HomeMy WebLinkAbout13-1729 Supreme Cour, of Pennsylvania
Con Com Pleas
et For Prothonotary Use Only;
Cum b r County Docket No: ^�
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
Complaint ❑ Writ of Summons ❑ Petition ❑ Notice of Appeal
" ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
�* R Lead Plaintiff's Name: Lead Defendant's Name:
Y Members 1st Federal Credit Union Thomas J. White and Connie R. White
❑ Check here if you are a Self- Represented (Pro Se) Litigant
Name of Plaintiff /Appellant's Attorney: Karl M. Ledebohm, Esq.
Dollar Amount Requested: within arbitration limits
Are money damages requested? : Yes El No (Check one) x outside arbitration limits
w.. Is this a Class Action Suit? ❑ Yes ❑x No
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card 11 Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Zoning Board
S ❑ Product Liability (does not include ❑ Statutory Appeal: Other
mass tort) ❑ Employment Dispute:
" ❑ Slander/Libel/ Defamation Discrimination
C _' ❑ Other: ❑Employment Dispute: Other
Judicial Appeals
❑ MDJ - Landlord /Tenant
❑Other: ❑ MDJ - Money Judgment
MASS TORT ❑ Other:
❑ Asbestos —
N ❑ Tobacco
❑ Toxic Tort - DES _
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
9 Mortgage Foreclosure Restraining Order
PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto
❑ Dental ❑ Quiet Title ❑ Replevin
❑ Legal
❑ Medical ❑ Other: ❑ Other:
❑ Other Professional:
Pa.R.C.P. 205.5 212010
Karl A Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070 -0173
(717)938 -6929
MEMBERS IST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF r� l
Vs. NO.:
THOMAS J. WHITE and
CONNIE R. WHITE CIVIL ACTION — LAW
DEFENDANTS 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 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 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.
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 corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus objections a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte 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 peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED 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.
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070 -0173
(717) 938 -6929
MEMBERS 1 sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF :
Vs. NO.:
THOMAS J. WHITE
and CONNIE R. WHITE
DEFENDANT : CIVIL ACTION - LAW- MORTGAGE
:FORECLOSURE
COMPLAINT
AND NOW, comes Members 1 St 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
1. Plaintiff, Members 1 St Federal Credit Union ( "Members 1 is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Defendants, Thomas J. White and Connie R. White (collectively
"Defendants "), are adult individuals having a last known address of 18
Neponsit Lane, Camp Hill, PA 17011.
3. On or about December 6, 2007, Defendants borrowed from and agreed to
repay to Members 1 St THIRTY THOUSAND SEVEN HUNDRED
SEVENTY -ONE AND 10 /100 ($30,771.10) dollars (the "Loan"). The Loan
is evidenced by a Closed -End Note, Disclosure, Loan and Security Agreement
executed and delivered to Members 1 St by Defendants on December 6, 2007,
(the "Note "). A copy of the Note is attached hereto as Exhibit "A" and made
part hereof.
4. As security for the Loan, Defendants executed and delivered to Members 1 st a
mortgage ( "Mortgage ") on all that certain real estate and improvements
erected thereon situate in Lower Allen Township, Cumberland County,
Pennsylvania, known and numbered as 18 Neponsit Lane, Camp Hill, PA
17011 (the "Property "). A description of the Property is attached hereto as
Exhibit "B" and made part hereof.
5. On or about January 7, 2008, the Mortgage was recorded in the Cumberland
County Recorder of Deeds Office to Instrument No.: 200800534. A true and
correct copy of the Mortgage is attached hereto as Exhibit "C" and made part
hereof.
2
6. The Mortgage has never been assigned by Members 1 st and is still held by it
as a valid and subsisting obligation of Defendant(s).
7. The Mortgage is in default because Defendants have failed to deliver to
Members 1 St the monthly payments of principal and interest due thereon in the
amount of $242.75 each for June through December 2012, and January
through March, 2013, as more particularly described, in part, in the Act 91
Notice attached hereto as Exhibit "D" and made part hereof.
