borrower from paying the scheduled installments on aech due data, until the entire
indebtedness is paid. Notwithstanding anything to the contrary set forth above. the prepayment penahy will Trot be charged if up to twenty
120%1 percent of the original principal amount is prepaid from internally generated funds whhin any ban year. The term "loan year"mused
herein is defined es any period of one year commencing on the date hereof or on any snniversery of such data. Except for the foragoing,
Borrower may pay ell or a portlon of the amoum owed eerUer than it is due. Early payments will not, unless agreed tc by Lender In writing,
relieve Borrower of Borrower's obligation to continue to make payments under [he payment schedule. Rather, early payments will reduce the
principal balance due and may result in Borrower's making fewer payments. Borrower agrees not to Bend Lander payments marked "paid in
Lull", "without recourse", or slmflar language. If Borrower sends such a payment, Lander may accept it without losing any of Lender's rights
under this Nota, and Borrower will remain obligated to pay any further amount owed to Lander, All written communications concerning disputed
amounts, including any check or other payment instrument that indicates that the payment constitutes "payment in full' of the amount owed or
that is tendered with other conditions or limitations or es full satisfaction of a disputed amount must be melted or delivered [o: Fulton Bank,
N.A.; Downtown Harrisburg Office; One Penn Square; Corporate Address; Lancaster, PA 17602.
LATE CHARGE. It a payment is 15 days or more late, Borrower will be charged 5.000% of the unpaid portion of the regularly scheduled
payment.
INTEREST AFTER DEFAULT. Upon default, including failure to pay upon final maturity, the Interest rate on this Note shall be increased by
adding a 5.000 percentage point margin ('Default Rate Margin"1. The Default Rate Margin shall also apply to each succeeding interest rate
change that would have applied had there been no default. If judgment Is entered In connection with this Nota, interest will continue to accrue
after the date of judgment et the rate In effect et the time judgment is entered. However, in no event will the interest rate exceed the maximum
Interest rate limitations under eppllcable law.
DEFAULT. Each at the following shall constitute an event of default ('Event of Default"1 under this Note:
Payment Defauh. Borrower fails to make any payment when tlue under this Nota.
Other Defauhs. Borrower fails [o comply with or to perform any other term, obligation, covenant or condition contained in this Note or {n
any of the related documents or to comply with or io pariorm any term, obligation, covenant or condition contained in any other agreement
between Lender end Borrower.
Dofauh In Favor of Third Partiec. Borrower or any Grantor defaults under any loan, extension of credit, security agreement, purchase or
salsa agreement, or any other agreement, in favor of any other creditor or person that may materlelly affect any of Borrower's property or
Borrower's ability to repay this Note or perform Borrower's obligations under this Note or any of the related documents. i
False Statements. Any warranty, representation or statement made or furnished to Lender by Borrower or on Borrower's behalf under this
Note or the related documents is false or misleading in any material respect, either now or at the time made or furnished or becomes false
or misleading et any time thereafter.
Death a insolvency. The death of Borrower or the dissolution or termination of Borrower's existence as a going business, the insolvency
of Borrower, the appointment of a receiver for any pert of Borrower's property, any assignment for the benefit of creditors, any type of
creditor workout, ar the commencement of any proceeding under any bankruptcy or insolvency laws by or against Borrower.
Creditor or Forfeiture Proceedings. Commencement of foreclosure or forfeiture proceedings, whether LiY judicial proceeding, self-help,
repossession or any other method, by any creditor of Borrower or by any governmental agency~agalnst arty collateral securing the loan.
This includes a garnishment of any of Borrower's accounts, including deposit accounts, with Lender. However, this Event of Default shall
not apply if there is a good faith dispute by Borrower as to the validity or reasonableness of the claim which is the basis of the creditor or
forfeiture proceeding and if Borrower gives Lender written notice of the creditor or forfeiture proceeding and deposits with Lender monies or
a surety bond for the creditor or forfeiture proceeding, in an amount determined by Lender, in its sole discretion, as being an adequate
reserve or bond for [he dispute.
Events Affecting Guarantor. Any of the preceding events occurs with respect to any Guarantor of any of rho indebtedness or any
Guarantor dies or becomes incompetent, or revokes or disputes the validity oi, or liability under, any guaranty of the indebtedness
evidenced by [his Note.
Adverse Change. A materiel adverse change occurs in Borrower's financial condition, or Lender believes the prospect of payment or
performance of this Note Is Impaired.
-- _ __ -_ - 2 __ _ - _ _ -- - -
PROMISSORY NOTE
Loan No: 0001-9712337-9001 (Continued) Page 2
,._
Insecurity. Lender in good faith believes Itself Insecure. '
Cure Provisions. If any default, other then a-default in payment is curable and if Borrower has net been given a notice of a breach of the
same provision of this Note within the preceding twelve 112) months, It may be cured II Borrower, attar Lender sends written notice to
Borrower demanding cure of such default: 11) cures the default within fifteen 1151 days; or 12) if the cure requires more thsn•fifteen 1151
days, immediately initiates steps which Lender deems in Lender's sole discretion to be sufficient [o curd the default and thereafter
continues and completes elf reasonable and necessary steps sufficient to produce compliance as soon as reasonably practical.
LENDER'S RIGHTS. Upon default, Lender may, after giving such notices ae required 6y eppllceble law, declare the entire unpaid principal
balance under this Noto and all accrued unpaid interest immediately due, and then Borrower will pay that amount.
ATTORNEYS' FEES; EXPENSES. lender may hire or pay someone else to help collect this Note if Borrower does not pay. Borrower will pay
Lender that amount. This includes, subject to any limits under eppllceble law, Lender's reasonable attorneys' tees end Lender's legal expenses,
whether or not there ie a lawsuit, including reasonable attorneys' fees, expanses for bankruptcy proceedings (including efforts to modify or
vecato any automatic stay or injunction}, end appeals. If not prohibited by applicable law, Borrower also will pay any court costs, ih addition to
all other euma provided by law.
JURY WAIVER. Lender and Bonower hereby waive the dght to any Jury trial In any action, proceeding, or oounterclalm brought by either Lender
m Bonower agelrot the other. '
GOVERNING LAW. Thla Note will be governed by }sderal law applicable to Lander and, to the extent not preempted by federal law.~the laws of
the Commonweahh of Panneylvenla wthout regard to Its conflicts of law provisions. This Note has been accepted by Lender In the
Commonwealth of Pennsylvania.
R1GH7 OF SETOFF. To the extent permitted by applicable law, Lender reserves a right of setoff in all Borrower's accounts with Lender (whether
checking, savings, or some other eccountl. This includes all accounts Borrower holds jointly with someone else and ell accounts Borrower may
open In the future. However, this does not include any IAA or Keogh accounts, or any trust acdounts for which setoff would be prohibited by
law. Borrower authorizes Lender, to the extent permitted by applicable law, to charge or setoff all sums owing on the indebtedness against any
end all such accounts, end, at Lender's option, to adminiatratively freeze all such eccounte to allow Lander to protect Lender's charge and eetoff
rights provided in this paragraph.
COLLATERAL. Borrower acknowledges this Note is secured by Mortgage on 1 Commercial Drive, Township of Lower Allen, Cumberland
County, PA;
Assignment of Leeaes and Rents;
Guaranty of Prevail Salon, L.L.C.
CROSS DEFAULT. Any event of default under any loan due and owing to Lender by Borrower, at any time, shaft constitute an avant of default
under all (cans due and owing to Lender by Borrower.
SUCCESSOR INTERESTS. The terms of this Note shall be binding upon Borrower, end upon Borrower's heirs, personal representatives,
successors and assigns, and shall inure to the benefit of Lender end Its successors and assigns.
