Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
13-2121
5 Supreme Coyer ,ennsylvania Collt' I� 3I1Imo pleas For Prothonotary Use Only: 11 C 'per t _ Docket No: erlarid f . County 161 lerm l ra The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required bylaw or rules of court. Commencement of Action: S 0 Complaint Writ of Summons Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Freedom Mortgage Corporation Russell and Michele Franks T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? Yes X' No (check one) ®outside arbitration limits O N Is this a Class Action Suit? 0 Yes 0 No Is this an MDJAppeal? E3 Yes El No A Name of Plaintiff/Appellant's Attorney: Kevin P. Diskin, Esq. ® Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) 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 [3 Buyer Plaintiff Administrative Agencies 12 Malicious Prosecution 13 Debt Collection:Credit Card Board of Assessment 0 Motor Vehicle 0 Debt Collection:Other Board of Elections Nuisance Dept.of Transportation El Premises Liability [3 Statutory Appeal:Other S Product Liability(does not include E mass tort) 13 Employment Dispute: 0 Slander/Libel/Defamation Discrimination C rA Other: ® Employment Dispute:Other El Zoning Board T n Other: I 0 Other: O MASS TORT ® Asbestos N [3 Tobacco ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS M Toxic Waste rl Other: ® Ejectment [3 Common Law/Statutory Arbitration B 0 Eminent Domain/Condemnation [] Declaratory Judgment ® Ground Rent ®Mandamus 1 13 Landlord/Tenant Dispute ® Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure:Commercial ®Quo Warranto Dental ® Partition 0 Replevin 0 Legal Quiet Title ®Other: ® Medical ®x Other: Other Professional: Mortgage Foreclosure: Non-owner occupied Updated 1/1/2011 STEVEN K.EISENBERG,ESQUIRE(75736) M .�. KEVIN P.DISKIN,ESQUIRE(86727) m - r'i-- LESLIE J.RASE,ESQUIRE(8365) ) 7:0 M CHRISTINA C.VIOLA,ESQUIRE(308909) <> STERN&EISENBERG,PC r > THE PAVILION 'n 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND,PA COUNTY Freedom Mortgage Corporation 907 Pleasant Valley Ave., Ste. 3 Mount Laurel,N3 08054 V. Civil Action Number: 13 -al oll C-1v'11 10rm Russell W. Franks, Sr. 198 SE Pearl Terrace Lake City, FL 32025-1865 COMPLAINT IN Michele R. Franks a/k/a Michele R. I. Franks MORTGAGE FORECLOSURE 591 Geneva Drive, 19 Mechanicsburg, PA 17055 Defendant(s) CIVIL ACTION-MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. -�I03.75 PD fl--IrY 04 W718 0 ,28q413 YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. f you and a judgment may be entered against you persona. Sea avisado que si usted no se by the court without further notice for any money defiende, la corte tomara medidas y puede claimed in the complaint or for any other claim or continuar la demanda en contra suya sin relief requested by the plaintiff. You may lose previo aviso o notificacion. Ademas, la money or property or other rights important to corte puede decidir a favor del demandante y you. requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede YOU SHOULD TAKE THIS PAPER TO A perder dinero o sus propiedades u otros LAWYER AT ONCE. IF YOU DO NOT HAVE derechos importantes para usted. A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET Lleva esta demanda a un abogado FORTH BELOW TO FIND OUT WHERE YOU inmediatamente. Si no tiene abogado o si CAN GET LEGAL HELP. THIS OFFICE CAN no tiene el dinero suficiente de pagar tal PROVIDE YOU WITH INFORMATION servicio, vaya en persona o flame por ABOUT HIRING A LAWYER. telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar IF YOU CANNOT AFFORD TO HIRE A donde se puede conseguir asistencia legal. 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. Lawyer Referral and Information Service (Asociacion de Licenciados Servicio de Referencia e Informacion Legal) NOTICE PURSUANT TO FAIR DEBTOR COLLECTION PRACTICE ACT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter,this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A DISCHARGE IN BANKRUPTCY (AFTER ENTERING INTO THE RELEVANT MORTGAGE NOTE AND MORTGAGE AND HAVE NOT REAFFIRMED THE DEBT) THEN THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE MORTGAGE/LIEN AGAINST REAL PROPERTY. STEVEN K.EISENBERG,ESQUIRE(75736) KEVIN P.DISKIN,ESQUIRE(86727) LESLIE J.RASE,EsQum(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) STERN&EISENBERG,PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND,PA COUNTY Freedom Mortgage Corporation 907 Pleasant Valley Ave., Ste. 3 Mount Laurel,NJ 08054 V. Civil Action Number: Russell W. Franks, Sr. 198 SE Pearl Terrace Lake City, FL 32025-1865 - COMPLAINT IN Michele R. Franks a/k/a Michele R. I. Franks MORTGAGE FORECLOSURE 591 Geneva Drive, 19 Mechanicsburg, PA 17055 Defendant(s) COMPLAINT CIVIL ACTION-MORTGAGE FORECLOSURE 1. Plaintiff is Freedom Mortgage Corporation(hereinafter referred to as "Freedom Mortgage Corporation")with offices located at 907 Pleasant Valley Ave., Ste. 3, Mount Laurel,NJ 08054. 2. Defendant(s) are Russell W. Franks, Sr., adult individual(s) with a last-known address of 198 SE Pearl Terrace, Lake City, FL 32025-1865591 3. Defendant(s)Michele R. Franks a/k/a Michele R. I. Franks, adult individual(s)with a last- known address of 591 Geneva Drive, 19,Mechanicsburg,PA 17055. 4. Under date of 12/06/2010, defendants executed and delivered to MERS" as nominee for Freedom Mortgage Corporation a mortgage upon the property 591 Geneva Drive, 19 , Mechanicsburg, PA (the "Property")to secure the payment of the sum of$110,589.00 . The said mortgage is recorded in the Office for the Recording of Deeds in and for Cumberland, PA County on 12/22/2010 at Instrument#201038042 and is incorporated herein by reference as though set forth at length herein. A copy of the note,mortgage and legal description of the Property is attached hereto and made a part hereof as Exhibit "A". 5. An assignment transferring the mortgage originally with"MERS"as nominee for Freedom Mortgage Corporation(Originating Lender)to Freedom Mortgage Corporation, was prepared and is in the process of being recorded in the Office of the Recorder of Deeds of Cumberland, PA County, Pennsylvania. Said Defendant(s) are the real owners of Property 591 Geneva Drive, 19, Mechanicsburg, PA 17055. 6. The loan is an FHA loan and as such is not subject to the requirement of Pennsylvania law with regard to pre-foreclosure notice. Rather a notice of intent as otherwise required was sent to the defendants and no response was made in the appropriate period of time. A true and correct copy of the foresaid notice is attached hereto and made a part hereof as Exhibit "C". Also attached as Exhibit"D"is a copy of the FHA/HUD pamphlet setting forth borrowers' options in the event of foreclosure. 7. The said loan is in default as a result of the failure to pay the monthly installments of $777.74 due on May 1, 2012 and on the same day of each month thereafter. 8. The following is due on the loan: PRINCIPAL BALANCE.......................................................$108,405.98 INTEREST accrued thru 04/08/2013 of ...............................$5,213.53 Interest after 04/08/2013 shall accrue at the per diem rate of$13.85.) LATE CHARGES accrued thru 04/08/2013 of.....................$63.08 Late charges after 04/08/2013 shall accrue at the monthly rate of$31.11.) ESCROW ADVANCES........................................................$1,432.96 RECOVERABLE BALANCE..............................................$1,182.30 COSTS...................................................................................$300.00 ATTORNEY'S FEE..............................................................$5,420.00 TOTAL..................................................................................$122,017.85 Attorney fees are allowed in conformity with the mortgage documents and Pennsylvania law, and may be requested with judgment and may be collected in the event of a third party purchaser at Sheriffs Sale. If the mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually performed. COULD NOT USE ANTICIPATED INTEREST THROUGH 5/1/2013. AS OF APRIL 8TH, 2013 INTEREST IS AT $5,213.53, CALCULATED AS FOLLOWS: 30-8 (April) =22 + 1 (May) =23 days 23 days * $13.85 per diem =$318.55 $5,532.08 (interest thru 5/1) - $318.55 = $5,213.53 WHEREFORE, Plaintiff, Freedom Mortgage Corporation requests this Court to enter judgment, IN REM, for foreclosure of the mortgaged property for the sum of$108,405.98 plus interest thereon of$5,213.53 plus $13.85 per day from 04/08/2013 until judgment is paid in full, Iate charges of $63.08, plus late charges of $31.11 per month from 04/08/2013 until judgment is paid in full, escrow advances of $1,432.96, recoverable balance of 1,182.30, costs of$300.00, attorney's fees of $5,420.00 and all other amounts set forth above, less any suspense as set forth above, together with record costs and any other amounts that accrue over the course of the instant matter and to which Plaintiff is entitled to recover. STERN&EISENBERG,PC BY: STEVEN K. EISENBERG, ESQUIRE IwKEVIN P.DISKIN, ESQUIRE ❑ JACQUELINE F. McNALLY,ESQUIRE ❑ LESLIE J. RASE,ESQUIRE ❑ LEN M. GARZA, ESQUIRE ❑ CHRISTINA C.VIOLA,ESQUIRE Attorney for Plaintiff Date: April 8,2013 VERIFICATION I,the undersigned, an authorized representative of Freedom Mortgage Corporation,by LoanCare, A Division of FNF Servicing, Inc. as Attorney in fact Under Limited Power of Attorney ("Freedom Mortgage Corporation"), am authorized to make this verification on behalf of Plaintiff and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge,information and belief. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant,or to invite a public servant's reliance upon a written statement or instrument,which I do not believe to be true or which I know to be false. Freedom Mortgage Corporation,By LoanCare, Date. a Division of FNF Servicing,Inc.,as attorney in fact der a limited power of attorney N wONG Title: Vice President MIN 1000730-008404388.4-.0. VERS Telephone: (888) 679-6377 NOTE FHA Case Na. SMtC Of Pennsylvania 946-037 6148-734 December 6, '7b20 Mate) 591 Geneva Dr, 19 Mechanicsburg,. ?A 17055 ['-perry Add-rO 1.PARTIES "Borrower"means each person signing it the end of this Note,and the person's successors and assigns. "Lender"means Freedom Mortgage Corporation and its successors and.assignS. ?