8. Members 1 St 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. SeMc ., 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. SeMc ., by letter dated
February 20, 2013, addressed to Defendants at the Defendants' last known
address set forth in paragraph 2 above being the Property via certified mail,
return receipt requested. A copy of the said notice is attached hereto as Exhibit
"D" and made part hereof.
9. USPS.com Track and Confirm statements evidencing the mailing of said
Notices are attached hereto collectively as Exhibit "E" and made part hereof.
10. Simultaneously, Members 1 St forwarded to Defendants the same Notices and
addressed to Defendants at the same addresses as set forth in paragraph 8 by
United States mail, first class, postage prepaid, bearing the return address of
Members 1 The Notices forwarded in said manner have not been returned to
the offices of Members 1 St as undeliverable or otherwise.
3
11. Defendants are indebted to Members 1 st in connection with the Mortgage in
the amount of THIRTY TWO THOUSAND THREE HUNDRED SEVENTY
AND 98/100 ($32,370.98) dollars itemized as follows:
a. Outstanding principal $29,452.91
b. Interest to April 4, 2013 1,645.23
c. Late fees 72.84
d. Attorney's fees 1,200.00
e. Total due to Members 1 St $32,370.98
12. Defendants also agreed under the terms and conditions of the Mortgage that in
the event of default there under Defendants would pay, in addition to the
amounts set forth in paragraph 11 above, costs incurred by Members 1 St as a
result of the institution and prosecution of these legal proceedings.
13. The obligation owed to Members 1 St continues to accrue interest at the rate of
$5.8422 per day, through the date of payment and continues to accrue
attorney's fees and costs.
14. Members 1 St is not seeking a judgment of personal liability (or an in personam
judgment) against Defendants; however, Members 1 St 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.
4
15. As set forth above, Members 1 St has made demand upon Defendant(s) to pay
to Members 1 St the amounts due under the Mortgage and the Note. However,
as of the date hereof, Defendant(s) continues to refuse and fail to make
payment of such amounts to Members 1 St .
WHEREFORE, Plaintiff, Members 1 St Federal Credit Union, demands judgment,
In Rem against Defendants, Thomas J. White and Connie R. White, in the amount of
THIRTY TWO THOUSAND THREE HUNDRED SEVENTY AND 98/100
($32,370.98) dollars plus interest at the rate of $5.8422 per day, through the date of
judgment 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.
Respectfully submitted,
Date:
arl . Le ebohm q Es .
Supre e Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070 -0173
(717)938 -6929
Attorney for Plaintiff
5
03119/2013 23:05 7179320317 KARLLEDEBOHM PAGE 07/07
MEMBERS 11T FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO..
THOMAS J. WHITE
and CONNIE R. WRITE
DEFENDANT : CIVIL ACTION- LAW - MORTGAGE
:FORECLOSURE
VERIFICATION
T, Dan Summers, Collections Manager for Members I go Federal Credit Union,
being authorized to do so on behalf of Members I' Federal Credit Union, hereby verify
that the statements made in the foregoing pleading are true and correct to the best of my
information knowledge and belief.. I understand that false statements are trade subject to
the penalties of 18 Pa. C.S.A. Section 4904, relating to un.sworn falsification to
authorities.
Members 1' Federal Credit Union
Date: March 2013 By:
Dan Summers, Collections
Manager
6
bt CLOSED•END IVO�V DASrC RFOFMFUT
� 1 5000 WUIse Ddvo. P.O. BOK 40 THOMA WHI
AND AOatcss -
mecherdcsb TFrOMAS J WHRE
trg, PA 17035
_.-_A[
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Pwa,...�..�r,.. a Lro•aw A'SNAMe
FIXED U vmmu
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed. The anauruof Total ofPaymena: The emowa
RATE: The cost or ym me* Fs a The dollar emamt the ere& Vie credit provided to you or on your you wffl have paid after you have
Nearly rate. ' cost you. behalf, made all payrnents as scheduled.