GENERAL PROVISIONS. It any pert of this Note cannot 6e enforced, this fact will not affect the rest of the Nota. Lender may delay or forgo
enforcing any of Its rights or remedies under this Note without losing them. Each Borrower understands end agrees that, with or without notice
to Borrower, Lender may with respect to any other Borrower la) make one or more additional secured or unsecured loans or otherwise extend
additional credit; Ib) alter, compromise, renew, extend, accelerate, or otherwise change one or more times the time for payment or other terms
of any indebtedness, including Increases and decreases of the rate of Interest on the indebtedness; Icl exchange, enforce, waive, subordinate,
fell or decide not to perfect, and releass any security, with or without the substitution of new collateral; Idl apply such security and direct the
order or manner of sale thereof, including without limitation, any non-Judicial sale permitted by the terms of the controlling security egreetnenta,
es Lender in its discretion may determine; let release, substitute, agree not to sus, or deal with any one or more of Borrowers sureties,
endorsers, or other guarantors on any terms or in any manner Lender may choose; and It) determine how, when end what application of
payments and credits shall be made on any other indebtedness owing by such other Borrower. Borrower and any other person who signs,
guarantees or endorses this Nota, to the extent allowed by law, waive presentment, demand for payment, and notice of dishonor! Upon any
change to the terms of this Note, end unless otherwise expressly stated in writing, no party who signs this Note, whether as maker, guarantor,
accommodation maker or endorser, shall be released from liability. All such parties agree that Lender may renew or extend (repeatedly end for
any length of time) this loan or release any party or guarantor or collateral; or Impair, fell to realize upon or perfect Lender's security interest in
the collateral; and take any other action deemed necessary by Lender without the consent of or notice to anyone. All such parties also agree
that Lender may modify this loan without the consent of or notice to anyone other then the party with whom the modification ie made. The
obl(gatlona under this Note are joint end aeverai. It any portion of this Nota is for any reason determined to be unenforceable, it will not affect
[he enforceability of any other provislone of this Nota.
CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE
PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT. ANY TIME
FOR BORROWER AFTER A DEFAULT UNDER THIS NOTE AND WITH OR WITHOUT COMPLAINT FILED, CONFESS OR ENTER JUDGMENT
AGAINST BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE AND ALL ACCRUED INTEREST, LATE CHARGES AND ANY AND
ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THIS NOTE, TOGETHER WITH COSTS
OF SUIT, ANO AN ATTORNEY'S COMMISSION OF TEN PERCENT 110%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR
COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS (95001 ON WHICH JUDGMENT OR JUDGMENTS ONE OR
MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS NOTE OR A COPY OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL
BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS NOTE 70 CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE
EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN
FULL OF ALL AMOUNTS DUE UNDER THIS NOTE. BORROWER HEREBY WAIVES ANY RIGHT BORROWER MAY HAVE TO NOTICE OR TO A
HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT AND STATES THAT EITHER A REPRESENTATIVE OF LENDER
SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S ATTENTION OR BORROWER HAS BEEN
REPRESENTED BY INDEPENDENT LEGAL COUNSEL.
PRIOR TO SIGNING THIS NOTE, EAOH BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE
VARIABLE INTEREST RATE PROVISIONS. EACH aORROWER AGREE6 TO THE TERMS OF THE NOTE.
BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF THIS PROMISSORY NOTE.
THIS NOTE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS NOTE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A
SEALED INSTRUMENT ACCORDING TO LAW.
BORR WER:
X ISeal> X (Seel)
Stacy Buxton Erl xton
Signed, acknowledged and delivered in the presence of:
x ~. _~ s~_
~la~{
~~~~ ~~
Parcel Identification
Number:
13-23-0547-300
RECORDATION
REQUESTED BY:
Fulton Bank, N.A.
Downtown Harrisburg
Office
One Penn Square
Corporate Address
Lancaster, PA 17602
WHEN RECORDED MAIL
TO:
Fulton Bank, N.A.
Collateral
1695 State Street
East Petersburg, PA
17520
~ro~
FOR RECORDER'S USE ONLY
*00001-9712337-900100040031057*
OPEN -END MORTGAGE AND SECURITY AGREEMENT
(This instrument is an open-end mortgage and secures future advances pursuant to 42 Pa. C. S.
§ § 8143 and 8144, Act No, 126 of 19901
MAXIMUM LIEN. The unpaid principal balance of advances exclusive of interest and unpaid
balances of advances and other extensions of credit, secured by the Mortgage made for the
payment of taxes, assessments, maintenance charges, insurance premiums and costs incurred
for the protection of the mortgaged premises shall not exceed at any one time 5315,000.00.
Amount Secured Hereby: 5315,000.00
THIS MORTGAGE dated March 10, 2010, is made and executed between Stacy Buxton and
Eric Buxton, whose address is 2506 Mallard Way, Mechanicsburg, PA 17055 {referred to
below as "Grantor"~ and Fulton Bank, N.A., whose address is One Penn Square, Corporate
Address, Lancaster, PA 17602 (referred to below as "Lender").
--1
~~ ,
GRANT OF MORTGAGE. For valuable consideration, Grantor grants, bargains, sells, conveys,
assigns, transfers, releases, confirms and mortgages to Lender ail of Grantor's right, title, and
interest in and to the following described real property, together with all existing or
-- __ __
- _-2
MORTGAGE
Loan No: 0001-9712337-9001 (Continued) Page 2 ',
i
subsequently erected or affixed buildings, improvements and fixtures; all streets, lanes, alleys,
passages, and ways; all easements, rights of way, all liberties, privileges, tenements,
hereditaments, and appurtenances thereunto belonging or anywise made appurtenant hereafter,
and the reversions and remainders with respect thereto; all water, water rights, watercourses
and ditch rights (including stock in utilities with ditch or irrigation rights); and all other rights,
royalties, and profits relating to the real property, including without limitation all minerals, oil,
gas, geothermal and similar matters, lthe "Real Property"} located in Cumberland County,
Commonwealth of Pennsylvania:
See the exhibit or other description document which is attached to this Mortgage and made
a part of this Mortgage as if fully set forth herein.
The Real Property or its address is commonly known as 1 Commercial Drive, Township of
Lower Allen, Cumberland County, PA. The Reaf Property parcel identification number is
13-23-0547-300.
Grantor presently assigns to Lender all of Grantor's right, title, and interest in and to all present
and future leases of the Property and all Rents from the Property. In addition, Grantor grants to
Lender a Uniform Commercia! Code security interest in the Personal Property and Rents.
THIS MORTGAGE, INCLUDING THE ASSIGNMENT OF RENTS AND THE SECURITY INTEREST
fN THE RENTS AND PERSONAL PROPERTY, IS GIVEN TO SfGURE !A) PAYMENT OF THE
INDEBTEDNESS AND {g) PERFORMANCE OF ANY AND ALL OBLIGATIONS UNDER THE NOTE
!N THE ORIGINAL PRINCIPAL AMOUNT OF $315,000.00, THE RELATED DOCUMENTS, AND
THIS MORTGAGE. THIS MORTGAGE IS GIVEN AND ACCEPTED ON THE FOLLOWING TERMS:
PAYMENT AND PERFORMANCE. Except as otherwise provided in this Mortgage, Grantor shat{
pay to Lender all amounts secured by this Mortgage as they become due and shall strictly
perform all of Grantor's obligations under this Mortgage.
POSSESSION AND MAINTENANCE OF THE PROPERTY. Grantor agrees that Grantor's
possession and use of the Property shall be governed by the following provisions:
Possession and Use. Until the occurrence of an Event of Default, Grantor may (1) remain
in possession and control of the Property; (2) use, operate or manage the Property; and
(3) collect the Rents from the Property.