—BORROWER! PROMISE TO PA'S;XNTBR1 ST In return for a loan received from Lender;Borrower promises to pay the principal sum of One Hundred Ten Thousand Five Hundred Eighty Nini:'and 00/100 Dollars(U.S.S.11{),.589.40 ),plus interest,.to the order of Lender.interest will be charged on unpaid principal, from the date-of disbursement,of the loan proceeds by Tender,at the rate of Four and Three—Quarters percent( 2.750 %)per year until the fuU amount of.principal has been paid. 3.PROMISE TO PAY SECURED Borrmver's promise to pay is secured by a mortgage,deed of trust or similar security instrument that Is dated the same date as this Note and called the"Security instrument."The Security itutrument.prgtects the Lender from losses which might result if Borrower defaults under this Note. 4.MANNER OF PAYN93NT (A) Time $orrower shall make a payment of principal and interest to Fender on the'fast day of each month beginning on €'ebxvary 1, . 2,011 .Any principal and interest remaining on the BN day of January 2041 'will be due on that date,which is called the"Maturity Date.' (B) .Place Paymentshallbemadeat P.O. sox soG6, virgiria Beach, VA 23450-8668 or at such place as lender may designate in writing by notice to Borrower. (C) Aruount Each monthly payment of principal and interest will be in the amount of U.S.5 . 576a89 This amount, will he part of a larger monthly payment required by the Security Instrument,,that shall be applied to.principal, interest and other items in the order described in the Security Instrument. (D) Allmtge to this Note for payment.adjustments .If an allonge providing for payment adjustments is'extcuted by Borrower together.kith this Nate,the coveaant-t of the allonge shall he incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this.Note.lCheck applicable box) ❑Graduated Payment Allonge []Growing Equity.Ai)onge Dotim[specify), S.BORROWER'S RIGHT TO PREPAY Borrower has the right to pay,the debt evidenced;by this Note,in whole or in part,without charge or-penalty,on the first day.of any month,Lender shalt accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to(he extent required by Lender and permitted by regulations of the Secretary.If Borrower.makesa partial prepayment,there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in .kaiting to those changes. 71819397 0084043884' FHAPennsytvanin Rut]RateNote 10M Wolters Kknvei finanetai Services VMP 9-1 RPA)40707) 'J � A! b EXHIBIT 0064n43d84 b.'BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments' If Fender has not received the fall monthly payment required by the Security Instrument, is described in Paragraph 4(C)of this Note,by(be,-end of fifteen calendar days:after.the.paymeni is due, Lender may collect a late charge it,the amount. of Four and percent:.(. 45LOM the overdue amount of each payment. +(13) Defauh. If Borrower defaults.by failing to pay in full aiay monthly payment.then Lender may,except as limited by regulations, of the Secretary in the rase of payment defaults,requite immediate payment in full of the principal balance remaining due arid, all accrued interest. Lender may choose not.to exercise this option without waiving its rights in'the event of any subsequent default.In many circumstances regulations issued by the Seereaairy,will limit Lender's rights to require immediate paynt en!in full in the case of payment.defaults.This Note floes not.authorize acceleration when not permitted by HUD.it gulations.As used in this Note;"Secretary'°means the Secretary of Housing and.Urban Development or his or her designee (C) Payment of Costs and Expenses If Lender has required,immediate payment fn full,as described above,lender may require Borrower to pay casts and expenses: reasonable and customary attorneys'fees€or enforcing this Note to the extent not prohibited by applicable law.%Such fees and costs shall bear interest from file date of disbursement at the same rate as the principal of this Note. 7.WAIVERS Borrower.and auk other person who has obligations under.this Mote waive the rights of presentment and donee of dishonor."Presentment means the right to require Lender to demand payment of amounts due."Notice of dishonor'means the right to require Lender to give notice to other persons that amounts due have not been,paid.. 8.GIVING OF NOTICES Unless applicable law requires a different method,any notice ihat.must be given to Botrower under this Note will be given by delivering it or by mailing it by fist class mail 10,Borrower at the property address above or at a different address if Bormwer has given Lender a notice of Borrower's different address.. Any notice.that most be given to Lender under this Note will be:g-Wen by first class mail to Lender at the address stated in Paragraph 4(B)or at a different address if Borrower is given a notice of tha£different address, 4.OBLIGATIONS OF PERSONS TINDER THIS NOTE If more than one person signs this Note,each person is fully and personally obligated to keep all of the promises made in thls'Note,including the promise to pay the full arnount owed.Any Person who Is a guarantor,surety or endorser of this Note ii also obligated:to do these things.Any person who takes over these obligations,including the obligations of a guarantor,safety or endorser of this Note,is also obligated to keep all of the promises made in this Note.t=ender may enforce Its righis under this Note against each person Individually or eWlost all signatories together. Any one person signing this Note maybe required to Pay all of the amounts owed under this Note. This is a-contract under sea]and may he'en€arced:under 42 Pal.C;S.Seaton 5599(b). BY SIGNING BELOW,Borrower accepts and agrees to the terms and covenants contained in this Note. ,T ° * - (Seali�� (Seal. usse W. t* r trz tt. r -1Sorror�or FrAWr 5 -Bortowtr (Seal) (Sol) -t3oanwer &ormwtr pay to Fha.arder of rh7hatitremom this_nav_oL., . _20,,,,. (Seal) (Seal) Frt#wom Mortgage corporawn --Borrovmr (Seal) Seal ------°�,*teY£r-fi'ticftilenr� 5eai (Seal) Froeldent/ChIal exemove officer Borrower tiattower 7i819397 VMP6.1KPA)(ww) yrzocs MM.'.. ` 911 i. s mm i. .7yit lPlllfi ._ __. _ r_..,. o l i► _.,._.. RECORD AND RETURN TO EAST COAST ABSTRACT 36 E VINCENT CIRCLE IVYk.AND, PA 18974 215-674-8788 l Prepared By: OOOJV8 � Freedom Mortgage Corporation 907 Pleasant Valley Av Ste 3 Mount Laurel, NJ 08054 Relw&lo: Freedom Mortgage Corporation, Attn: Final Documents P.O. Box 8001 Fishers, IN 46038-8001 -usI let Parcel Number: 42-24-0791-163.g05-7-30 Premises: 591 Geneva Dr 19 Mechanicsburg, PA 17055 [Spaoc Above This Line For Recording Data] Commonwealth of Pennsylvania FHA Case r�o.' MORTGAGE 446-0379149-734 Refinance MIN 1000730-0084043884-0 THIS MORTGAGE("Security Instrument") is given on December 6, 2010 The Mortgagor is Russell W. Franks Sr and Michele R. Franks. ("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. ("MERS"), (solely as nominee for Lender, as hereinafter defined, and Lender's successors and assigns), as mortgagee. MERS is organized and existing under the laws of Delaware,and has an address and telephone number of P.O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS. Freedom Mortgage Corporation ("Lender")is organized and existing under the laws of The State of New Jersey ,and has an address of 907 Pleasant Valley Av Ste 3, Mount Laurel, NJ 08054 FHA Pmnsylvania Mortgage with MERS-4/96 0084043884 Wolters Kluwer Financial Services P® p�a71819398 i COMMITMENT SCHEDULE'C File Nu b.,6r: EC-1.8998 ALL THAT CERTAIN Unit, being Unit Nis. 591-19 {the "Unit"}, of Sunguild III, a:Condominium Iocated in UPPER ALLEN TOWNSHIP, County of'CUMBERLAND, 'Commonweaith of PENNSYLVANIA, which Unit is designated in the Declaration of Sunguild III,.a Condominium(the".Declaration of Condominium")and Declaration flats and Plans as recorded in the Recorder's Office of Cumberland County in Misc.Book 357,Page 20, and in Right of Way Plan Book 9, Page 24;as amended in Misc.Book 362, Page 1111, and Plan Book 57, Page 132 and as fii Cher amended in Misc.Book 365 :Page 993 and_Plan Book 58,Page 81. TOGETHER with an undivided 1.9061% interest in Common Elements as more particularly set forth in;the aforesaid Declaration of Condominium and Declaration Plats and Plans,as amended aforesaid.. � TOGETHER with the right to use any limited common elements applicable to the:Unit being conveyed herein; pursuant to the Declaration of Condominium and Declaration Plats and Plans,as amended. BEING THE SAME PREMISES which MICHAEL D.HENNING.and LISA.L.HENNING,husband and wife by Indenture bearing the date of February 16,2001 and recorded in the Office of the Recorder of_Deeds, in and for the County of Cumberland,COMMONWEALTIH OF PENNSYLVANIA on February 21,2001 in Book.239 Page: 926 granted and conveyed unto RUSSELL W. FRANKS, SR, and MICHELE R. FRANKS, their Heirs and Assigns, in fee= Parcel No:-42-24-0791-163.US91-19 EAST COAST ABSMACr 235.574-8788: RESIDENCE , Borrower owes Lender the principal sum of One Hundred Ten Thousand Five Hundred Eighty Nine and 00/100 Dollars (U.S. $ 110,58 9.00 ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on January 1, 2041 .This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals,extensions and modifications of the Note: (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns)and to the successors and assigns of MERS,the following described property located in Cumberland County, Pennsylvania: SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF f which has the address of 591 Geneva Dr, 19 (Street] Mechanicsburg [city], Pennsylvania 17055 [Zip Code] ("Property Address"); TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument, All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument; but, if necessary to comply with law or custom, MERS, (as nominee for Lender and Lender's successors and assigns), has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. 