7,24 % • $ 27,Se2.02 . e $ 30.771.10 • $ 56.313.12 a
Varbbb R—a loan eels w molis rw as Maelea above ea AMA Patenage Rae May Noeaw dump the oils a INI 0 5 , a0a pndeq cnsrges. the
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YOU w uc 1 $238.31 Final Due • On Prove 12103!2027 S WA wtan N7 0es 1 Oft
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Y eesale. • P Oat s / rp+r a a•
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S To f To
AMOUNT GIVEN TO YOU DIRECTLY S 36.771.10 $ 7o S To TO
S
It To i TO
i To f To
AMOUNT PAID ON YOUR ACCOUNTS f TO $ To
$ To i To
f To f 1'0
$ To f To
PREPAID FINANCE CHARGE $ 0.00 $ To So= To FM
$ To Avers tame IT To Aw dsaw —
- - '�� ' "' '"'SECURRY:INFORMh4T10N
MAKE MODEL YEAR 1.0. NUMK-R. TYPE VALUE
OTHER (Describe): 18 NEPONST LANE CAMP HILL PA 17011
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1 CO�MAKER O'QTHEROWNER 0 "CO- SIGNER M ATE 0 C04AAKER Q'OTHEROWNER(3 "CO- SIGNER PATE
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Page 1 or 2
Exhibit "A"
1
NAME UWMWaW ,rr'• pATi LO
THOW15 J WHITE 237088 12/068007
NA6ED AS THE WOROS'CREDIT UNION' MEANS MEMBERS 1ST FEDERAL CREDIT UNION, THE WORDS 'YOU.' YOUR' AND YOURS MEAN THOSE
LOAN AGREEMENT SECURITY AGREEMENT
at received ,h�ha
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en.'
Page 2 of 2
A ALL llen, TCou n Cou nty of land ofnPennsylvania�, of
towew Allan. Couty
bounded and described as followsd
sEGINNING at a point an the W*%tarly line e4 N■ponsit Lane which
point is 18o feet north of the nor-tbeastenly corner of Palmer
Drive and Neponsit Lane pxtended And at dividing line hrtween
Lot Nos 4 and 5 "F" on the hereinaft.r mentioned lot; thence along �
;aid dividing line north 69 dogrows 4 minutes w*xt 171.72 feat
to a point gat dividing line between Lot Nos. '4 and 7 Block "P"
on said Planl thence along said dividing line north 36 degrees
34 minutas Vast 28.27 40et to a point at dividing line between
Lot Nos. 3 and 4 stock "F"' on said P14nt thence along said dividing
line norh 64 degrees 38 W nutPs east 17'3.84 fast to a point on
a westerly line Qf Naponsit Lane &+orwsaid; thence along said
of l ine dissttancerof d irect i on an t r adius
Place
of 9193MN =NO
HAVING thereon erected premispp known in 18 Naponsit Line.
Being the same premises which Dorothy R. Gambler, et.al. by their deed dated September 9,
1991 and recorded in the Cumberland County Recorder of Deeds Office at Deed Book H -35,
Page 1082, granted and conveyed onto Thomas J. White and Connie R. White.
Being Tax Parcel No.: 13 -2S- 0022 -235
Exhibit "B"
02- 15 -'13 11 45 FROM -ABLE ABSTRACTS T -451 P0019/0026 F -942
Prepared By: Members 1st FCU
5000 Louise Drive
Mechardcsburg, PA 17055
When rcmorded mail to:
FIRS'TAlFIER1CAIY TITHE INSURANCE
L,C ADVANTAGE
1100 SUPE, J08 AVFNZIE, $UtTF 240
CLEVELAND, 01970 44114
ATTNr FT'11Z0
MORTGAGE r 3 4(.