Duty to Maintain. Grantor shall maintain the Property in tenantable condition and promptly
perform all repairs, replacements, and maintenance necessary to preserve its value.
Compliance With Environmental Laws. Grantor represents and warrants to Lender that: (1)
During the period of Grantor's ownership of the Property, there has been no use,
generation, manufacture, storage, treatment, disposal, release or threatened release of any
Hazardous Substance by any person on, under, about or from the Property; (2) Grantor
has no knowledge of, or reason to believe that there has been, except as previously
disclosed to and acknowledged by Lender in writing, (a) any breach or violation of any
Environmental Laws, (b) any use, generation, manufacture, storage, treatment, disposal,
release or threatened release of any Hazardous Substance on, under, about or from the
Property by any prior owners or occupants of the Property, or (c) any actual or threatened
litigation or claims of any kind by any person relating to such matters; and (3) Except as
__ __ __
__- -- - - 3
MORTGAGE
Loan No: 0001-97 1 2337-9001 (Continued) Page 3
previously disclosed to and acknowledged by Lender in writing, (a) neither Grantor nor any
tenant, contractor, agent or other authorized user of the Property shall use, generate,
manufacture, store, treat, dispose of or release any Hazardous Substance on, under, about
or from the Property; and fb) any such activity shall be conducted in compliance with all
applicable federal, state, and local laws, regulations and ordinances, including without
limitation alt Environmental Laws. Grantor authorizes Lender and its agents to enter upon
the Property to make such inspections and tests, at Grantor's expense, as Lender may deem
appropriate to determine compliance of the Property with this section of the Mortgage. Any
inspections or tests made by Lender shall be for Lender's purposes only and shall not be
construed to create any responsibility or liability on the part of Lender to Grantor or to any
other person. The representations and warranties contained herein are based on Grantor's
due diligence in investigating the Property for Hazardous Substances. Grantor hereby (1)
releases and waives any future claims against Lender for indemnity or contribution in the
event Grantor becomes liable for cleanup or other costs under any such laws; and (2}
agrees to indemnify, defend, and hold harmless Lender against any and all .claims, losses,
liabilities, damages, penalties, and expenses which Lender may directly or indirectly sustain
ar suffer resulting from a breach of this section of the Mortgage or as a consequence of any
use, generation, manufacture, storage, disposal, release or threatened release occurring
prior to Grantor's ownership or interest in the Property, whether or not the same was or
should have been known to Grantor. The provisions of this section of the Mortgage,
including the obligation to indemnify and defend, shall survive the payment of the
Indebtedness and the satisfaction and reconveyance of the lien of this Mortgage and shall
not be affected by Lender's acquisition of any interest in the Property, whether by
foreclosure or otherwise.
Nuisance, Waste. Grantor shall not cause, conduct or permit any nuisance nor commit,
permit, or suffer any stripping of or waste on or to the Property or any portion of the
property. Without limiting the generality of the foregoing, Grantor will not remove, or grant
to any other party the right to remove, any timber, minerals {including oil and gas), coal,
clay, scoria, soil, gravel or rock products without Lender's prior written consent.
Removal of Improvements. Grantor shall not demolish or remove any Improvements from
the Real Property without Lender's prior written consent. As a condition to the removal of
any Improvements, Lender may require Grantor to make arrangements satisfactory to
Lender to replace such Improvements with Improvements of at least squat value.
Fender's Right to Enter. Lender and Lender's agents and representatives may enter upon
the Real Property at all reasonable times to attend to Lender's interests and to inspect the
Real Property for purposes of Grantor's compliance with the terms and conditions of this
Mortgage.
Compliance with Governmental Requirements. Grantor shall promptly comply with all laws,
ordinances, and regulations, now or hereafter in effect, of al! governmental authorities
applicable to the use or occupancy of the Property, including without limitation, the
Americans With Disabilities Act. Grantor may contest in good faith any such taw,
ordinance, or regulation and withhold compliance during any proceeding, including
appropriate appeals, so long as Grantor has notified Lender in writing prior to doing so and
so long as, in Lender's sole opinion, Lender's interests in the Property are not jeopardized.
Lender may require Grantor to post adequate security or a surety band, reasonably
__ ----- -- --- --_ _ _ -- _ _ __-- _ _ _ _4
MORTGAGE
Loan No: 0001-9712337-9001 (Continued} Page 4
satisfactory to Lender, to protect Lender's interest.
Duty to Protect. Grantor agrees neither to abandon or leave unattended the Property.
Grantor shall do all other acts, in addition to those acts set forth above in this section,
which from the character and use of the Property are reasonably necessary to protect and
preserve the Property.
DUE ON SALE -CONSENT SY LENDER. Lende- may, at Lender's option, declare immediately
due and payable all sums secured by this Mortgage upon the sale or transfer, without Lender's
prior written consent, of all or any part of the Real Property, or any interest in the Real
Property. A "sale or transfer" means the conveyance of Real Property or any right, title or
interest in the Real Property; whether legal, beneficial or equitable; whether voluntary or
involuntary; whether by outright sale, deed, installment sale contract, land contract, contract
for deed, leasehold interest with a term greater than three (3} years, lease-option contract, or by
safe, assignment, or transfer of any beneficial interest in or to any land trust holding title to the
Real Property, or by any other method of conveyance of an interest in the Real Property.
However, this option shall not be exercised by Lender if such exercise is prohibited by federal
law or by Pennsylvania law.
TAXE5 AND LIENS. The following provisions relating to the taxes and liens on the Property are
part of this Mortgage:
Payment. Grantor shall pay when due (and in all events prior to delinquency) all taxes,
payroll taxes, special taxes, assessments, water charges and sewer service charges levied
against or on account of the Property, and shall pay when due all claims for work done on
or for services rendered or material furnished to the Property. Grantor shall maintain the
Property free of any liens having priority over or equal to the interest of Lender under this
Mortgage, except for those liens specifically agreed to in writing by Lender, and except for
the lien of taxes and assessments not due as further specified in the Right to Contest
paragraph.
Right to Contest. Grantor may withhold payment of any tax, assessment, or claim in
connection with a good faith dispute over the obligation to pay, so long as Lender's interest
in the Property is not jeopardized. 1f a lien arises or is filed as a result of nonpayment,
Grantor shall within fifteen (15} days after the lien arises or, if a lien is filed, within fifteen
(15) days after Grantor has notice of the filing, secure the discharge of the lien, or if
requested by Lender, deposit with Lender cash or a sufficient corporate surety bond or
other security satisfactory to Lender in an amount sufficient to discharge the lien plus any
costs and reasonable attorneys' fees, or other charges that could accrue as a result of a
foreclosure or sale under the lien. In any contest, Grantor shall defend itself and Lender and
shall satisfy any adverse judgment before enforcement against the Property. Grantor shall
name Lender as an additional obligee under any surety bond furnished in the contest
proceedings.
Evidence of Payment. Grantor shall upon demand furnish to Lender satisfactory evidence of
payment of the taxes or assessments and shall authorize the appropriate governmental
official to deliver to Lender at any time a written statement of the taxes and assessments
against the Property.
!Notice of Construction. Grantor shall notify lender at least fifteen (15) days before any
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MORTGAGE
Loan No: 0001-9712337-9001 (Continued)
Page 5
work is commenced, any services are furnished, or any materials are supplied to the
Property, if any mechanic's lien, materialmen's lien, or other lien could be asserted on
account of the work, services, or materials. Grantor will upon request of Lender furnish to
Lender advance assurances satisfactory to Lender that Grantor can and will pay the cost of
such improvements.