00 9043884 71819398 - VMP®-4N(PA)twos).os Page 2 of 10 Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property. (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"). or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or(ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et seq, and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary,and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paragraphs 1 and 2 shall be applied by Lender as follows: . First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; ourth, to amortization of the principal of the Note;and Fifth, to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in 0�0fj8440043884 71819398 tmc�aeSJr`�" VMP®-4N(PA)(0708).01 Page 3 of 10 the amounts and for the periods that Lender requires.Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to bender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3,and then to prepayment of principal, or(b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required tv pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of.foreclosure of this Security Instrument or other transfer of title to the Property that M extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue, to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances_ Borrower shall not commit waste or destroy; damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or Inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold. Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender"shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the. amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 0084043884 71819398 k�cue f VNIP 8-4N(PA){0708}41 Pa*A of 10 ° 7. Charges to Borrower and Protection of Lender's Rights in the Property, Borrower shall pay all. governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower falls to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes,hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement,at the Note rate, and at the option of Lender,shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of payment defaults, require immediate payment in full of all sums secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment,or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn-St, Germain Depository Institutions Act of 1982, 12 U.S.C. 1701]-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if- (I) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property,is sold or otherwise transferred (other(ban by devise or descent),and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (c)No Waiver. If circumstances occur that would permit Lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to subsequent events. t708 3889 71819398 IrAia WZ VMP 0.4N(PA)(wos).ci Page s of i0 x (d) Regulations of HUD Secretary. In many circumstances regulations Issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e)Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary, 14. Reinstatement, Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument. foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower,subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 0084043884 71819398 Wtia� VMP*4 N(PA)ro7aei o1 Page 6 of to i i 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law. such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each 0084043884 71819398 �nitiair VMP04N(PA)to7ost.oi ease 7 or 10 i tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3751 et seq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mortgage. if any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property,this Security Instrument shall be a purchase money mortgage. 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security instrument as if the rider(s) were a part of this Security Instrument. (Check applicable box(es)J. Q Condominium Rider ❑Growing Equity Rider ED Other[specify] Q Planned Unit Development Rider ED Graduated Payment Rider 00 4043884 71819398 � � VMP8Z4N{PA)toioe).ot Pagesorio _ __ __! _ This is a contract under seal and may be enforced under 42 PA. C.S. Section 5529(b). BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument and in any rider(s)executed by Borrower and recorded with it. Witnesses: (seal) Russell W. Franks, Sr. -Borrower � � (Seal) Nichel . � Fra -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower z 71819398 —0084043884_y VMP 8-4N(PA)t0708t.01 Page 9 of 10 COMMONWEALTH OF'PENNSYLVANItt, (_.(. yj" _rt,Lt;/tQt...County ss: On this, (p"f 1 day of i>&C- before me, the undersigned officer, personally appeared, rlk" ed u). r s 1�',tI<!tV� -knewn4G-me-(or satisfaclorily proven) to be the Verson(s) whose name(s) Aare subscribed to.4he.within instrument and acknowledged that-he{ehelthey executed-the same for the purposes herein contained. IN WITNESS WHEREOF,,I hereunto set my hand and oCfieial seal' My Commission Expires::l).3.L1-�2D! V _ I ;NOTARIAL SEAL MARY K POTTER Notary Public ANTRIM iwP FRANKLlN,COUNTY My Commission Expires.Mdi:14, 2011 Tide of Officer CertiScate of Psid.eW I, do.hereby certify that the correct ad ess of the in-named,Mort a'ee'is P.O. Box:2026 Flint MI:48501-2 2 g8 06. Witness my hand this day of rr Agent of Mortgagee 0084043864 7:1.1119 3 9 8' initials, VMP:(0-4N(PA)toioslpi i,60 16of 10' CONDOMINIUM RIDER 008404388.4 FHA Case No. 446-0379149-734 THIS CONDOMINIUM RIDER is made this 6th .day of December; 2010 , :and is incorporated into and shall be deemed to amend and supplement the Mortgage, Deed of Trust or Security Deed ("Security Instrument") of the same date given by the undersigned ("Borrower".).to secure Borrower's Note ("Note") to Freedom Mortgage Corporation ("Lender") of the same date and covering the Property described in the Security Instrument and located at: 591 Geneva Dr, 19 Mechanicsburg, PA 17055, [Property Address] The Property includes.a unit in, together. with an undivided interest in the common elements of, a condominium project known as: Sunguild III: [Name of Condominium Project] ("Condominium Project"). If the owners association or other entity which acts for the Condominium Project ("Owners Association") holds title to property for the benefit or use of its members or shareholders, the Property also includes Borrower's interest in the Owners Association and the uses, proceeds and benefits of Borrower's interest. CONDOMINIUM COVENANTS. in addition to the covenants and agreements made in the Security Instrument, Borrower and Lender further covenant and agree as follows: A. So long as the Owners Association maintains with a generally, accepted insurance carrier, a "master" or "blanket" policy insuring all property subject to the condominium documents, including all improvements now existing or hereafter erected on the Property, and such policy is satisfactory to Lender and provides insurance coverage. in the amounts, for the periods, and against the hazards Lender requires, including fire and other hazards included within .the term; "extended 71819399 .FHA Multistate Condominium Feder- 14195 Wolters Kluwer Financial Services 1/MPOv86U (0402).01 1 1111111 Ill III 111111 III 1111118 Page 1 of 3 Initials: 1 v coverage," and loss by flood, to the extent required by the Secretary, then: (i) Lender waives the provision in Paragraph 2 of this Security Instrument for the monthly payment to Lender of one-twelfth of the yearly premium installments for hazard insurance on the Property, and (ii) Borrower's obligation under Paragraph 4 of this Security Instrument to maintain hazard insurance coverage on the Property is deemed satisfied to the extent that the required coverage is provided by the Owners Association policy. Borrower shall give Lender prompt notice of any lapse in required hazard insurance coverage and of any loss occurring from a hazard. In the event of a distribution of hazard insurance proceeds in lieu of restoration or repair following a loss to the Property, whether to the condominium unit or to the common elements, any proceeds payable to Borrower are hereby assigned and shall be paid to Lender for application to the sums secured by this Security Instrument, with any excess paid to the entity legally entitled thereto. B. Borrower promises to pay all dues and assessments imposed pursuant to the legal instruments creating and governing the Condominium Project. C. If Borrower does not pay condominium dues and assessments when due, then Lender may pay them. Any amounts disbursed by Lender under this Paragraph C shall become additional debt of Borrower secured by the Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 71819399 884 VMPO-586U (0402).01 Page 2 of 3 i . I BY SIGNING BELOW,, Borrower accepts and agrees.to the erms and provisions contained in this Condominium Ride (Seal) (Seat) Russell W. Frarilcs,, Sr. Borrower Michele Fran -Borrower (Seal) (Seal) Borrower -Borrower ;I (Seal) (Seal). Borrower -Borrower (Seal) (Seal) Borrower Borrower 71819399 008404.3884 VMP®-,586U (0402):01 Page,3 of 3 - I ROBERT P. ZIEGLER ' RECORDER OF DEEDS �. CUMBERLAND COUNTY t �'= ! 1 COURTHOUSE SQUARE ~ CARLISLE, PA 17013 _ a 717-240-6370 ' Instrument Number-201038042 Recorded On 12/22/2010 At 11:44:22 AM Total Pages- 15 *Instrument Type-MORTGAGE Invoice Number-79112 User ID-JM •Mortgagor-FRANKS,RUSSELL W SR •Mortgagee-MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC •Customer-EAST COAST ABSTRACT *FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $31.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 This page is now part FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $82.00 I Certify this to be recorded in Cumberland County PA oV G°'�►e '� e9 RECORDER O D EDS r�ao *-Information denoted by an asterisk may change during the verification process and may not be reflected on this page. OWNS Ill llllllllilllllllllll 11111 When Recorded Return To: DOCUMENT CONTROL DEPARTMENT LOANCARE,A DIVISION OF FNF SERVICING, INC. PO Box 8068 Virginia Beach,VA 23450 Parcel No.42-24-0791-163.U591-19 CORPORATE ASSIGNMENT OF MORTGAGE Cumberland, Pennsylvania SELLER'S SERVICING#:5785753 "FRANKS" MERS#: 1000730-0084043884-0 SIS#:1-888-679-6377 Date of Assignment; March 21st, 2013 Assignor: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE FOR FREEDOM MORTGAGE CORPORATION, ITS SUCCESSORS AND/OR ASSIGNS Assignee: FREEDOM MORTGAGE CORPORATION I hereby certify the precise address of the within named Assignor is P.O. BOX 2026, FLINT, MI 48501. 