Made 12/06/2007
Between
THOMAS r WHITE AND CONNIE R WHITE
(h ereinatier ca "Mortgagor
And
MEMBERS 1 FEDERAL CREDIT UNION (hereinafter called "Mortgagee'
Whereas, Ma fagor has executed and delivered to Mortgagee a cWain Mortgage Note (hereinafter
called the "Note'] of - even date berewith, payable to the order of - principai sum of
$ 30. 1.,� Q , lawfirt rn Oney of the United States oMeerica, and has provided therein
for payment of any additional moneys loaned or advanced tbermnder by Mortgagee, togetber with
interest thereon at the raze provided in the Note, in the manner and at the tunes 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 LOWER A1.1 ZU
Tt"1WNRt1FP County, Pennsylvania
SEE ATTACHED EXHIBIT "A
which currently has the address of IT
(Street]
8mn H3i1 Pennsylvania 17011
[City] Pennsylvania
Code]
AM N APB 2370880002
Page t of 4
Exhibit "C"
02- 15 -"13 11;45 FROM -ABLE ABSTRACTS T -451 P0020/0026 F -942
1'Wther with the buildi and improvements steeled thereon, the �pp�r�enances thereunto
belonging a� ngs the reversions, remaindgs, rents. issues and prollts ttaof.'
To Have and To Hold the same unto Mortgagee, its successors and assigns, forever.
Provided, However. That if Mortgagor Shan pay to Martpgee the aforesaid debt or Principal sum,
including additional looms or advances and all other sums payable by Mortgagor to �
and under the [elms of the Note, Welber with tntereat thtaepn, and shall Iuep each of the
and Other covOw ts, conditions and agreements hereinafter set forth, then this a 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 evidertee and this Mp�l�q a shall cover and be security for any
future loans or advances that ppr�aay he made by MV�to 1 a �ti ftw at any time or times hereafter and
intended by ModW�gor and Mortgagee to be so evidenced and secured, artd such loans and advances shall
be added to the prhxpal debt.
(2) From time to time until said debt and interest are fully paid, Mortgagor shall. (1) pay and
discharge, when and as the same shall become due and Able, all taxes, a4ssessrrrents. sewer and water
rents, and all other dMW and chines assessed or leviedom been to time by any lawful authority u on
any peat of the mortgaged premises and which shall or Wright have priority in lien or payment to the debt
secured hereby, (b) ay all ground rents reserved from the mort ed premises and pay and dise all
mechanics lien may be s wh ch flied against said premises and which shall or might have priority in7ien
or payment to the debt secured hereby, (c) and disch
irtcludi interest and �' � any documentary stamp or other tax,
nB 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 b Mo�agor and Mortgag as their respective interests may ap pear,
and (e) promptly submit to Morr"�agee evidence of the due and p unctual p
char�� vrded, however, thatZlsortg y payment of all the foregoing
the t'oregpg charges be paid in instaLrmeats to 14tnn$gg n are t sum sufficient to discharge
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and
substantial repair, as determined by Mort e. the purpose of ins Mortgagee shall have the right to enter upon the mortgaged remises at any reasonable hourTO pectIng the order, condition and repair
of the but7dpogs and improvements erected thereon.
Acct No AWD 237[1880002
?age 2 of 4
02- 15 -'13 11:45 FROM -ABLE ABSTRACTS T -451 P0021/0026 F -942
(4) In the evem M� neglects or refuses to the charges mentioned at (2) above, or falls to
maintain the buildings mrroveme 0 as afotesald, may do so, add the cost thered to the
P�Pil debt WaH d hetbby, and coIlect the same as a part o said principal debt.
m (5) Mortgagor covenants and agrees not to create, rear permit to accrue, upon 911 or any part of the
M euWged premises, any debt, Lien or charge which would be prior to, or on a parity with, the lien of this
°rtgege.
of the
prin or in pursttant�to the terms oof the Note, orriin Q in the payment of any installment of
other obIigativas of the Note Or this Mo a of tgagor of any
aa r r�atgge, the entire anpai bzta,tce of Mor pr�nctpal sum, additional
loans or ances and all other sums paid by M pursaamt to the terms of the Note or this
Mortgage, together with ttnpaId interest thereon, sha11 at the Option of Mao and without notice
become immediately due and payable. and forec)ostue proceedmp may be t
e and pro forthwith an this
Mo promoted to udgment, owca don and sale for the collection of the s9me, together with
Costs of suit rid an attorney's commission for collection of five percent (5%) of the total indebtedness or
$200, whtchever is the larger amount. Mo hereby forever waives and rely all errors in said
Proceedings, waives stay of execution, the rlgh 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 PrOPettY that now is or hereafter may be exempted by law.