PROPERTY DAMAGE INSURANCE. The following provisions relating to insuring the Property
are a part of this Mortgage:
Maintenance of Insurance. Grantor shall procure and maintain policies of fire insurance with
standard extended coverage endorsements on a replacement basis for the full insurable
value covering all Improvements on the Real Property in an amount sufficient to avoid
application of any coinsurance clause, and with a standard mortgagee clause in favor of
Lender. Grantor shall also procure and maintain comprehensive general liability insurance in
such coverage amounts as Lender may request with Lender being named as additional
insureds in such liability insurance policies. Additionally, Grantor shall maintain such other
insurance, including but not limited to hazard, business interruption and boiler insurance as
Lender may require. Policies shall be written by such insurance companies and in such form
as may be reasonably acceptable to Lender. Grantor shall de{iver to Lender certificates of
coverage from each insurer containing a stipulation that coverage will not be cancelled or
diminished without a minimum of thirty (30) days' prior written notice to Lender and not
containing any disclaimer of the insurer's liability for failure to give such notice. Each
insurance policy also shall include an endorsement providing that coverage in favor of
Lender will not be impaired in any way by any act, omission or default of Grantor or any
other person. Should the Real Property be located in an area designated by the Director of
the Federal Emergency Management Agency as a special flood hazard area, Grantor agrees
to obtain and maintain Federal Flood Insurance, if available, for the full unpaid principal
balance of the loan and any prior liens on the property securing the loan, up to the
maximum policy limits set under the National Flood Insurance Program, or as otherwise
required by Lender, and to maintain such insurance for the term of the loan.
Application of Proceeds. Grantor shall promptly notify Lender of any loss or damage to the
Property. Lender may make proof of loss if Grantor fails to do so within fifteen {15) days of
the casualty. Whether or not Lender's security is impaired, Lender may, at Lender's
election, receive and retain the proceeds of any insurance and apply the proceeds to the
reduction of the Indebtedness, payment of any Tien affecting the Property, or the restoration
and repair of the Property. if Lender elects to apply the proceeds to restoration and repair,
Grantor shall repair or replace the damaged or destroyed Improvements in a manner
satisfactory to Lender. Lender shall, upon satisfactory proof of such expenditure, pay or
reimburse Grantor from the proceeds for the reasonable cost of repair or restoration if
Grantor is not in default under this Mortgage. Any proceeds which have not been disbursed
within 180 days after their receipt and which Lender has not committed to the repair or
restoration of the Property shall be used first to pay any amount owing to Lender under this
Mortgage, then to pay accrued interest, and the remainder, if any, shall be applied to the
principal balance of the Indebtedness. If Lender holds any proceeds after payment in full of
the Indebtedness, such proceeds shall be paid to Grantor as Grantor's interests may appear.
LENDER'S EXPENDITURES. If any action or proceeding is commenced that would materially
affect Lender's interest in the Property or if Grantor tails to comply with any provision of this
6
MORTGAGE
Loan No: 0001-9712337-9001 {Continued) Page 6
Mortgage or any Related Documents, including but not limited to Grantor's failure to discharge
or pay when due any amounts Grantor is required to discharge or pay under this Mortgage or
any Related Documents, Lender on Grantor's behalf may {but shall not be obligated to) take any
action that Lender deems appropriate, including but not limited to discharging or paying all
taxes, liens, security interests, encumbrances and other claims, at any time levied or placed on
the Property and paying all costs for insuring, maintaining and preserving the Property. Al! such
expenditures incurred or paid by Lender for such purposes will then bear interest at the rate
charged under the Note from the date incurred or paid by Lender to the date of repayment by
Grantor. All such expenses will become a part of the Indebtedness and, at Lender's option, will
(A) be payable on demand; (B) be added to the balance of the Nate and be apportioned
among and be payable with any installment payments to become due during either {1) the
term of any applicable insurance policy; or (2) the remaining term of the Note; or {C) be
treated as a balloon payment which will be due and payable at the Note's maturity. The
Mortgage also will secure payment of these amounts. Such right shall be in addition to al! other
rights and remedies to which Lender may be entitled upon Default. Grantor's obligation to
Lender for all such expenses shall survive the entry of any mortgage foreclosure judgment.
WARRANTY; DEFENSE OF TITLE. The following provisions relating to ownership of the
Property are a part of this Mortgage:
Title. Grantor warrants that: {a) Grantor holds good and marketable title of record to the
Property in fee simple, tree and clear of all liens and encumbrances other than those set
forth in the Real Property description or in any title insurance policy, title report, or final title
opinion issued in favor of, and accepted by, Lender ;n connection with this Mortgage, and
(b) Grantor has the full tight, power, and authority to execute and deliver this Mortgage to
Lender.
Defense of Title. Subject to the exception in the paragraph above, Grantor warrants and
will forever defend the title to the Property against the lawful claims of all persons. In the
event any action or proceeding is commenced that questions Grantor's title or the interest
of lender under this Mortgage, Grantor shall defend the action at Grantor's expense.
Grantor may be the nominal party in such proceeding, but Lender shall be entitled to
participate in the proceeding and to be represented in the proceeding by counsel of Lender's
own choice, and Grantor will deliver, or cause to be delivered, to Lender such instruments
as Lender may request from time to time to permit such participation.
Compliance With Laws. Grantor warrants that the Property and Grantor's use of the
Property complies with al! existing applicable laws, ordinances, and regulations of
governmental authorities.
Survival of Representations and Warranties. All representations, warranties, and
agreements made by Grantor in this Mortgage shag survive the execution and delivery of
this Mortgage, shah be continuing in nature, and shall remain in full force and effect until
such time as Grantor's Indebtedness shall be paid in full.
CONDEMNATION. The following provisions relating to condemnation proceedings are a part of
this Mortgage:
Proceedings. If any proceeding in condemnation is filed, Grantor shall promptly notify
Lender in writing, and Grantor shall promptly take such steps as may be necessary to
MORTGAGE
Loan No: 0001-9712337-9001 tCoaltinued) Page 7
defend the action and obtain the award. Grantor may be the nominal party in such
proceeding, but Lender shall be entitled to participate in the proceeding and to be
represented in the proceeding by counsel of its own choice, and Grantor will deliver or
cause to be delivered to Lender such instruments and documentation as may be requested
by Lender from time to time to permit such participation.
Application of Net Proceeds. If all or any part of the Property is condemned by eminent
domain proceedings or by any proceeding or purchase in lieu of condemnation, lender may
ai its election require that all or any portion of the net proceeds of the award be applied to
the Indebtedness or the repair or restoration of the Property. The net proceeds of the
award shall mean the award after payment of all actual costs, expenses, and attorneys' fees
incurred by Lender in connection with the condemnation.
IMPOSI7iON OF TAXES, FEES AND CHARGES BY GOVERNMENTAL AUTHORITIES. The
following provisions relating to governmental taxes, fees and charges are a part of this
Mortgage:
Current Taxes, Fees and Charges. Upon request by Lender, Grantor shall execute such
documents in addition to this Mortgage and take whatever other action is requested by
Lender to perfect and continue Lender's lien on the Real Property. Grantor shall reimburse
Lender for all taxes, as described below, together with atl expenses incurred in recording,
perfecting or continuing this Mortgage, including without limitation all taxes, fees,
documentary stamps, and other charges for recording or registering this Mortgage.