1 hereby certify the precise address of the within named Assignee is 907 PLEASANT VALLEY AV, SUITE 3, MOUNT LAUREL, NJ 08054. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC is at 1901 E Voorhees Street, Suite C, Danville, IL 61834, P.O. BOX 2026, FLINT, MI 48501-2026 Executed By: RUSSELL W. FRANKS SR AND MICHELE R. FRANKS To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE FOR FREEDOM MORTGAGE CORPORATION, ITS SUCCESSORS AND/OR ASSIGNS Date of Mortgage: 12/06/2010 Recorded: 12/22/2010 as Instrument/Document: 201038042 In the County of Cumberland, State of Pennsylvania. 591 GENEVA DR, 19, MECHANICSBURG, PA 17055 in the Township of UPPER ALLEN I do certify that A precise addr s �NJ08054 GAGE CORPORATION is 907 PLEASANT VALLEY AV, S ! 3, MO Attested By: KNOW ALL MEN BY E E PRESENTS, that for good and valuable consideration, the receipt and sufficiency of which is he y acknowledged, the said Assignor hereby assigns unto the above-named Assignee, the said Mortgage having an original principal sum of$110,589.00 with interest, secured thereby,with all moneys now owing or that may hereafter become due or owing in respect thereof,and the full benefit of all the powers and of all the covenants and provisos therein contained, and the said assignor hereby grants and conveys unto the said assignee,the assignor's beneficial interest under the Security Instrument. TO HAVE AND TO HOLD the said Security Instrument, and the said property unto the said assignee *WD*WDLCSV*03/21/2013 04:16:14 PM*LCSV01LCSVA000000000000000087172*PACUMBE* 5785753 PASTATE_MORT ASSIGN ASSN*TH*THLCSV* EXHIBIT CORPORATE ASSIGNMENT OF MORTGAGE Page 2 of 2 forever, subject to the terms contained in said Security Instrument, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE FOR FREEDOM MOR CORD ATION, ITS SUCCESSORS AND/OR ASSIGNS On '( By: yM ,—t .! NE Nf�ER B()WDEN STATE OF Virginia g OF Virginia Beach City On 3 k�&`L3 before me, DAWN L. KRETCHMAR , a Notary Public in and for VIWVE� W te Virginia, personally appeared of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE FOR FREEDOM MORTGAGE CORPORATION, ITS SUCCESSORS AND/OR ASSIGNS, personally known to me(or proved to me on the basis of satisfactory evidence)to be the person(s)whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity, and that by his/her/their signature on the instrument the person(s), or the entity upon behalf of which the person(s)acted, executed the instrument. DNOTARY PUSL CAR WITNESS my hand and offici l seal, o k REGISTRATION#7518224 COMMONWEAL(H OF VIRGINIA MY COMM SSI ^�X 1 ES C�. L. Notary Expires: (This area for notarial seal) *WD*WDLCSV*03/21/2013 04:16:14 PM*LCSV01LCSVA000000000000000087172* PACUMBE* 5785753 PASTATE_MORT_ASSIGN ASSN *TH*THLCSV* COMMITMENT SCHEDULE G File Number.EC-18998 ALL THAT CERTAIN Unit, being Unit No. 591-19(the=(Unit'), of Sunguild 111, a Condominium located in UPPER ALLEN TOWNSM, County of CUMBERLAND, Commonwealth of PENNSYLVANIA, which Unit is designated in tho Declaration of Sunguild 111, a Condominium (the"Declaration of Condominium") and Declaration Plats and Plans as recorded in the Recorder's Office of Cumberland County in Misc.Book 357,Page 20, and in Flight of Way Plan Book 9, Page 24;as amended in Misc.Book 362,Page I l 11, and Plan Book 57, Page 132 and as Aitther amended in Misc,Book 365,Page 993 and Plan Book 58,Page 81. TOGETHER with an undivided 1.9461% interest in Common Elements as more particularly set forth in the aforesaid Declaration of Condominium and Declaration Plats and Plans,as amended aforesaid. TOGETHIMR with the right to use any limited common elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans,as amended. BF,MQ THE SAME PREMISES which NICHA.EL D.HBNNING and LISA L.HENNING,husband and wife by Indenture bearing the date of"February 16,2401 and recorded in the Office of the Recorder of Deeds,in and for the County of Cumberland,COMMONWEALTH OF PENNSYLVANIA on February 21,2001 in Book 239 Page 826 granted and conveyed unto RUSSELL W. FRANKS, SR, and MICHELE R. FRANKS, their Heirs and Assigns,in fee. Parcel No.•42-24-0791-163.U591-19 EASTCAASTABSTRACT 215674.8788 RESIDENCE 3 XCO39 Certified and Regular Mail 214121113 ACT 91 N1OTICE 'T'AKE ACTION TV SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default,and the lender intends to foreclose.Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER IS EMMERGENCYMORTGAGEASSISTANCE PROGRAM(HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if REMAP can help,you must MEET WfTHA CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name,address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice.If you have any questions,you may call the Pennsylvania Housing Finance Agency toll free at I-800-34,2-2397. (Persons with impaired hearing can call(7179 780-1869). 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 NOTIFICACIO'N EN AD3UNTO ES DE SUMA IMPORTANCIA,PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA(PENNSYLVANIA HOUSING FINANCE AGENCY)SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOW'NER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. _ EXHIBIT � ROOM- HOMEOWNER'S NAME(S): RUSSELL W.FRANKS SR MICHELE R.FRANKS PROPERTY ADDRESS: 591 GENEVA DR MECHANICSBURG,PA 17055 LOAN ACCT.NO.: 5785753 ORIGINAL LENDER: FREEDOM MORTGAGE CORPORATION CURRENT LENDER: Freedom Mortgage Corporation CURRENT SERVICER: LoanCare, a Division of FNF Servicing,Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YO U MA Y BE ELIGIBLE FOR FI]VANCL4L ASSISTANCE WHICH CAN SA VE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE 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. TEMPORAR Y STA Y OF FORECLOSURE-Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage for thirty(30)days from the date of this Notice(plus three —(-T)-days for mailing). During that time you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHEV TIDR TY-THREE(33)DA YS OF THE DA TE OF THIS NOTICE. IF YOU DO NOTAPPLYFOR EMERGENCYMORTGAGE ASSISTANCE, YOUMUSTBRflVG YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOWTOCURE YOUR MORTGAGE DETAULT". EXPLAINS HOW TO BRDVG YOUR MORTGAGE UP TO CONSUMER CREDIT COUNSELINGAGENCIES--Ifyou meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action _ ............ KC039 against 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 property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately ofyour intentions. APPLICATION FOR MORTGAGE ASSISTANCE—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 lenderfromfiling aforeclosure action,your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency- YOU SHOULD FILEA BEHAPAPPLICA TIONAS SOONAS POSSIBLE. IF YOU HA VE A MEETING WITHA COUNSELINGA GENCY WITHIN33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILEANAPPLICATION WITH PHFA WITHIN 30DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTINGA FORECLOSUREAGAINST YOUR PROPERTY,ASEXPLAINED ABOVE,IN THE SECTION CALLED "TEMPORARYSTA Y OF FORECLOSURE. YOU HA VE THE RIGHT TO FILEA HEMAPAPPLICA TIONEVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTINGA FORECLOSUREACTION,BUTIF YOUR APPLICATIONIS EVENTUALLYAPPROPEDATANY TIMEBEFOREA SHERIFF'SSALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION—Avallablefundsfor 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 YOUARE CUR"NTLYPROTECTED BY THE FILING OFA PETITION IN BAAWR UPTCY, THE FOLL 0 WING PART OF THIS NOTICE IS FOR INFORMA TION PURPOSES ONL Y AND SHOULD NOT BE J CONSIDERED AS ANA TTEMPT TO COLLECT THE DEBT (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) XCO39 HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 591 GENEVA DR MECHANICSBURG,PA 17055 IS SERIO USL Y IN DEFA ULT because: A. YOU HAVE NOT AMDE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments Delinquent Amount 05/01/2012 $777.74 06/01/2012 $777.74 07/01/2012 $777.74 08/01/2012 $777.74 09/01/2012 $777.74 10/01/2012 $777.74 11/01/2012 $788.56 12/01/2012 $788.56 01/01/2013 $788.56 02/01/2013 $788.56 Late Charges $0.00 Bad Check Fees $0.00 Other Fees $0.00 Corporate Advances $315.00 Suspense Balance $0.00 Total Due $8135.68 HOW TO CURE THE UEFA UL T--You may cure the default within THIRTY(30)DAYS of the date of this notice BYPA YING THE TOTAL AMOUNT PAST.DUE TO THE LENDER, WHICH IS$8135.68, PL US ANY MORTGAGE, PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY(30)DA Y PERIOD- Payments must be made either by cash cashier's check, certified check or money order made payable and sent to: LoanCare, a Division of FNF Servicing,Inc. P.O.Box 37628 Philadelphia,PA 19101-0628 XC039 IF YOUDO NOT CURE THE DEFAULT If you do not cure the default within THIRTY(30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt, This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Iffull payment of the total amount past due is not made within THIRTY(30)DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE.MORTCAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred, up to$50,00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed$50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the TIII'RTY(30)DAYperiod,you will not be required to pay attorney's fees. OTHER LENDER REA&DIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFA UL PRIOR TO SHERIFF'S SALE--.If you have not cured the default within the THIRTY(3 0)DAYperiod and foreclosure proceedings have begun,you still have the right to cure the default and prevent. the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due,plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any 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. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five 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 LENDER: Freedom Mortgage Corporation c/o LoanCare, a Division of FNF Servicing,Inc. Collection Department 3637 Sentara Way Virginia Beach,VA 23452 "Poll Free 1-800-909-9525 Fax 757-466-2828 EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the XCO39 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 MOR TGA GE—You may or_✓—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. YOU MAY ALSO IM VE 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. TO THE EXTENT THE FAIR DEBT COLLECTION PRACTICES ACT IS APPLICABLE,PLEASE BE ADVISED THAT THIS COMMUNICATION IS AN ATTEMPT TO A COLLECT DEBT AND ANY INFORMATION OBTAI NED'BY VIRTUE OF IT WILL BE USED FOR THAT PURPOSE.IF YOU ARE CURRENTLY OR HAVE WITHIN THE LAST NINE (9) MONTHS BEEN IN THE MILITARY SERVICE PLEASE NOTIFY US IMMEDIATELY. YOU MAY BE ENTITLED TO RELIEF UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT. YOU MAY ALSO CALL 1-800-342- 9647 FOR FURTHER ASSISTANCE OR VISIT WWW.MILITARYONESOURCE.COM/SCRA. WHEN CONTACTING THIS OFFICE AS TO YOUR MILITARY SERVICE,YOU MUST PROVIDE US WITH POSITIVE PROOF AS TO YOUR MILITARY STATUS. IF YOU DO NOT PROVIDE THIS INFORMATION,WE WILL ASSUME THAT YOU ARE NOT ENTITLED TO PROTECTION UNDER THE ABOVE MENTIONED ACT. IF YOU ARE CURRENTLY INVOLVED IN A BANKRUPTCY PROCEEDING PLEASE NOTIFY US IMMEDIATELY.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN A BANKRUPTCY PROCEEDING, PLEASE BE ADVISED THAT THIS NOTICE IS NOT INTENDED TO COLLECT AGAINST YOU PERSONALLY OR INDICATE THAT YOU ARE PERSONALLY LIABLE FOR THIS DEBT. IT IS REQUIRED SO THAT WE MAY ENFORCE OUR LIEN RIGHTS WITH RESPECT TO THE ABOVE-REFERENCED PROPERTY. XC039 CONSUMER CREDIT COUNSELINGAGENCIES SERVING YOUR COUNTY CUMBERLAND County Advantage Credit Counseling Service/CCCS of Community Action Commission of Capital Region Western PA 1514 Derry Street 2000 Linglestown Road Harrisburg,PA 17104 Harrisburg,PA 17102 717-232-9757 888-511-2227 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 PA Interfaith Community Programs Inc PHPA 40 E High Street 211 North Front Street Gettysburg,PA 17325 Harrisburg,PA 17110 717-334-15I8 717-780-3940 800-342-2397 I i " ® - ' e 19 � m m ED cO - = W 11" 1 m t71 y• ! as - r=1 rq ra a Postage $ l-1. 1- i . CeAified Fee r1 Posimark O M Return Receipt Fee Mere O CJ (Endorsement Required) _ E3 E3 Restricted Delivery Fee O r 3 (Endorsement Required) n Q E s u7 vi m M RUSSELL W. FRANKS SR a rA 591 GENEVA DR a MECHANICSBURG PA 17055 - -- - -------------- c i s i t I is Ggmn lets items 1.,2,and 3.Also complete A Signature i item 4 if Restricted Delivery Is desired. ❑Agent ® Print your name and address on the reverse ❑Addressee so that we can return the card to you. B. Received by(Printed Name) C.Date of Delivery _ .Attach this card to the back of the mailpiece, or on the kint if space permits. D. is delivery address different from item 1? ❑Yes l 1_ Article Addressed to: If YES,enter delivery address below: ❑No t RUSSELL W. FRANKS SR 591 GENEVA DR I MECHANICSBURG PA 17055 a ServiceType [3 Certmed Mait ❑Express man ❑Registered ❑Return Receipt for Merchandise ; I ❑insured Mail ❑C.O.D. 4. Restricted Delivenr7 '39) ❑Yes ' 12 Article Number ,�d11r 3500 00131 1418 (transfer from servic PS Form 3811,February 2004 Domestic Return Receipt 102595.02-M-1640 b a 1 C ° —'-- to M :� r1=1 Postage $ -' � in Certitiad Fea Postmark Here • ® "�° Cf r3 Return Remipt Fee to 1:1 (Endorsement Requued) C! C3 _ Restricted Dsl'arery Fee '(EndorsemantRegwre d) U3 C3 t3 Cf in Lr) rn in MICHELE R• FEA _ 591 GENEVA DR a Q s PA PA 17©55 _--------- e, Ar. Complete items 1,2.and 3.Also complete A. Signature i item 4 ff Restricted Delivery Is desired. ' . � 0 Agent I IN Print your name and address on the reverse 0 Addressee j so that we can return the Card to you. B.Received Attach this card to the back of the mailpieoe, by l P"" Name) Date of Delivery : i or on the front if space permits. I. Artiste Addressed to D.Is delivery address ciiffmard from Rem 1? 13 Yes ra If YES,enter delivery address below: ❑No MICHELE R. FRANKS 591 GENEVA DR s. Sarvice Type l MECHANICSBURG PA 17055 l:] ❑ Mail . ❑Registered ❑Return Receipt for Merchandise E3 insured Mail Q O.O.D. I 4- Restricted Delivery?{Extra Fea) Q Yes 2. Artlrde Number 7011 3500 O 0 01, 5113 1401 Mansfer tram PS Form 3811,February 2004 Domestic Retum Receipt 102595-0244.1640 t d ` . O . . M IT, D o r—1 A " .... . m 'r4 r-1 r-1 rl postage $ . xn in _ certified Fee Ci Cl Return Receipt Fee Posirnark O L7 (Endorsement Required) Here r-3 r3 Restricted Delivery Fee n (Endorsement Require C3 0 Ln Ln m m RUSSELL W. FRANKS SR O ra a 198 SE PEARL TERRACE . o a LAKE CITY FL 32025 - •-- - �` ` - r ei Complete item' tems 1,2,and 3.Also complete A-Signature. i item 4 If Restricted Delivery is desired. 0 Agent i R Print your name and address on the reverse ©Addressee ; so that we can return the card to you. B. Received by(printed Name) C.Date of Delivery jB Attach this card,to the back of the mailpiece, i or on the front If space permits. ; D. Is delivery address different from Item 1? Cl Yes I i 1. Article Addressed to: if YES,enter delivery address below: .13 No RUSSELL W. FRANKS SR 198 SE PEARL TERRACE i LAKE CITY FL 32025 3. Service Type ❑Certified Mai{ 0 Express Man 0 Registered is Return Receipt for Merchandise D Insured Mail 0 C.O.D. 4. Restricted Delivery?(Extra Fee) 0 Yes 2. Article 7011 3500 Q[]Ej' (nansfer from 5123 x,623 serv,�r,�, _ PS Form 3811,February 2004 Domestic Rettun Receipt 102595-0244-1540 a _a —0 . � ,- - m m r� r� Postage .. Ln Ln CerlifledFee Postmark C3 M Return Receipt Fee Hem �.® M O (Endorsement Required) E3 173 Restricted Relivery Fee CJ C3 (Endorsement Required) C3 Q M m MICHELE R- FRANKS 198 SE PEARL TERRACE r`-9 a LAKE CITY FL 32025 .----_-_-_--. r4N —--------------- 'R Il!i .Complete items 7,2,and 3.Also complete A signature i item 4 if Restricted Delivery is desired. Agent Print your name and address ort the reverse ❑Addressee ; i so that We Can return the card to you. B. Received by(Prirrted Name) Date of Delivery C. . Attach this card to the back of the maiipieee, or on the front if space permits. 1 I. Article Addressed to, Is delivery address dWweM from item 1? ❑Yes i If YES,enter delivery address below: 0 No i • Al MICHELE R. FRANKS 198 SE PEARL TERRACE i LAKE CITY FL 32025 ? 3. Service Type i - ❑Certified Mail 0 Express Mail 0 Registered 0 Retum Receipt for Mernhandise ; i O Insured Mail Q c.Q.D. 4. Restricted Delivery? apx a Fee} ©Yes 2. Article Number i (rrans>erfrom servk 7 011 3 50 0 0001 5113 1616 I PS Form 3811,February 2004 Domestic Return Receipt to2ss5-02 ra,t5ao z 7- a Y A t fSJ} + l f { r} oil YK Rod MY i� YAWS f f 1 A r x 7'17,;U�o1�wi=� 77 n Cc; WN t Owns, Iasi f { I > t { t t !Y 1' _ Y{ i u f f t t ! 7 J S f � f= S, l WHAT i APPEHS MMEN I miss MY MORTGACVE PAYMENTS? Foreclosure may o=ur This is the legal means that Your lender can use to repossess(taicz over)your home.When this happens,yore must move oat of your house-If your property is worth less than the total amount you owe on your mortgage Ioan,a deficiency judgment could be pursued_If that happens,you not only lose your home,you also wot.ld owe.HUD an additional amount Both foreclosures and defc:imcy judgments could seriously affect your ability to qualify for a edit in the fiittue_So you should zooid forulosu re if possible. WHM SHOULD I DO? L DO NOT IGNORE TES LET SRS FkOM YOUR LENDER If you are having problems making your pay- ments,call or write to your lender's LOSS Mitlg.tion Department without ddap.Explam your situation.Be prepared ro provide them with financial information, such as your monthly income and expenses-Without this information,they may not be able to help. 2.Stay in your home for now.You may not quay for assistance if you abandon yore property 3.Contact a HUD-approved housing counseling icy Call 1-SCO-5 64'-4297 or TDD 1-900-977-8334 for the housing Counscliog agcy t you These ageuaes are valuable resources.Ibey frequently have information on services and programs offrsed by Government agencies as well as privne and community o"gani"aaous that could help you.The housing counseling agency may also offer astir counseling These services are casually free of charge. You may be considered for tfie following: becW Forbearass m Your lentkx maybe able to arrarge a repayment plan based on your franc ial situatton and may even provide for a temporary reduction or suspension Of Your payments.You may qualify for tbis if you bave re= tly experienced a reduction in income or m increase in living etpext.M you must fiM iSh information to your lender to shDI tbatyon would be able to mkt t(rermVia ments of the ter payment pl.an- �'fort°"ageMadsfscatian Ygu may be able to refinance the debt and/or•extend the term of your wort;age loan_i his Mw help You catch up by reducing the monthly payments to a more affordable kveL You may qualify if you have recovered from a financial problem and can afford the new Payment amount. Partial Claim.your Imder may be able to work with you to obtain a one-time naYmcmt from the FHA-Insurance fund to bung your mortgage current. You may qua*ifi i.your loan is at&2st 4 months delinquent but no more tban.12 months delinquent~ 2.You an able to begin Making full mortgage payments. Whea your lender files a Partial Claim, the U.S. Department of Housing and Urban Development will pay your lender the amount necessary to bring your mortgage currmt You must eraeutx a Promissory Note,and a Lien will be placed On your property nntrl the Promxssaiy Nam is paid in frill. 