(7) Upon ppaayment of all sums secured by this Mortgage, this Mores and the estate conveyed shall
terminate and ltecome void. After such and satisfy this Mort
occurrence Mortgagee shall cl�cFi a .
Mortgagor shall pay any recordation costs. M gag may charge Mortg r a fee for releasing (his
e
gage, but only if the fee is paid to a third � services rend and the charging of the fee is
perm tted under Applicable Law.
The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall
inure to, the respective parties hereto mid their respective heirs, executors. administrators, successors and
assigns. and if this Mortgage is eyed by more than one Party, the undertakV and liability of each
shaft be' joint and severa .
AM No _ AP81A 237 08t;0002
Pegg 3 Of 4
02- 15 -'13 11;46 FROM -ABLE ABSTRACTS T -451 P0022/0026 F -942
r ,
Witness the due execution hereof the day and year first above written.
J WHITE
CONNIE R WHITE
Commonwealth of Pennsylvania )
County of Cumberland ) ss.
On this, the 6th yof December 2007
Bever 1 R organ M' bye me,
personeily appeared
satisfactorily proven to me to be the persons) whose names) ' are subscrtbad to the within Mortgage, and
acknowled that hats he executed the same for the purposes therein contained.
In Witness Whereof,1 hereunto set my hand and official seal.
My commission expires:
Members 1rr Federal Credit Unton, Mortgagee within named, hereby certified that its restdcnce
is 5000 Louise Drive, Mechanicsburg, PA 17055.
sy
Aca No App1t, ?88M2
p8Q2 4 Of 4
GQM_W_ VWEALTH OF PENNSYLVANIA
Notarial Sesi
8" K, Morrgan, Notary pubk
CMWWon Cumtxrrbrtd county
E> rft July 7, 2008
Member, PannsynranIa AsspciaGon of Notaries
02- 15 -'13 11;46 FROM -ABLE ABSTRACTS T -451 P0023/0026 F -942
EXHIBIT "A"
LEGAL DESCRIPTION
A VANXL OF LUM SiTtMTED IN THE STATE 08 PXMMVANIA, COUNTY OF
CUR D, WITH A STIMT LOCKMON ADORES$ OF 18 NEPONSIT LN: CJU41P
HILL, PA 170117926 CURRENTLY OMW BY TBmdhz J WHXTX AND CONNIE R
WHITE RAVING A TAIL IDENTIFICATION NUH=R OF
2 5 - 0022 - 0235- 0000000 -13 Ahab F'ORTSER DRSCRIBED AS LOT 4 BLK F RE 7
PC 41 .
25 - 0 022 - 0235 - 0000000 - 13
18 NEPONSIT Lid; CAM HILL, PA 17011
237088 13 tp +� WHITE
35568618/f FIRST AmERYCgN LENDERS RDVMtAM
MORTORM
II116mill II�ItIIiMf fsld�lNll�
02- 15 -'13 11,46 FROM -ABLE ABSTRACTS T -451 P0024/0026 F -942
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE r
CARLISLE, PA 17013
717 - 240 -6370
Instrument Number - 200800534
Recorded On 117/2008 At 10;18:49 AM � Total Pages - 6
*
Instrument TYPe - MORTGAGE
brvoice Number -11975 User ID -1v BL
* Mortpgor - WHITE, THox4s J
* Mortgagee - MEMIIERS 1ST FEDERAL CR UN
" Customer - FERST AMERICAN
* F7 ES
STATE WR TAX $0.50 Certification Page
STATE JCS /ACCESS TO $10.00
JUSTI
R DO NOT DETACH
L>CORDING F1iES � $13.50
RECORDER OF DEEDS
AFrOROASLE HOUSrKe $11.50 This page is now hart
COUNTY ARCHIVES > $2.00 of this legal document.
ROD ARCHIVES FEE $3.00
TOTAi, PAID $40.50
I Certify this to be recorded
in Cumberland County PA
IZEGORDER O
- laforWtion denoted by an asterisk may cb*W during
the veriticstion prot"s and may not be rdtected on this page.