Taxes. The following shall constitute taxes to which this section applies: (1 } a specific tax
upon this type of Mortgage or upon all or any part of the Indebtedness secured by this
Mortgage; {2} a specific tax on Grantor which Grantor is authorized or required to deduct
from payments on the Indebtedness secured by this type of Mortgage; (3) a tax on this
type of Mortgage chargeable against the Lender or the holder of the Note; and (4> a
specific tax on all or any portion of the Indebtedness or on payments of principal and
interest made by Grantor.
Subsequent Taxes. If any tax to which this section applies is enacted subsequent to the
date of this Mortgage, this event shall have the same effect as an Event of Default, and
Lender may exercise any or all of its available remedies for an Event of Default as provided
below unless Grantor either (1) pays the tax before it becomes delinquent, or {2)
contests the tax as provided above in the Taxes and Liens section and deposits with Lender
cash or a su#ficient corporate surety bond or other security satisfactory to Lender.
SECURITY AGREEMENT; FINANCING STATEMENTS. The following provisions relating to this
Mortgage as a security agreement are a part of this Mortgage:
Security Agreement. This instrument shall constitute a Security Agreement to the extent
any of the Property constitutes fixtures, and Lender shall have all of the rights of a secured
party under the Uniform Commercial Code as amended from time to time.
Security Interest. Upon request by lender, Grantor shall take whatever action is requested
by Lender to perfect and continue Lender's security interest in the Rents and Personal
Property. In addition to recording this Mortgage in the real property records, Lender may, at
any time and without further authorization from Grantor, file executed counterparts, copies
or reproductions of this Mortgage as a financing statement. Grantor shall reimburse Lender
__ _ _ _ - ___ _- ___ _ --a
MORTGAGE
Loan No: 0001-9712337-9001 (Continued) Page 8
for alt expenses incurred in perfecting or continuing this security interest. Upon default,
Grantor shall not remove, sever or detach the Persona) Property from the Property. Upon
default, Grantor shall assemble any Personal Property not affixed to the Property in a
manner and at a place reasonably convenient to Grantor and Lender and make it available to
Lender within three (3) days after receipt of written demand from Lender to the extent
permitted by applicable law.
Addresses. The mailing addresses of Grantor (debtor) and Lender (secured party) from
which information concerning the security interest granted by this Mortgage may be
obtained leach as required by the Uniform Commercial Code) are as stated on the first page
of this Mortgage.
FURTHER ASSURANCES; ADDITIONAL AUTHORIZATIONS. The following provisions relating
to further assurances and additional authorizations are a part of this Mortgage:
Further Assurances. At any time, and from time to time, upon request of Lender, Grantor
will make, execute and deliver, or will cause to be made, executed or delivered, to Lender or
to Lender's designee, and when requested by Lender, cause to be filed, recorded, refiled, or
rerecorded, as the case may be, at such times and in such offices and places as Lender may
deem appropriate, any and all such mortgages, deeds of trust, security deeds, security
agreements, financing statements, continuation statements, instruments of turther
assurance, certificates, and other documents as may, in the sole opinion of Lender, be
necessary or desirable in order to effectuate, complete, perfect, continue, or preserve 11)
Grantor's obligations under the Note, this Mortgage, and the Related Documents, and (2)
the {tens and security interests created by this Mortgage on the Property, whether now
owned or hereafter acquired by Grantor. Unless prohibited by law or Lender agrees to the
contrary in writing, Grantor shall reimburse Lender #or all costs and expenses incurred in
connection with the matters referred to in this paragraph.
Additional Authorizations. If Grantor fails to do any of the things referred to in the
preceding paragraph, Lender may do so for and in the name of Grantor and at Grantor's
expense. For such purposes, Grantor hereby irrevocably authorizes Lender to make,
execute, deliver, file, record and do all other things as may be necessary or desirable, in
Lender's sole opinion, to accomplish the matters referred to in the preceding paragraph. It
is understood that nothing set forth herein shall require tender to take any such actions.
FULL PERFORMANCE. If Grantor pays all the Indebtedness when due, and otherwise performs
all the obligations imposed upon Grantor under this Mor#gage, Lender shall execute and deliver
to Grantor a suitable satisfaction of this Mortgage and suitable statements of termination of any
financing statement on file evidencing Lender's security interest in the Rents and the Personal
Property. Grantor will pay, if permitted by applicable law, any reasonable termination tee as
determined by Lender from time to time.
EVENTS OF DEFAULT. Each of the following, at Lender's option, shall constitute an Event of
Default under this Mortgage:
Payment Default. Grantor fails to make any payment when due under the Indebtedness.
Default on Other Payments. Failure of Grantor within the time required by this Mortgage to
make any payment for taxes or insurance, or any other payment necessary to prevent filing
of or to effect discharge of any lien.
C
MORTGAGE
Loan No: 0001-9712337-9001 (Continued)
Page 9
Other Defaults. Grantor fails to comply with or to perform any other term, obligation,
covenant or condition contained in this Mortgage or in any of the Related Documents or to
comply with or to perform any term, obligation, covenant or condition contained in any
other agreement between Lender and Grantor.
Defauk in Favor of Third Parties. Should Grantor default under any loan, extension of
credit, security agreement, purchase or sales agreement, or any other agreement, in favor of
any other creditor or person that may materially affect any of Grantor's property or
Grantor's ability to repay the Indebtedness or Grantor's ability to perform Grantor's
obligations under this Mortgage or any of the Relayed Documents.
False Statements. Any warranty, representation or statement made or furnished to Lender
by Grantor or on Grantor's behalf under this Mortgage or the Related Documents is false or
misleading in any material respect, either now or at the time made or furnished or becomes
false or misleading at any time thereafter.
Detective Collateralization. This Mortgage or any of the Related Documents ceases to be in
full force and effect {including failure of any collateral document to create a valid and
perfected security interest or Lien} at any time and for any reason.
Death or Insolvency. The death of Grantor, the insolvency of Grantor, the appointment of a
receiver for any part of Grantor's property, any assignment for the benefit of creditors, any
type of creditor workout, or the commencement of any proceeding under any bankruptcy or
insolvency taws by or against Grantor.
Creditor or Forfeiture Proceedings, Commencement of foreclosure or forfeiture proceedings,
whether by judicial proceeding, self-help, repossession or any other method, by any creditor
of Grantor or by any governmental agency against any property securing the Indebtedness.
This includes a garnishment of any of Grantor's accounts, including deposit accounts, with
Lender. However, this Event of Default shall not apply if there is a good faith dispute by
Grantor as to the validity or reasonableness of the claim which is the basis of the creditor or
forfeiture proceeding and if Grantor gives Lender written notice of the creditor or forfeiture
proceeding and deposits with Lender monies or a surety bond for the creditor or forfeiture
proceeding, in an amount determined by Lender, in its sole discretion, as being an adequate
reserve or bond for the dispute.
Breach of Other Agreement. Any breach by Grantor under the terms of any other
agreement between Grantor and Lender that is not remedied within any grace period
provided therein, including without limitation any agreement concerning any indebtedness or
other obligation of Grantor to Lender, whether existing now or later.
Events Affecting Guarantor. Any of the preceding events occurs with respect to any
Guarantor of any of the Indebtedness or any Guarantor dies or becomes incompetent, or
revokes or disputes the validity of, or liability under, any Guaranty of the Indebtedness.
Adverse Change. A material adverse change occurs in Grantor's financial condition, or
lender believes the prospect of payment or performance of the Indebtedness is impaired.
Insecurity. Lender in good faith believes itself insecure.
Right to Cure. If any default, other than a default in payment is curable and if Grantor has
not been given a notice of a breach of the same provision of this Mortgage within the
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MORTGAGE
Loan No: 0001-9712337-9001 1Contlttuedl Page 10
preceding twelve (12- months, it may be cured if Grantor, after Lender sends written notice
to Grantor demanding cure of such default: (1) cures the default within fifteen (15) days;
or (2) if the cure requires more than fifteen (15) days, immediately initiates steps which
Lender deems in Lender's sole discretion to be sufficient to cure the default and thereafter
continues and completes all reasonable and necessary steps sufficient to produce
compliance as soon as reasonably practical.