'fie Pmmismry Note is interest-fie and is due-,ben you pay off the first mortgage or whim You sell the property. Pre-£oreclogure sale.This will allow you to avoid fzrre joswe by selling Your Property for an amount Jess than the amount necessary to pay Off Y=mortgage loan. `'a,ou may qualify i L the Iowa rs at least 2 months delinquent; 2.you are able to sell your house within 3 to S months;and 3_a nceu appraisal(that your lender will-obtain)shows that the value of your home meets HUD program gaideliam Deed^i XI-lieu offoreclosure As a last resort,you uiaY be able to voluntarily`give back"Your property to the lender_ This vroa't save your house,birt it is not as damaging to your credit rating as a foreclosure. ' vou can qualify ii± I-you are in default and don't qualify&r any of the other optiona, 2.your attempts at selling the housebefore foreclosure WM unsuccessful;and 3,you don't have another FHA mortgage in defai,tt 0 JJOW Do I KNOW lflF I OUAUFY FOR ®, ,lam'OF THESE AL'EMB(MVES? your lender will determme if you qualify for any of the altetaatzves.A housing anMSeing agency caa also help you dPrP,mine which,if any,of these optiotks may meet Your needs and also assist you in inu zac ing with your leader Call 1-800-569-4287 or TOD 1-800-977-9=9. SHOULD !I SO AWARE OF ,l 'MJNG ELSE? Ins,Beare of scamsl Soluttnm that sound too simple or toa good to be true usually are-If you.'re selling qom' home without professional guidance,beware of buyers Who try to nish yvu t-hmugh the process.Unfom�, there are people who map try to tape advmtap of Your financW difficulty.Be espt dally alert to the followitg: Ecruity sk in this type of scam,a"buyer" approaches You,offering to get you out of financial trou- ble by promising to pay off your mortgage or give you a sum of monvyr when the property is sold_T e:"buyer" may suggest:that you shove out quickly amd deed the property tD him or her:Tbz"buyer"then collects rent for a tame,does not make any mortgage payments,and allows the lender to foreclose_Remember;signing over your deed to someone else does not necessarily reliem you of your obligation on your loan.. Phoay cousoseliniagencies,_Some groups calling themselves"counseling agencies may approach you and affer to perform certain services for a fee.Tb�%e could well be services you mould do for yourself for Ere,such as negoti- ating a new payment plan with your leader*or pursuing a pre- rerlosum sale_If you have ate*doubt about paying for such services,call a HUD-approved housing counS-Jiag agency ax 1-800-569-42a7 or TDD I-900-87r 83 9. Do this before you pay anyone or sign anything. ARE THERE ANY PRECAILMONS I CAN TAKE? Here are several precautions that should help you avoid being°takm"by a scare artist: 1.Don't:sign any papers you don't fully undm au l_ 2.Maim sure you get all"promises"'is writing. 3.Beware of any contract of sale or loan assumption where you are not formally released from liability for your mortgage debt. 4.Check with a lawyer or your mortgage company before entering into aay dual involving your home_ S.If You're selling,the house yourself to avoid foreclosure, check to see if there are any complaints against the pmspective buyer iron can contact your state's AtaotacY G neral,the State heal Fstate Conwaicsion,or tae local District Attorney's Ccnsumer Fraud Unit for this type Of information. aa WHAT ARE THE SIN Polfffs I 0 SHOULD REMEMBER? L Don`t lose your home and damage your credit history. 2.CA or wrie your mortgage lender immediaty and be honest about pour financial situation. 3.Stay m your bome to make sure you qualify for asmtance 4.An-tee an appaiutmear with a HUD-approved housing counselor to explore yaur options at 7-800-56M-4287 or TDD 1-800-877-8339. 5.Cooperate with the counselor or lender trying to help you. 6.Explom every alternative to keep your home. 7.Beware of scams. s3 Do not sign anything you don't understand.And remem- ber drat dgrdng over the deed to someone else does not necessarily relieve you ofym r loan obligation_ Act now Delaying can't help.If you do nothing,YOU VnLL LOSE YOUE HOMEand your good credit razisg� Visit our web site at www.hud.gov ,4.,1§{;; Gi't tir {��ol i{tLr✓.r r"`�'`MlS�'.fk f;({x-11 lr� ';`i:CSa rini IxA} .�f'yl r-{,-4r?tr�r y�F':'L�S�:e 1 6 4iy{{!+,,��4j;;�.Yr.ti Jr�r.t;:',��'' a,.�r 1 7�f(�`j; l�n;?i� .;s�`t✓r 1':.�l�h,i-.i i,�r..re pr ,t^➢,i�tt�,u'�2.�,r 4i,1�✓1 Gertr,�J r{�i���t�tu:�1 r/t aJt!15�"Ar 4i:�tk1r 1�ilb:�m>r � ,_Srl 190 M NW. ".RR ,:,i l-v e A 0r,l1;l:$7 �i hig d fT rim, b , .xr•r ,f,,', r., ,�,,r+ ,rh �+ ., � .,,.�,.: 1. !. , rxu+`rtr�t !I:a �r fro�`)Sba�'2 �:{.! �[!' 'i;{z,r,�'T. j;,�{14,. ,.�yti.,e:;:��!�� Jt$r .1 5: p "i F!{"irti�7�,;��•: v/�7 z �i +� .,�:.1{",1 ,!:�"f;'tai p, �-,.:'�,f,aF�.;.l1:;., �.(,f f.l lt��� .f, i i°tt�t e.�r,,al�r-�� '•1 n / .qq;, ,rr:.f,m J. .l fl-'.F(�r N�,>• •1f 1.�f)(.>.r. �1 j,.J`j�.f.,� !f �et.J/� ilj♦ .J Y.it.�;.'j7.r).� !�.,/;�e%:J'i;;)�.•f. ,1:,.":}i,�N��i,.tt 5t: ,f��rr}9'lrgS(+rJ..,: •at�l,i12`t:....,f ;`:'1'19 1, f la;,H,�S`lam.r`�.���7. C;fi..i YtiC•M..�.,.k;;Cri,.t. I,J_.`ti4'���i!fis 7.f: .:1 S lh.ir-,�S��rl.•�arfr`iG�'r.yro )T :��1 $°f,r.,. R r!? .qt _ :?. .t.,, y.},.; ,.df�+.n ,:.t t f{,,fltt....j,ppt:S:}.q i 1t,' 7,1,�-1,.tr,,f,�,�i'.1,1�s r.a.-, y`�kln::.e5 ..d.�„rrt':;.�`� .;�' •.till i >• t.c+„� t� �.- I(. d-1 •J.n�1:1:( ,".}. rj}i f, a''rf,tiro-°.¢t.avt'irt+;fg<L' .,?('...3?airy� 1ro:+t�{,�°d1.�i ::'rra:S N ti .�. S': n.✓,:,9a;..ti�i, S.:Po :.d� n ;rJ r.1,..a t. itin.- r' .,ik12.Y f 1, r•{ir+r�ly4>1,. 4„r,a.,1J,> ,n 4:5,:�✓r. {.,1. >•F��-1 '`•S �,.�1t1'rt 2Y�.,.1, r,!, ,�, :t1.,;v;i;. ..,A,. .,I:,f..N,:,:.� �4 t:' :�tr,.•t,{':, ;•rira ..r , ;n .,h,s.Y.,�..C�.;•.� ft .,r n r - >,t:ti>, r.;�..`�. rxr,,� �:;�. S •-s A1, .t,,:«4 'ifilr t"t- =`:{!#... ,.s.t za1l;.-•iSe�F. h� ,T.�w, `-v!�ta2 3,t,�r-t :!'.,.:.irk tug > .l.Yi"�.',; d�mn. ;,r.;l.id��1.,� .,(.-a•,rr,,,, :'a..ray..-,J.p°.nfn: .r:?, ra' dN S%PI n1,:i 7 r-z{.f 3f rL .1A S�?�, o-,ye.. A,- ,. .!' .s }. 1._ l i. '+`t"3tr,,i.,, ..4.. .1:fia,-.x .., !/. ',.r !='o+eetl. 5.,1..,,-..,,1 _ :�I�,;.r:.,r,t.s.;,. •r, F"•a'' n r.rl.. `�� v. .# �r_cx y �I ls:rr..t .,a .�•°.4�:ae:1:' .f'�!, ,a... �,r •�t s r r ,�� r, d n.. _.r, •a�,r _3.,.1... ,,• ., .,r -'�'t f .r.,• r",. ..,.a ,,r�,,,�:.t. �d,r ...���..�, .r ..•rs�{..pr,j'.�•1?:�d• a,m:� U;`r.r,k-,A> �.. a.<_... rF: f< :.e%,.,. .r._.,.;'+ .:Y., 77P,�, ,�:u.t,_:,. 4 ,,, !.: d ._f,. .u.,. ur .rd• .1 s� '��r,rs1 �f. ..rt• .,r. t� n �<:a,.r �. ,rt t e ro 2,. f f , ., ,ry£y .✓. , .. .,. t .- 1,+;.�EG'�'� y r`ib';>� �ry>; tnr an. t�� ., .., a. !•r P. .� .l., .f i .t v.Y. J� .f F•f ri t. a -r d, _.I. �, a.. dr A, r r G. r �, .7�- .i.. �^N.. Z... :'N.�.,t: .f' .•I... .!L '.f_xt.. 2 , e�rx ;:.5:', t ...7`H r�r t x:2 a �. . .l.a S. .7 �,r - �: �. .. .{n � ;;, h. c i �. l r. a r. .. s:. •s.. , l.t .✓.. w,t.. '?;,,i> ;:r...:ri;:!ar( r.;; ,,r.-. ,s, ...• �.. . .. �� 1. w � ... .. r. � c , , .t,. �..,� ..( ....r :-•.c, .r:., {;a:.,. �� y r t., 1 �i•. ,a �� �r t � .r rrr 1. r:,�� .r r . .:r,n::.N... � :n,,.. .✓...rl. �:. ,�, rr ,... :'a.� 1. r r✓.r�° 'i:}:;�'`k:�... �1.. a 1 � .. .. .,.. ++ : f 1.71 > - ..1J `ry.,.> >r...,. ,. .I i..r F+; rl.,+�.>.,...{:'r'vr;.. 1(:!• 7 .f t �.. / 1 �o- '•�::',•.�.:!�('�: Ge f.. ,.'J,., �IJ'c• ':'L. {(o- 2 1r.f ,r'' 'fa• l�i�jrF'• '� � o-r ,.l. .t ,t. J. �{ .t.}>, ,F. .+J .1 ,.i .1 �..a :j; f�9 .�',t�:ljn<if'::_,,:��il•; ."i.. T .ti. .�..�...1. t,: >-t, s .1 u.i. ,N. ...t._�r. ,d• Ce,1.+ a. t ..�r �+:, .:�:� e.s. .+r� ..4.. .... .,.r rd°, , S �. .1'.d ..a9 �....,.�.,1.,.., _. ,.t .la, r: ° ::, . F ,�.,.. „�,L ,6..{: ..J•. 1: y > {.n, s.� ,v..,> iCtl:a.: 1 r tii. .r 4<r ,r. r.,...1.� .�.r,,. ,.r ,.ra.�.. �zi.. i•q,, :+r'•'•: v. r R fr ,.. r.:�iJr_.•.. G: n-r �.t_ �I f tt ra! ,::��: r, ;ip::';...per>.a;:.-; .r 't'C. X. l •r•„ •r.�. .JI,. r : i � {k$n• nJ. .�.:.}•':..rl d.�' r.5 2 a ..,r, .t 'iry 'ji' .� �o„ ..y ,.... ..�.y,7•� r.j� , ... .� !. t,,11�: `N ))�� 3 •,1. � :���• fi� 3 !..,.� ,,..,•>,`:t }•,:., .e.ru ,� ;•* , ..,,. :r:�i..• .>ra gin:' t .y:•69 ,. 1�7r r' � ;'c 7 •'r�. Y L. 'die t. r„ 'N .i�E �=i'• ;:'ire`';` ,e. .r 54; y 5 (•. M4.1..a,,. .:1. ...t. r +Y. ) �.1•.r �l�a a h. 1Y•.., ai. �,j. krrr� r 7r.�, r -G.`' t e ,.,:•y, i•t. f!. c. I .t :a. ,1• --.�-;• I- t .<< „1 - §. t .t� per { 1.: �.�,�• .1 .{ .;i r� •�'� r 1 i:• . f �. �,.. .r n.,+�f.�::....:.. ..t.>> l:r.r:'.:. f' .r a .in .. ::>.ilk �.f�'�' `c.�':l�la�.l:4 p'r.:.�1��,�j:1�! •f'!.?�. �.r 1 .. v t � re. .� ,.:.C:!... is.: .�:^..,+,�•i",..,a�.:.�::�r i.�:ri4.n,�'.� rh.>i::" }. 1. { r( ry ">i� f4 �'• .t ..t,: r" r r, ,.r { ,� s•a .� +r.Y •:f. ;"P�� .4 ,:i x "f�., s'J.'r r,ti...� 1. !;{�: �a(.f. �,...•. F.�.r .a>r :1r.:v .,.,...,;;q:'�'y�'!rr f ..�C. , >�r� .r aaa:�.,r..r:� •! a. r .l. 1 ^r aa:: .t >i i. r,' I ,��` ,�. 3•t t h ,r.. r�. .t t. •r rl. 1�µ.r. s r ls� c: „ dr. f ''fF� v?r �.F•v. ., r Ir.'� '.1 'r '4. .a:"� :r .4 :J•.'!'i�i,`„'.ii..,.: ':G 11 rx:o-r� a• !7�.,. ...n;. ,t. Jtl; ��`S`x. ) ';,;,:, 't'r::'!. �' +:•;=� :-ai•'-� �ttir;� �j%r ;�i,:ay" 4: i a .,,f>': i• hrt, ,} �4�' Z. .{:':�•.:'.e i. ..ro. .t _;t.' a,.. t- •.t, r� r �Cryrr:: 4, .,,::�.. '... ,..:. L: rnl' .2 �°�'. a`,rF;'•iv.:...'. { r r�. ,s. •�r, ;t� }r +r '�ls ...�. 1, �•.c ,ts: si, r.. {. , ., 4� � br �v:• .i. 1 ,1 r� .t.: a r. r.:.. .•...u.:,.�..: .,:,.,,,,,,,1 i-.,r, pp ,p lA-ate» a, r. vi •'e. [•E'"�ti� .y,r. :!, 'v• ..2'�>: 1, t �1. 1• 1 9f• .... i �f r 1r - 1� I-i 1� •.r.: r' viv. S r �t1%, •.r I ,.t t i Y r f+ y: 1. r. r Y�• c. f ..(n• Y :.I• � �_r1�•-x. �� 1 ! .r s, ..l, ":r�;<'1�: ;%iai'�'�• :x�,.t>; k , � t,..r>:{.°;r; f 1:1.:y I- .r (,.r e•- -tt.^�t�� '{i.? t: ,r'r(: .:1`;'� .!: ,7. I !. -.7`t.r,.fit' ,r•' ... l,l....o�..�..��....�,c_.. .5..:':... >r.�.. .-,rte.....; ',.... ?.. ...........} I .fI 1. r l 1 r 1 .i' r1 (} ! i (!:�r�!„�r7,• t tj. I J�( f l- .l .r J �fai `rr�r. .( _7 -t. 1( i. I ! t��,. yr t� r ;r: r1 �, 1 Irr r1r ��11rt f It1�� Ir 1 �l - + 7 1 t r >. - ltrr tr1 l �ri jtr {� � rr rr r � �1, 1r.., J1.Ft♦. Ti _ 111c�.l�fill t._ l COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW C= -Va rnm = ZZ: KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG, PC - C5 The Pavilion r-z:<> 261 Old York Road, Suite 410 Ca-rl =C) Jenkintown,PA 19046 —c (215) 572-8111 I.D. 486727 Freedom Mortgage Corporation V. Civil Action Number: 13-2121 Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R.I. Franks MORTGAGE FORECLOSURE Defendant(s) CERTIFICATE OF SERVICE 1, KEVIN P. DISKIN, ESQ., attorney for the within Plaintiff, hereby certify that the complaint in mortgage foreclosure, was mailed to the Defendants by certified mail, return receipt requested on April 23, 2013 and received by the Defendants on April 26, 2013 as evidenced by copy of certified mailing receipts and signed green cards attached hereto. STERN AND EISENBERG PC B VIN P. DISKIN Attorney for Plaintiff 5/1/13 SENDER: . . DELIVERY pQ ■ Complete items 1,2,and 3.Also complete A gna item 4 if Restricted Delivery is desired. X LAddressee d Ji ■ Print our name and address on the reverse x � �° so that we can return the card to you. B. Rec ' (Pinte e)/ C. D■ Attach this card to the back of the mailpiece, �� 01 or on the front if space permits. F°a D. Is delivery address different from item 1? 0 Yes 1. Article Addressed to: If YES,enter delivery address below: 0 No 3. Service Type 0 Certified Mail 0 Express Mail LL % �m �° 1'�e Ctrl 3 .