OOOFAT
(Rev.9 ON)
Date: _February 20, 2013
i
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends t
foreclose. Snecif c information about the nature of the dgf8 �1� t is nrocided in the atta ' aagg .
The HOMROWNERIS EMERGENCY MORTGAGE ASSISTANCE PROGRAM "'MAPI
maybe able to helnn to save your home, This Notice, exi?lains how the program works.
To see if HE1VIiAM can help. yqu must MEET WITH A CONSUM ER [`RFniT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NnTTCTi Take this Notice with yQu,
when you meet with the Counselinor Agency
The name, address and nhong number of C onsumer Credit C°i =gAgencies servin
County are listed at the end of his Noticg,, If you have any ,questions. _ you may call am
Pennsylvania Housing Finance gengy tall free at 1-8 342 2397 (Persons with impaired
hearing gan call 717) 78_ 0- 86).
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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCIbN INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRASTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
j PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTE CA.
i
i
Exhibit "D"
HOMEOWNER'S NAME(S): THOM J WHJTE
CONNIE R WHITE
PROPERTY ADDRESS: 18 NEPONSIT LANE
CAMP HILL, PA 17011
LOAN ACCT. NO.:
ORIGINAL LENDER: Members 1" Federal Qredit Union
CURRENT LENDERSERVICER: Members I" Federal Credit Union
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ETA SIB , . FOR FINA NCIAL ASSISTAN, CR
WHICH CAN SAV , YOUR HOME FROM FORFC I A)SURE 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 ELIGIBLE 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
• IF YOU MEET OTHER. ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
i
TEMPORARY STAY OF FORRC'i, OSURR -- 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 MAST OCCUR WITHIN THIRTY THREE Qj) DAYS OF THE DATE ()� F TIM
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 ". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE
CONSUMER CREDIT COTINSE AGENCIES — 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 gainst you for thirty (30) days after the date of this
meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county
in which the pro erty 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 immediatey of your intentions.
APPLICATION FOR MORTG SSISTANCE
.- .- _TtzA.�F t 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
i
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
1 TEMPORARY STAY OF FORECLOSURE ".
YOU HAVE THE RIGHT TO FILE A HEM—AP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE
APPLICATION WELL NOT PREVENT THE LENDER .FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE
j STOPPED.
Page 2 of 5
j
AGENCY ACTION __ 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 flied bankruptcy you can still apply for Emergency Mortgage Assistance.)
i
HOW TO CURE XQUR MQRTGAQE DEFAULT (Dring it un to datej
NATURE OF THE DEFAULT - - The MORTGAGE debt held by the above lender on your property located at:
18 NEPONSIT LANE
CAMP HILL. PA 17011
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:$118.52 for 6/3/2012, $242.75 for 713/2012, $242.75 for 8/3 /2012, $242.75 for 9/3/2012,
S242-7-5 for 10/3/2011.0,49-75 for 11/3/2012.$242-71 for 12/3/2012,$242.75 for 1/3 01 $ 4 75 fog /3 011
i
Other charges (explain /itemize):
i
TOTAL AMOUNT PAST DUE: _ $2.060.52
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ( not use if not applicable
HOVY_ TO ('L1R .
HE DRFAUIZ --You 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 $ 2.0 0.52
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must be made either b
en to: y cash cashier's check certified check or money order made payable and
j
Members l Federal Credit Union, ATTN• Laura Z
5000 Louise Drive _
Mecbaniesbur-a. 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
i
IF YOU DO NOT CURE ME DEFAU you do not cure the default. within THIRTY (30) DAYS of the date of
this Notice, th�endgr inLads In exercise oft rights to _a�lerate the mortgAgL 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 ulUn dour mariggged prop
IF THE MORTGAGE 19 FOR ,CLOSED 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 tender 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 yon cure the default within the THIRTY (;Q1 DAY period, yeti will
not be required to pay at orn v'R�feeR
OTHER IXNDFR REMED S -- The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortg
RIGHT TO CURT THE DEFAULT PRIOR 10 SHERIFF'S SALE -- If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, Estill have the right to cure the default and
prevent the sale at anv time up to one hour before the Sheriffs Sale You may do so by pgying the total amount then past
due,_glus any We or other charges then due reasonable Attorney's fees and costs connected with the foreclosure sale and
anv other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing n other
requirements under the mortgage 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.
ti
EARLIEST POSSIRLE SHER1FF SAL 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.