RIGHTS AND REMEDIES ON DEFAULT. Upon the occurrence of an Event of Default and at any
time thereafter, Lender, at Lender's option, may exercise any one or more of the following
rights and remedies, in addition to any other rights or remedies provided by law:
Accelerate Indebtedness. Lender shall have the right at its option, after giving such notices
as required by applicable law, to declare the entire Indebtedness immediately due and
payable.
UCC Remedies. With respect to all or any part of the Personal Property, Lender shall have
all the rights and remedies of a secured party under the Uniform Commercial Code.
Collect Rents. Lender shall have the right, without notice to Grantor, to take possession of
the Property and, with or without taking possession of the Property, to collect the Rents,
including amounts past due and unpaid, and apply the net proceeds, over and above
Lender's costs, against the Indebtedness. In furtherance of this right, Lender may require
any tenant or other user of the Property to make payments of rent or use fees directly to
Lender. if the Rents are collected by Lender, then Grantor irrevocably authorizes Lender to
endorse instruments received in payment thereof in the name of Grantor and to negotiate
the same and collect the proceeds. Payments by tenants or other users to Lender in
response to Lender's demand shall satisfy the obligations for which the payments are made,
whether or not any proper grounds for the demand existed. Lender may exercise its rights
under this subparagraph wither in person, by agent, or through a receiver.
Appoint Receiver. Lender shall have the right to have a receiver appointed to take
possession of all or any part of the Property, with the power to protect and preserve the
Property, to operate the Property preceding foreclosure or sale, and to collect the Rents
from the Property and apply the proceeds, over and above the cost of the receivership,
against the Indebtedness. The receiver may serve without bond if permitted by law.
Lender's right to the appointment of a receiver shall exist whether or not the apparent value
of the Property exceeds the Indebtedness by a substantial amount. Employment by Lender
shall not disqualify a person from serving as a receiver.
Judicial Foreclosure. Lender may obtain a judicial decree foreclosing Grantor's interest in all
or any part of the Property.
Possession of the Property. For the purpose of procuring possession of the Property,
Grantor hereby authorizes and empowers any attorney of any court of record in the
Commonwealth of Pennsylvania or elsewhere, as attorney for Lender and all persons
claiming under or through Lender, to sign an agreement for entering in any competent court
an amicable action in ejectment for possession of the Property and to appear for and
confess judgment against Grantor, and against all persons claiming under or through
Grantor, for the recovery by Lender of possession of the Property, without any stay of
execution, for which this Mortgage, or a copy of this Mortgage verified by affidavit, shall be
- -- _.-- - - - - - -- _---- __ - - - - --- --- - ___ 11
MORTGAGE
Loan No: 0001-9712337-9001 (Continued)
Page 11
a sufficient warrant; and thereupon a writ of possession may be issued forthwith, without
any prior writ or proceeding whatsoever.
Nonjudicia! Sale. If permitted by applicable law, Lender may foreclose Grantor's interest in
all or in any part of the Personal Property or the Real Property by non-judicial sale.
Qeficiency Judgment. Lender may obtain a judgment for any deficiency remaining in the
Indebtedness due to Lender after application of all amounts received from the exercise of
the rights provided in this section.
Tenancy at Sufferance. If Grantor remains in possession of the Property afiter the Property
is sold as provided above or Lender otherwise becomes entitled to possession of the
Property upon default of Grantor, Grantor shall become a tenant at sufferance of Lender or
the purchaser of the Property and shall, at Lender's option, either { 1) pay a reasonable
rental for the use of the Property, or {2) vacate the Property immediately upon the demand
of Lender.
Other Remedies. Lender shall have ail other rights and remedies provided in this Mortgage
or the Note or available at law or in equity.
Sale of the Property. To the extent permitted by applicable law, Grantor hereby waives any
and all right to have the Property marshalled. In exercising its rights and remedies, Lender
shall be free to sell ail or any part of the Property together or separately, in one sale or by
separate sales. Lender shall be entitled to bid at any public sale on all or any portion of the
Property.
Notice of Sale. Lender shall give Grantor reasonable notice of the time and place of any
public sale of the Personal Property or of the time after which any private sale or other
intended disposition of the Personal Property is to be made. Unless otherwise required by
applicable law, reasonable notice shat! mean notice given at least ten (10) days before the
time of the saie or disposition. Any sale of the Personal Property may be made in
conjunction with any sale of the Real Property.
Election of Remedies. Election by Lender to pursue any remedy shall not exclude pursuit of
any other remedy, and an election to make expenditures or to take action to perform an
obligation of Grantor under this Mortgage, after Grantor's failure to perform, shall not affect
Lender's right to declare a default and exercise its remedies. Nothing under this Mortgage
or otherwise shall be construed so as to limit or restrict the rights and remedies available to
Lender following an Event of Default, or in any way to limit or restrict the rights and ability
of Lender to proceed directly against Grantor andJor against any other co-maker, guarantor,
surety or endorser and/or to proceed against any other collateral directly or indirectly
securing the Indebtedness.
Attorneys' Fees; Expenses. If Lender institutes any suit or action to enforce any of the
terms of this Mortgage, Lender shall be entitled to recover such sum as the court may
adjudge reasonable as attorneys' fees at trial and upon any appeal. Whether or not any
court action is involved, and to the extent not prohibited by law, all reasonable expenses
Lender incurs that in Lender's opinion are necessary at any time for the protection of its
interest or the enforcement of its rights shall become a part of the Indebtedness payable on
demand and shall bear interest at the Note rate from the date of the expenditure until
repaid. Expenses covered by this paragraph include, without limitation, however subject to
-- - _ _ 12
MORTGAGE
Loan No: 0001-9712337-9001 (COntltlued) Page 12
any limits under applicable law, Lender's reasonable attorneys' fees and Lender's legal
expenses, whether or not there is a Lawsuit, including reasonable attorneys' fees and
expenses for bankruptcy proceedings (including of#orts to modify or vacate any automatic
stay or injunctionl, appeals, and any anticipated post-judgment collection services, the cost
of searching records, obtaining title reports (including foreclosure reports), surveyors'
reports, and appraisal tees and title insurance, to the extent permitted by applicable law.
Grantor also will pay any court costs, in addition to all other sums provided by law.
NOTICES. Unless otherwise provided by applicable law, any notice required to be given under
this Mortgage shall be given in writing, and shall be effective when actually delivered, when
actually received by telefacsimile (unless otherwise required by law), when deposited wish a
nationally recognized overnight courier, or, if mailed, when deposited in the United States mail,
as first class, certified or registered mail postage prepaid, directed to the addresses shown near
the beginning of this Mortgage. All copies of notices of foreclosure from the holder of any lien
which has priority over this Mortgage and notices pursuant to 42 Pa. C.S.A. Section 8143, et.
seq., shall be sent to Lender's address, as shown near the beginning of this Mortgage. Any
party may change its address for notices under this Mortgage by giving formal written notice to
the other parties, specifying that the purpose of the notice is to change the party's address.
For notice purposes, Grantor agrees to keep Lender informed at all times of Grantor's current
address. Unless otherwise provided by applicable law, if there is more than one Grantor, any
notice given by Lender to any Grantor is deemed to be notice given to all Grantors.