� N% �� ❑Registered ❑Return Receipt for Merchandise U. d1 E3 Insured Mail 0 C.O.D. Lk a° m ,�', ? m B if3 v� d ° m¢ m �id i4 4. Restricted Delivery?(Extra Fee) 0 Yes • � U E"0) v m a 2 Z ry E 'C d a° �o iQ`o o :m 2. Article Number m� �� o m :1 7012 1010 0000 1,826 3389 Ir o %a m ti iv(:) ;h (transfer from service label) _ PS Form 3811,February 2004 Domestic Return Receipt 102595.02-M-1540; 22.EE 929T 0000 020'C 2TU. SENDER: ■ Complete items 1,2,and 3.Also complete A. S' a re >� item 4 if Restricted Delivery is desired. Agent a' _ �ti I� f? � °, ■ Print your name and address on the reverse X Addressee so that we can return the card to you. B. Re e e b '(P t a e) C. Date of Delivery ■ Attach this card to the back of the mailpiece, , j or on the front if space permits. D. Is delivery address different from item 1? 13 Yes v i 1. Article Addressed to: 'if YES,egter:delivery address below: ❑No es m I , V Lj 1! a� i—a\ t 3.-S rviceT e jkCertified Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandise a an d m m dt �'ia 0 Insured Mail 0 C.O.D. m 4. Restricted Delivery?(Extra Fee) M y v SHERIFF'S OFFICE OF CUMBERLAND COUNTY D Ronny R Anderson , -OFFIC Sheriff J, 4," Tf,'�FPROTHOHOTW�l Jody S Smith Chief Deputy 0 U Richard W Stewart MBERLAHO COUNTY Solicitor OF TWR';HE R IF PENNSYLVANIA Freedom Mortgage Corporation Case Number M Russell Franks, Sr. (et al.) 2013-2121 SHERIFF'S RETURN OF SERVICE 05102/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michele R Franks, 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 591 Geneva Drive, Unit 19, Upper All'en, Mechanicsburg, PA 17055. Deputies were advised by a neighbor that the address above has been vacant for at least six months.The Mechanicsburg Postmaster has provided a forwarding address of 225 NW Spanish Oaks Circle, Apt. 101, Lake City, Florida 32055. 05/02/2013 Ronny R Anderson, Sheriff, being duly sworn.according to law, states he made diligent search and inquiry for the within named Defendant to wit: Russell Franks, Sr., 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 591 Geneva Drive, Unit 19, Upper Allen, Mechanicsburg, PA 17055, Deputies were advised by a neighbor that theaddress above has been vacant for at least six months.The Mechanicsburg Postmaster has provided a forwarding address of 225 NW Spanish Oaks Circle,Apt. 101, Lake City, Florida 32055. SHERIFF COST: $55.30 SO ANSWERS, May 14, 2013 RbNN R ANDERSON, SHERIFF (0)CountySuite Sherift,7 eleosoft,trio, �l � t -_ ] - 'RO.NNY R.ANDERSON ^! 14. ° �t .. •�: 5heiii " ' I JODY S.SMITH Chief Deputy OFFIGE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 1701.3 To: Postmaster Agency Control No. f Date: js Address Informatioii Request Please famish thins a gency with the new address,if available,-for the.following indivfcl a or verify whether the address given:below is one at which rnail.for—this individual is currently being delivered I€the, follov�iug address is a post of5ce box,please furnish the.street address as recorded on the box holder's application form ' n +„ i f Name: R4"55e if ran �$., r• Last Known Address: 6 e c e_ .(� tin"t t C L..t�r rye. I certify the address lnuorr6adan for t s m 'individnal is required for.the performance 6f this agency's of duties. "/ (Signa gency Official) Fo'r Post Ofnce Use Only. (}Mail is delivered'to address given. New Address (}Not.Known at Address Given t :{)Moved,Left No Vorurarding Address ()No Such Address {)Other(Specify) Box holders'Street Address Agency Return Address PostnzarlslDate Stamp Please fax results to-the Cumberland County'Sheriff's Office.NL-fiber(717) 240-6397 Address Information Request(Required.for:iat) Exhibit 3.51444b May 09 2013 6: 04AM US POSTAL SERVICE 7177857856 p: 2 _.._...__ May, 1 2013 8: 11AM Cumberland County Sherrif No, 5880 P, 4 'BONNY-R.ANOMON t ► " JODY S.SMtT}i Chtef Deputy OFFICE•OF THE'SHERIFF One Courthouse Square, Room 303 Carlisle, PanneylVanla 170'!3 To: Postriastrr # Apuy Control No. a X3—;!a7� ; 1 • Datn: Addsest Tnformetta�;atetZueat Y I°loeao fkaish*19 sxeocy with*e Deer ed&o m,if ai►ailsble,fgr WonavLas into Uv dual or vsnyy what) a she address gitrsn'below ii tint 9 whio :oW,forthis 64'vidrial ie ouniady b*g 4clivwa& Ifthe, follow'ed 6n Is a post office box.plasma£uraisltsbe.6t*at pdd:'on as r&ordpolon the DaxboldwIo , ilppji�aijollfpl7�. ' ,• •, .� , ' ,. LastXttio�p Address:' '�� Etl��sw— Re.i., hrai. Iq� ..�`� W' • .� ' I ctsttty t>:a edtl:reip iafor�atidn fos tlaie'iaditddu!is rogixirtil PDr•the pertot� rca oy tW agaxsey'a official , •. - ' . (Sipuldro,a e oy offselat) . • (,Tito} nv poet other Plea Only , {}1,44 is doliveaod'ta address gives, 'New Address • (}NotRnovr+n at Addvest+,Given ' 2-�-"•� YY � '��+��� � . '�° 1�-- 1� � .}r .0 Moved,Left No#c.ravarding A idmse t% f�� *3 2.4 ()No SUL A"'ist (}Other(45ci m 13=holders,Sheet a j A4gaacy Rchua Ad&na portmarklDatc S14=0 � !M,fm, Please fax multa to 66 Cumbarj&zd County Shorifi•e Office"N tuber (717)240 'S 07 Addrari;Information RagTieas(RsgW:rcd,f=i At) ! tcl5ibi13k.44b , ' ®r.- r _ 'RO.NNY R.ANDERSON JODY S.SMI TH ---` Chief Deputy OFFICE OF THE SHERIFF One Courthouse Square, Room 303 ' Carlisle, Pennsylvania 17013 To: Postmaster Agency Control No.�G r Date: Address Information kequest x Please furnish this'a-ency with the new address,if a`r ailable,for the address the.following ind;vi'd„a or verify v✓heiher given below is one at;which mi-d for-this individual is currently being delivered• If the foIIoR�iug address is a post offEce box,please fia-cish•he-street address as recorded on the box holder's application form. . Name;OLGI Last Known Address: Q J. c�o ,h (.,In I`1 11'1•P I certify the address iorpiation for tliis'individnal is required for the pesom�ante of his agency/'s official dunes. 4 (Sib tore Ag ncy 0fncial) f Fo•r Post Ofuce Use OLY ()Mail is delivered'to address given - New Address O NOt.Known at Address Given ()Moved,Left No Foi"A'ardiug Address ()No Such Address OOther(Specify) Box holders Street Address Agency Return Address Postcauk/Date Stamp - Please fix results to'tfle Cumberland Co Addres anty'Sherifi's Office.Nuimber(717) 240-6397 s Information Request(Reg1affd.for*at) Exlubit 352.44b May 09 2013 6: 04flM US POSTAL SERVICE 7177957896 P. 1 Nay. 1 2013 8: 11AN Cumberland COUtiCY Shetrif No, 5680 P. 3 ACLNNYRANDCASON . , JODY&SMITH c�.toaputy OFr;ICE;OF THE-SHERIFF • On&CouRhouse uqusra,Room 3o3 Caros(e,Pennsyluartie'17013 To: Poctuias es ,' Apney CoattolNo1�01 Dale; . Addrae:Zaforasatloia$1at�u.at 1 ` . Please fktish 0&r a&aneg with the sew addibas�if e�eilable,'f�z t�p,toliowia�in8it�duat o:ver y woos r tht address gives below is tina at wllieli meii,f"Ais ir&vi"al is cur indy baits 4livetad, Wthe, ' following addre�9s 1t ppet o�co bax,plaice flarzsiah#iae.artreet aiSdraas ae rdtorded on tl:a boxaaldee`s •` , ' • ecppi{Cationfbim► '. '. ,, • ' ', ,', , • • New:• „�}Scktp�'i!.�F�.'�5�• i ,....�.�.• .,, .� ' ' , ,, , Luc Rnon Addtesse ae :-'(4 (� I Wrtify a iddtdis'ia'orjmatid ik it i's'6d duil Is nqubcd to:,tl a p 4 of cAi a'ZODW6 o1"uw • • - '�S%gv true Ag ey OtrSeialj ' (Tina) P'oi'Poat+Of6c.Use Oaly, , (}MO is deliverod'te address gives, .New Addross ()Not,li~aowa at Addbesa Graven 2-Z'�'r" 1 �`'p f:: � 6&:5 G c r'Z A4- to ,{}Mavad,Left No Yorwerdiaa Adder. ,,..�1� .-. �'�`�. ,�~" �•-� { p.,N-at ()No Suet Addiist ' f y Qd=(Speeifjr) Dexhol Ad So A;e�cy ReAun AAdWana pertautr Piaue tax results to'tbe Cumber'tattd Co:n�%-'Shertii's QM5 N%ai er(71'1 397 Address Information Regtiert(Req;Vrcd.fbzzi*t) STEVEN K.EISENBERG,ESQUIRE(75736) KEVIN P.DISKIN,ESQUIRE(86727) LESLIE J.RASE,EsQuIRE(58365) "' "SOT' CHRISTINA C.VIOLA,ESQUIRE(308909) cif V 3 T STERN&EISENBERG,PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 AND CQ JENKINTOWN,PENNSYLVANIA 19046 i��`r T TELEPHONE:(215)572-8111 r� FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Freedom Mortgage Corporation V. Civil Action Number: 13-2121 Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R. I. Franks Defendant(s) MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R. I. Franks , for failure of said Defendant(s)to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE...............................................................................$108,405.98 INTEREST accrued thru 04/08/2013 of .......................................................$5,213.53 Interest after 04/08/2013 shall accrue at the per diem rate of$13.85:) LATE CHARGES accrued thru 04/08/2013 of.............................................$63.08 Late charges after 04/08/2013 shall accrue at the monthly rate of$31.11.) - - ESCROW ADVANCES................................................................................$1,432.96 OTHER CHARGES.......................................................................................$1,182.30 %IU.s6�d a 291 ��Le COSTS...........................................................................................................$300.00 ATTORNEY'S FEE......................................................................................$5,420.00 Sub-Total Through Date of Complaint....................................................$122,017.85 ACCRUED INTEREST after 04/08/2013 shall accrue at the per diem rate of$13.85 to May 30, 2013......................................................................$720.20 ACCRUED LATE CHARGES Late charges after 04/08/2013 accruing at the monthly rate of $31.11 through May 30, 2013........................................................................$31.11 TOTAL DUE THROUGH DATE OF REQUEST FORJUDGMENT.........................................................................................