HOW TO CONTACT THE TINDERi
Name of Lender: Memb .rig 1 ` Federal Cre_d*t Unrnn
Address: 50001.o Drive
Mechnni sh urg, PA 17045 �+
Phone Number: (21 7179 134 n�(89M 283 -2328 Ext. 5134
Fax Number: (717) 795_52117
Contact Person: Laura Z
F,Mail Address: Arnmermanliamemhe.allQt_gra
EFFECT OF SHERIFF. SA ,r -- 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
Y OU MAY ALSO HAVF, 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.
CONS IM 11 CREDIT C012JERLING AGENC SERVING XQUR COUNTY
(Fill in a list gf all C umseling Agocles jUkd in Ann nd Y C. FOR THE CQUIVTY in which the prod rP � c
located using a i na - gages if necessary)
Certified Mail # 91 7199 9991 7031 1124 1293
I
I
i
I
i
i
I
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Page 5 of 5
YOU BJAY A . O RAVF, nIE RIGHT:
i
• 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,
CONSUMRR CREJU COUNSFT,ING AGENCIES FRVINC 'QUR COUNTY
{Fill in a list of all Counseling Agencies li led in Annendix C FOR COVNTY in which the =petU is
Located. using additional fiagg it necessa g).
Certified Mail # 917199 9991 7031 1124 1309
Page 5 of 5
(
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 02/19/2013 04 :29 PM
Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 -511 -2227 717- 232 -9757
Housing Alliance of York/Y Housing Resources Maranatha
290 West Market Street 43 Philadelphia Avenue
York, PA 17401 Waynesboro, PA 17268
717 - 855 -2752 717- 762 -3285
PathStone Corporation PathStone Corporation
1625 North Front St 450 Cleveland Ave
Harrisburg, PA 17102 Chambersburg, PA 17201
717- 234 -6616 717- 264 -5913
PA Interfaith Community Programs Inc PHFA
40 B High Street 211 North Front Street
Gettysburg, PA 17325 Harrisburg, PA 17110
717- 334 -1518 717- 780 -3940 800 -342 -2397
Servicemembers Civil U.S. Department of Housing MB Approval No, 2502 -0585
Relief Act and .Urban Development (exp 4/3 012 007)
Notice Disclosure Office of Housing
Legal Rights find Protections Under the SCRA
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 Mny Re Entitled to Tegal Protections Under the SCRA?
+ Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard,
and active service National Guard; I
+ Active service members of the commissioned corps of the National Oceanic and
Atmospheric Administration;
+ Active service members of the commissioned corps of the Public Health Service; I
+ 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 a al Protections vicememhers Entitled To h 4
_fig � Arir�r �ln+c� �.� RA? �
I
+ 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�n 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.
Row Does A Servocemember or D pendent Regliest HeljefUnder the SCRA
+ 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" Federal Credit Union, ATTN:
Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The
phone number is toll free (800) 283 -2328.
ljow -- Doev _S.&!'yicemeem eK or Dependent Obtain information About th RA?
+ The U. S. Department of Defense's information resource is "Military OneSource ".