ADVANCE MONEY MORTGAGE. (A} This Mortgage secures future advances made pursuant
to the Note or Related Documents. Without limiting the foregoing, this Mortgage secures all
advances made by Lender or Banks of any kind or nature described in 42 Pa. C.S.A. § 8144.
(B- If Grantor sends a written notice to Lender which purports to limit the indebtedness
secured by this Mortgage and to release the obligation of Lender to make any additional
advances to or for the benefit of Grantor, such a notice shall be ineffective as to any future
advances made: (1 } to enable completion of the improvements on the Real Property for which
the loan secured hereby was originally made; i2) to pay taxes, assessments, maintenance
charges and insurance premiums; (3) for costs incurred for the protection of the Property or
the lien of this Mortgage; (4) on account of expenses incurred by Lender by reason of a default
of Grantor hereunder or under the Related Documents or under the Note; and (5} on account of
any other costs incurred by Lender to protect and preserve the Property or the lien of this
Mortgage. It is the intention of the parties hereto that any such advance made by Lender after
any such notice by Grantor shall be secured by the lien of this Mortgage on the Property.
MISCELLANEOUS PROVISIONS. The following miscellaneous provisions are apart of this
Mortgage:
Amendments. This Mortgage, together with any Related Documents, constitutes the entire
understanding and agreement of the parties as to the matters set forth in this Mortgage.
No alteration of or amendment to this Mortgage shall be effective unless given in writing
and signed by the party or parties sought to be charged or bound by the alteration or
amendment.
Annual Reports. If the Property is used for purposes other than Grantor's residence,
Grantor shall furnish to Lender, upon request, a certified statement of net operating income
received tram the Property during Grantor's previous fiscal year in such form and detail as
MORTGAGE
Loan No: 0001-9712337-9001 (COntlrtu@d) Page 13
Lender shalt require. "Net operating income" shall mean all cash receipts trom the Property
less all cash expenditures made in connection with the operation of the Property.
Caption Headings. Caption headings in this Mortgage are for convenience purposes only
and are not to be used to interpret or define the provisions of this Mortgage.
Governing Law. This Mortgage wi{I be governed by federal law applicable to Lender and, to
the extent not preempted by federal law, the laws of the Commonwealth of Pennsylvania
without regard to its conflicts of law provisions. This Mortgage has been accepted by
Lender in the Commonwealth of Pennsylvania.
Joint and Several Liability. All obligations of Grantor under this Mortgage shall be joint and
several, and aH references to Grantor shall mean each and every Grantor. This means that
each Grantor signing below is responsible for all obligations in this Mortgage.
No Waiver by Lender. Lender shall not be deemed to have waived any rights under this
Mortgage unless such waiver is given in writing and signed by Lender. No delay or
omission on the part of Lender in exercising any right shall operate as a waiver of such right
or any other right. A waiver by Lender of a provision of this Mortgage shall not prejudice or
constitute a waiver of Lender's right otherwise to demand strict compliance with that
provision or any other provision of this Mortgage. No prior waiver by lender, nor any
course of dealing between Lender and Grantor, shall constitute a waiver of any of Lender's
rights or of any of Grantor's obligations as to any future transactions. Whenever the
consent of Lender is required under this Mortgage, the granting of such consent by Lender
in any instance shall not constitute continuing consent to subsequent instances where such
consent is required and in all cases such consent may be granted or withheld in the sole
discretion of Lender.
Severability. 1f a court of competent jurisdiction finds any provision of this Mortgage to be
illegal, invalid, or unenforceable as to any person or circumstance, that finding shall not
make the offending provision illegal, invalid, or unenforceable as to any other person or
circumstance. If feasible, the offending provision shall be considered modified so that it
becomes legal, valid and enforceable. If the offending provision cannot be so modified, ii
shall be considered deleted from this Mortgage. Unless otherwise required by law, the
illegality, invalidity, or unenforceability of any provision of this Mortgage shall not affect the
legality, validity or enforceability of any other provision of this Mortgage.
Merger. There shall be no merger of the interest or estate created by this Mortgage with
any other interest or estate in the Property at any time held by or for the benefit of Lender
in any capacity, without the written consent of Lender.
Successor Interests. The terms of this Mortgage shall be binding upon Grantor, and upon
Grantor's heirs, personal representatives, successors, and assigns, and shall be enforceable
by Lender and its successors and assigns.
Time is of the Essence. Time is of the essence in the performance of this Mortgage.
Waive Jury. All parties to this Mortgage hereby waive the right to any jury trial in any
action, proceeding, or counterclaim brought by any party against any other party.
DEFINITIONS. The following capitalized words and terms shall have t:he following meanings
when used in this Mortgage. Unless specifically stated to the contrary, all references to dollar
-- _--
MORTGAGE
Loan No: 0001-9712337-9001 (Continued) Page 14
amounts shall mean amounts in lawful money of the United States of America. Words and
terms used in the singular shall include the plural, and the plural shat) include the singular, as
the context may require. Words and terms not otherwise defined in this Mortgage shall have
the meanings attributed to such terms in the Uniform Commercial Code:
Borrower. The word "Borrower" means Stacy Buxton and Eric Buxton and includes all
co-signers and co-makers signing the Note and all their successors and assigns.
Default. The word "Default" means the Default set forth in this Mortgage in the section
titled "Default".
Environmental Laws. The words "Environmental Laws" mean any and all state, federal and
local statutes, regulations and ordinances relating to the protection of human health or the
environment, including without limitation the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended, 42 U.S.C. Section 9601, et seq.
("CERCLA"}, the Superfund Amendments and Reauthorization Act of 1986, Pub. L. No.
99-499 ("SARA"?, the Hazardous Materials Transportation Act, 49 U.S.C. Section 1801, et
seq., the Resource Conservation and Recovery Act, 42 U.S.C. Section 6901, et seq., or
other applicable state or federal laws, rules, or regulations adopted pursuant thereto.
Event of Default. The words "Event of Default" mean any of the events of default set forth
in this Mortgage in the events of default section of this Mortgage.
Grantor. The word "Grantor" means Stacy Buxton and Eric Buxton.
Guarantor. The word "Guarantor" means any guarantor, surety, or accommodation party of
any or all of the Indebtedness.
Guaranty. The word "Guaranty" means the guaranty from Guarantor to Lender, including
without limitation a guaranty of all or part of the Note.
Hazardous Substances. The words "Hazardous Substances" mean materials that, because
of their quantity, concentration or physical, chemical or infectious characteristics, may
cause or pose a present or potential hazard to human health or the environment when
improperly used, treated, stored, disposed of, generated, manufactured, transported or
otherwise handled. The words "Hazardous Substances" are used in their very broadest
sense and include without limitation any and all hazardous or toxic substances, materials or
waste as defined by or listed under the Environmental Laws. The term "Hazardous
Substances" also includes, without limitation, petroleum and petroleum by-products or any
fraction thereof and asbestos.
Improvements. The word "Improvements" means all existing and future improvements,
buildings, structures, mobile homes affixed on the Real Property, facilities, additions,
replacements and other construction on the Real Property.
Indebtedness. The word "Indebtedness" means alt principal, interest, and other amounts,
costs and expenses payable under the Note or Related Documents, together with all
renewals of, extensions of, modifications of, consolidations of and substitutions for the
Note or Related Documents and any amounts expended or advanced by Lender to discharge
Grantor's obligations or expenses incurred by Lender to enforce Grantor's obligations under
this Mortgage, together with interest on such amounts as provided in this Mortgage.
-- - _ _ _ _ - -_-_ _ - _ - 15
MORTGAGE
Loan No: 0001-9712337-9001 (Continued) Page 15
Lender. The word "Lender" means Fulton Bank, N.A., its successors and assigns.