Website: http: //www.militaryonesource eom
The toll. free telephone number for Military OneSource are:
o From the United States: 1- 800 -342 -9647
j o From outside the United States (with applicable access code): 800- 3429 -6477
i o International Collect (through long distance operator): 1484 -530 -5908
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+ Servicemembers slid 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
httl2:/Aegalassis
form HUD -02070
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3/25/2013
Karl M. Ledebohm, Esquire J
P.O. Box 173
New Cumberland, PA 17070 -0173
(717)938 -6929
MEMBERS 1 ST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
�j
Vs. NO.:
THOMAS J. WHITE and
CONNIE R. WHITE CIVIL ACTION — LAW
DEFENDANTS 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 a court- supervised conciliation
conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for
a conciliation conference. First, within twenty (20) days of your receipt of this notice,
you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800)
822 -5288 extension 2510 and request appointment of a legal representative at no charge
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 prepared on your behalf. If you and
your legal representative complete a financial worksheet in the format attached hereto,
the legal representative will prepare and file a Request for Conciliation Conference with
the Court, which must be filed with the Court within sixty (60) days of the service upon
you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an
attempt to work out reasonable arrangements with your lender before the mortgage
foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the
following steps to be eligible for 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 (60) days of the service upon you of the foreclosure complaint. If
you do so and a conciliation conference is scheduled, you will have an opportunity to
meet with a representative of your lender in an attempt to work out reasonable
arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND
TAKE THE STEPS REQUIRED BY THIS NOTICE.
THIS PROGRAM IS FREE.
Res 1 u tted,
Date: April 1, 2013
azl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New 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: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
%a Cell: Other:
Email:
# of people in household: How long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default.
Is the loan in Bankruptcy? Yes ❑ No ❑
i
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 #l: Model: Year:
Amount owed:.. Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description shot wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees _
Auto Insurance Med. not covered
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Mone
Da / Child Ca re/Tuit. Other Expenses-
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
t Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
I/We, , authorize the above
named to use /refer this information to my lender /servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that I /we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
V Proof of income
V Past 2 bank statements
Proof of any expected income for the last 45 days
Y Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the market)
3
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson I L
Sheriff
vxr ME PROT
Jody S Smith 2013 APR IS PM 3
Chief Deputy 06
Richard W Stewart CUMBERLAUD cOUNT
MICE OF THE SNERIFP
Solicitor PENNSYLVANIA
Members 1 st Federal Credit Union Case Number
vs. 2013-1729
Thomas J. White(et al.)
SHERIFF'S RETURN OF SERVICE
04/08/2013 06:16 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Connie
R. White at 18 Neponsit Lane, Lower Allen Township, Camp Hill, PA 17011.
RYAN BURGETT, DE
04/10/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit:Occupant,but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion
Program and Complaint in Mortgage Foreclosure as"Not Found"at 18 Neponsit Lane, Lower Allen
Township, Camp Hill, PA 17011. There were no occupants other than the defendants Thomas&Connie
Mite.
04/10/2013 12:58 PM-Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally"handing a true copy to a person representing themselves to be the Defendant,to wit:
Thomas J.White at 18 Neponsit Lane, Lower Allen Township, Camp Hill, PA 17011.
(AmalAa
AMANDA COBAUOR 015PUTY C—S
SHERIFF COST: $69.46 SO ANSWERS,
100*111,
April 11, 2013 RONW R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoff Inc,
i'HE PRO T HONO
2013 AUG 28 pHp. .C15
CUMBERLAND COUNTY
PENNSYLVA141A
Karl M.Ledebohm,Esquire
P.O.Box 173
New Cumberland,PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
NO. 13-1729
Vs.
THOMAS J. WHITE and CIVIL ACTION—LAW
CONNIE R. WHITE
DEFENDANTS MORTGAGE FORECLOSURE
PRAECIPE TO SETTLE,DISCONTINUE AND END
To the Prothonotary:
Please mark the docket in the above captioned case settled, discontinued
and ended without prejudice.
Respect ly submitted,
Date: August 26, 2013
E-
arl m, Esquire
D#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 ST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
NO. 13-1729
Vs.
THOMAS J. WHITE and CIVIL ACTION—LAW
CONNIE R. WHITE :
DEFENDANTS MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm,Esquire,hereby certify that on the 27th day of August,
2013, I served a true and correct copy of the foregoing Praecipe to Settle, Discontinue
and End upon the defendants by first class mail,postage prepaid, addressed as follows:
Thomas J. White
Connie R. White
18 Neponsit Lane
Camp Hill, PA 17011
R Pfor mitte ,
Date: August 27, 2013
Karl m, Esq.
Attontiff
Supreme Court ID#: 5 9012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929