Mortgage. The word "Mortgage" means this Mortgage between Grantor and Lender.
Note. The word "Note" means the promissory note dated March 10, 2010, in the original
principal amount of 5315,080.00 from Grantor to Lender, together with all renewals of,
extensions of, modifications of, refinancings of, consolidations of, and substitutions for the
promissory note or agreement. NOTICE TO GRANTOR: THE NOTE CONTAINS A VARIABLE
INTEREST RATE.
Personal Property. The words "Personal Property" mean alt equipment, fixtures, and other
articles of personal property now or hereafter owned by Grantor, and now or hereafter
attached or affixed to the Real Property; together with all accessions, parts, and additions
to, all replacements of, and all substitutions for, any of such property; and together with all
proceeds (including without limitation all insurance proceeds and refunds of premiums? from
any sale or other disposition of the Property.
Property. The word "Property" means collectively the Real Property and the Personal
Property.
Real Property. The words "Real Property" mean the real property, interests and rights, as
further described in this Mortgage.
Related Documents. The words "Related Documents" mean all promissory notes, credit
agreements, loan agreements, environmental agreements, guaranties, security agreements,
mortgages, deeds of trust, security deeds, collateral mortgages, and all other instruments,
agreements and documents, whether now or hereafter existing, executed in connection with
the Indebtedness.
Rents. The word "Rents" means all present and future rents, revenues, income, issues,
royalties, profits, and other benefits derived from the Property.
__ _ _l6
MORTGAGE
Loan No: 0001-9712337-9001 (Continued) Page 16
EACH GRANTOR ACKNOWLEDGES HAVING READ ALL THE PROVISIONS OF THIS
MORTGAGE, AND EACH GRANTOR AGREES TO ITS TERMS.
THIS MORTGAGE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS MORTGAGE IS
AND SHALL CONSTITUTE AND HAVE 7HE EFFECT OF A SEALED INSTRUMENT ACCORDING
TO LAW.
GRANTOR:
X % (Seal)
Stacy Buxto
X _ iSeall
E~ Bux~tS - "C.~
Signed, a/cknowledged and delivered in the presence of:
X
v
X J~L~ _ _
CERTIFICATE OF RESIDENCE
1 hereby certify, that the precise address of the mortgagee, Fulton Bank, N.A., herein is as
follows:
Downtown Harrisburg Office, One Penn Square, Corporate Address, Lancaster, PA 17602
~. `~
At orney or Agent for agee
MORTGAGE
Loan No: 0001-9712337-9001 (Continued) Page 17
INDIVIDUAL ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF ~~AA(~ E1I1,~1.rn 1
On this, the _ 7-i day of u _, 20 /CL_, before
me _ -rsu ~1 ~F~~~ . ~~- the undersigned Notary Public, personally appeared Stacy
Buxton and Eric Buxton, known to me (or satisfactorily proveni to be the person whose names
are subscribed to the within instrument, and acknowledged that they executed the same for the
purposes therein contained.
In witness whereof, I hereunto set my hand a o 1 sea
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Stephen M. Reeves, Jr., Notary Public
t;~yptHarristwrg,DaUphinCouMY Notary Public in and for the State of F./.~
My Commission Expires July 28, 2010
Member. Pennsylvania AssoGation.of Notaries
LASER PRO Lending, Ver. 5.48.00.004 Copr. Harland Financial Solutions, Inc. 1997, 2010.
Alt Rights Reserved. - PA G:\LPLICOML\CFI\LPL1G03.FC TR-41623
ALL THAT CERTAIN lot or piece of ground situate on the Northwesterly corner of Pennsylvania State
Highway Legislative Route No. 21022 known as Carlisle Road, and Commercial Drive, in Block "1", on
the Plan of "Greater Highland Park", in the Township of Lower Allen, County of Cumberland and
Commonwealth of Pennsylvania, more fully bounded and described by true North bearings derived from
solar observations of the Pennsylvania Department of Highways, and surveyed by Earle M. Frankhouser
Associates, Inc. of Reading, Pennsylvania, as follows, to wit:
BEGINNING at the intersection of the Northerly right-of--way line of Pennsylvania State Highway
Legislative Route No. 21022 (fifty (50) feet wide) with the Westerly lot line of Commercial Drive (sixty
(60) feet wide); THENCE extending along the right-of--way line oFPennsylvania State Highway
Legislative Route No. 21022, known as the Carlisle Road, the four (4) following courses and distances: (1)
North eighty-five (85) degrees six (6) minutes West by a fine twenty-five (25) feet Northward from and
parallel with the center line of said right-of--way, adistance ofthirty-two and thirty-one one-hundredths
(32.31) feet to a point; (2) South four (4) degrees fifty-four (54}minutes West, a distance of five (5) feet to
a point; (3) North eighty-five (85) degrees six (6) minutes West, by a line twenty (20) Feet Northward from
and parallel with the center lien of said highway, a distance of seventy-two and sixty-seven one-
hundredths (72.67) feet to the point of curvature in said Northerly right-of--way line; (4} in a Westerly
direction along the arc of a curve deflecting to the left having a radius of two thousand five hundred sixty-
six and sixty-four one-hundredths (2,56b.64) feet to a central angle of no (0) degrees thirty-two (32)
minutes one and thirteen one-hundredths (1.13) seconds, the chord of said curve bearing North eighty-five
(85) degrees twenty-two (22) minutes West for adistance oftwenty-three and ninety-one one-hundredths
(23.91) feet to a point; THENCE leaving said Carlisle Road and extending along House No. 154b Carlisle
Road, the property now or late of Raymond R. Kurtz and Catherine 8. Kurtz, North eight (8) degrees no (0)
minutes twenty (20) seconds West, a distance of one hundred forty-eight and thirty-tive one-hundredths
(148.35} feet to a point; THENCE extending along land now or late of N.P. Ninneman and Naomi S.
Ninneman, his wife, South eighty-eight (88) degrees ten (10) minutes fifty {50) seconds Bast, a distance of
ninety-four and forty-nine one-hundredths (94.49) feet to a point on the westerly lot line of Commercial
Drive, South twenty (20) degrees ten (i0) minutes no (0) seconds, a distance of one hundred fifty-nine and
sixty-two one-hundredths (159.62) feet to the place of BEGINNING.
CONTAINING in area sixteen thousand five hundred fifty and one-tenth (16,550.1,1 square feet of land.
+° ~-
I
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201006124
Recorded On 3/11/2010 At 10:11:21 AM
* Instrument Typc -MORTGAGE
Invoice Number - 62099 User ID - KW
* Mortgagor -BUXTON, ERIC
* Mortgagee - FULTON BANK N A
* Customer -ASSURED LAND
* 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 - I9
°-.:_ _ 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
OM ~ M ~j~ ~~ ,D
v ~
RECORDER O D EDS
trao
* -Information denoted by an asterisk may change during
the verifreation process and may not be reflected on this page.
001QWi
II(f I((II(li(l lllllllll ll 111
KEEFER WOOD ALLEN & RAHAL, LLP
210 WALNUT STREET
PO BOX 11963
HARRISBURG,PA 17108-1963
FULTON BANK, N.A. : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
• CIVIL ACTION - LAW
•
v.
• NO. 13-249 CIVIL
•
STACY BUXTON AND ERIC BUXTON
• MORTGAGE FORECLOSURE
Defendants
PRAECIPE
TO THE PROTHONOTARY:
Please mark this action discontinued, without prejudice.
KEEFER, WOOD, ALLEN & RAHAL, LLP
Date: November 20, 2013 By:
Eugene E. Pepinsky, Jr.
Attorney I.D. #23702
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8051
Attorneys for Plaintiff
Fri
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