$122,769.16 STERN & EISENBERG, PC B STEVEN K. EISENBERG, ESQUIRE J? KEVIN P. DISKIN, ESQUIRE • JACQUELINE F. McNALLY, ESQUIRE • LESLIE J. RASE, ESQUIRE • LEN M. GARZA, ESQUIRE • CHRISTINA C. VIOLA, ESQUIRE Attorney for Plaintiff STEVEN K.EISENBERG,ESQUIRE(75736) KEVIN P.DISKIN,ESQUIRE(86727) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) STERN&EISENBERG,PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Freedom Mortgage Corporation V. Civil Action: 13-2121 Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R. I. Franks Defendant(s) MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF MONTGOMERY I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants': 1. Last-known address is: 198 SE Pearl Terrace, Lake City, FL 32025-1865 or 225 N.W. Spanish Oaks Circle, Apt. 101, Lake City, FL 32055 2. Is over the age of twenty-one. 3. Is not now nor has been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers' Civil Relief Act of 1940, as amended. STERN&EISENBERG, PC BY: I SENBERG, ESQUIRE A KEVIN P. DISKIN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE ❑ CHRISTINA C. VIOLA, ESQUIRE Attorney for Plaintiff Sworn tQ and subscribed before me this ay of '1'ZG�,_, 2013. Notary Public 1 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DIANE J.TUPANO,Notary Public Jenkinto7 n Eoro.,Montgomery County My Commission Expires October 31,2014 • Department of Defense Manpower Data Center Results as of:May-3D.2013 06:10:55 SCRA 3.0 y. Status Report Pursuant to Serv%cemembers Civil.Relief.Act Last Name: FRANKS First Name: RUSSELL Middle Name: Active Duty Status As Of: May-30-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - - No NA This response reflectslhe individuals'active duty status'based the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA No NA NA This response reflects where th&individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HWHer Unit was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA.' No NA This response reflects whether the individual or hislher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arfington,VA 22350 Department of Defense Manpower Data Center Results as of:May-30-2013 06:1123 SCRA 3.0 Statue Report Pursuant to Servicememben Civil Relid Act Last Name: FRANKS First Name: MICHELE Middle Name: Active Duty Status As Of: May-30-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No',�. NA This response reflects the individuals active duty status based on the Active Duty Status Date Left Active Duty within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA I i __ ,No _. NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or tds(her unit has received eaAy notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,bas d n the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 STEVEN K.EISENBERG,ESQUIRE(75736) KEVIN P.DISKIN,ESQUIRE(86727) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) STERN&EISENBERG,PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Freedom Mortgage Corporation V. Civil Action: 13-2121 Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R. I. Franks Defendant(s) MORTGAGE FORECLOSURE CERTIFICATION UNDER RULE 237.1 I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. No. 237.1., a true and correct copy of which is attached hereto. STERN&EISENBERG, PC BY: ❑ STEVEN K. EISENBERG, ESQUIRE ! KEVIN P. DISKIN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE ❑ CHRISTINA C. VIOLA, ESQUIRE Attorney for Plaintiff STERN&EISENBERG PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(22 15)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND,PA COUNTY Freedom Mortgage Corporation (Plaintiff) Docket#: 13-2121 V. Russell W. Franks, Sr. TEN DAY NOTICE Michele R.Franks &Wa Michele R.I.Franks (Defendant(s)) NOTICE PURSUANT TO Pa.R.C.P. 237.1 TO: Russell W. Franks, Sr. Michele R. Franks a/k/a Michele R.I. Franks 225 N.W. Spanish Oaks Circle,Apt. 101 225 N.W. Spanish Oaks Circle, Apt. 101 Lake City,FL 32055 Lake City,FL 32055 Date of Notice: Friday,May 17,2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: 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 800-990-9108 717-249-3166 STERN&EISENBERG,PC By: 2torney for Plaintiff 1:\Taylor\Ten Day\LoanCare.Franks.I Oday.5.13-Spanish Oaks Address.docx STERN&EISENBERGPC THE PAV ILION 261 OLD YORK RoAD,S InTE 410 JENKINTONATN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNTSEL FOR PLAINTIFF) IN THE COURT OF CONLgON PLEAS OF PENNSYLVANIA CUMBERLAIND,PA COUNTY Freedoin Mortgage Corporation. (Plaintiff) Docket#: 13-2121 V. Russell W. Franks, Sr. TEN DAY NOTICE Michele R.Franks a/k/a Michele R. I_ Franks (Defendant(s)) NO'T'ICE PURSUANT TO Pa.R.C.P. 237.1 TO: Russell W. Franks, Sr. Michele R. Franks a/k/a Michele R.I. Franks 198 SE Pearl Terrace 198 SE Pearl Terrace Lake City,FL 32025-1865 Lake City,FL 32025-1865 Date of Notice: Friday,May 17,2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: 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 Bas Association 32 South Bedford Street Carlisle,PA 17013 800-990-9108 717-249-3166 STERN&EISENBEERR9,PC By. o for Plaintiff' F J:\Taylor\Lo an Care.Frank-s.l Oday.5.13.docx STERN&EISENBERG PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 JENKATTOwN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND,PA COUNTY Freedom Mortgage Corporation (Plaintiff) Docket#: 13-2121 V. Russell W.Franks, Sr. TEN DAY NOTICE Michele R.Franks a/k/a Michele R.I. Franks (Defendant(s)) NOTICE PURSUANT TO Pa.R.C.P. 237.1 TO: Russell W. Franks, Sr. Michele R. Franks a/k/a Michele R.I.Franks 591 Geneva Drive, 19 591 Geneva Drive, 19 Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 Date of Notice: Friday,May 17,2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: 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 800-990-9108 717-249-3166 STERN&EISENBERG,PC By: ) rney for Plaintiff J:\Taylor\Ten Day\LoanCare.Frank 10day.5.13-Property.docx STEVEN K.EISENBERG,ESQUIRE(75736) KEVIN P.DISKIN,ESQUIRE(86727) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) STERN&EISENBERG,PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Freedom Mortgage Corporation V. Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R. I. Franks Civil Action: 13-2121 Defendant(s) MORTGAGE FORECLOSURE CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriffs Sale scheduled in the above-captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to Defendants and no timely response was made. STERN &EISENBERG, PC BY: z STEVfN K. EISENBERG, ESQUIRE i KEVIN P. DISKIN, ESQUIRE • JACQUELINE F. McNALLY, ESQUIRE • LESLIE J. RASE, ESQUIRE • LEN M. GARZA, ESQUIRE • CHRISTINA C. VIOLA, ESQUIRE Attorney for Plaintiff STEVEN K.EISENBERG,ESQUIRE(75736) KEVIN P.DISKIN,ESQUIRE(86727) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) STERN&EISENBERG,PC THE PAVILION 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PENNSYLVANIA 19046 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Freedom Mortgage Corporation V. Civil Action: 13-2121 Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R. I. Franks Defendant(s) MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Freedom Mortgage Corporation 907 Pleasant Valley Ave., Ste. 3 Mount Laurel,NJ 08054 (Plaintiff) Russell W. Franks, Sr. and Michele R. Franks a/k/a Michele R. I. Franks 198 SE Pearl Terrace Lake City, FL 32025-1865 225 N.W. Spanish Oaks Circle, Apt. 101 Lake City, FL 32055 (Defendant(s)) STE B�EISENBERG, PC BY: ❑ STEVEN K. EISENBERG, ESQUIRE .&-KEVIN P. DISKIN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE ❑ CHRISTINA C. VIOLA, ESQUIRE Attorney for Plaintiff C:) ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVA4 CIVIL DIVISION CD PRAECIPE FOR WRIT OF EXECUTION �-�, �~ J` Freedom Mortgage Corporation E]Confessed Judgment Plaintiff ❑Other Russel W. Franks , Sr,vs. File No. 13-2121 Michele R. Franks a/k/a Michele R. I. Amount Due 122,769.16 Franks Defendant Interest from 5/31/13-9/4/13 @ $13 . 85 per hem , Address: Attty s Comm 198 SE Pearl Terrace, Lake City, FL 32025 225 N.W. Spanish Oaks Circle, Apt. 1O1 ,Costs Lake City, FL 32055 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs,upon the following described property of the defendant(s) See full legal description attached PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property (if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s)described in the attached exhibit. Date 5/30/13 Signature: Print Name: Kevin P. Diskin Address: 2 61 Old York, Rd 410 Jenkintown, PA 19046 Attorney or: Plaintiff y SQ a �� Telephone: 215-572-8111 �0 Supreme Court ID No: 86727 a as �Wd ( a°1 rt T ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2121 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FREEDOM MORTGAGE CORPORATION Plaintiff(s) From RUSSEL W.FRANKS,SR.,MICHELE R.FRANKS A/K/A MICHELE R.T.FRANKS (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $122,769.16 L.L.: $.50 Interest FROM 5/31/13-9/4/13 @$13.85 PER DIEM-$1,343.45 Atty's Comm: Due Prothy: $2.25 Atty Paid: $204.05 Other Costs: Plaintiff Paid: Date: 6/3/13 LBy: d D.Buell,Prothonota (Seal) Dep uty REQUESTING PARTY: Name: KEVIN P.DISKIN,ESQUIRE Address: STERN& EISENBERG,PC 261 OLD YORK ROAD,SUITE 410 JENKINTOWN,PA 19046 Attorney for:PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No. 86727 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION LAW _ __., r......) G`7 r ANDREW J. MARLEY, ESQUIRE STERN AND EISENBERG, PC '� wry �, ':.- 1581 Main Street, Suite 200 __ Warrington, PA 18976 c-, (215) 572-8111 ...--r-c-) , I.D. #312314 FREEDOM MORTGAGE CORPORATION 907 Pleasant Valley Ave., Ste. 3 Civil Action Number: 13-2121 Mount Laurel, NJ 08054 v. Russell W. Franks, Sr. 198 SE Pearl Terrace MORTGAGE FORECLOSURE Lake City, FL 32025-1865 AND Michele R. Franks a/k/a Michele R. I. Franks 591 Geneva Drive, 19 Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE OF SERVICE I, ANDREW J. MARLEY, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendants by certified mail, return receipt requested on June 12, 2013. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on June 12, 2013, as evidenced by copy of certificates of mailing attached. STERN AND EISENBERG, PC /`i 1R"r J. ARLEY Q: • ttorney for Plaintiff 7/26/13 f f ''441 :1:s' s POSTAGE OSTAGE >PITNEY BONES y l' ZIP 19046 � 002 3 0 �p� 02 m 4ic 0001371685 JUL 12 2013 a) on o' 0 a C) < `` N /4.'i tin t z� T o Q , a a E ti "^W v +1 a∎ °� vii '> - ,..) • + 'd' O P , o 8 i vi p c�r-o o o O 0 ct O C `I O 0 '' U O r- ^i_ FTC -,zI r, W a°'id c` UC) a � � �� � Q O � � O ° o W C 2 Q - a a 00 .fl N . r; N 4: •rte' cu E u ca bA o ,Z cdN .4 N .fl O U � 0 .A 0Ch ..: z > C ;,z4,z� H � tit z /) — P. 0:) = Z QU � U E—, U00E-4 � , 1i E00 � � 3 * * • * * * * b * * ** U * (03 adz ° .° 1 � v, ' ~ N M '1" v z ` = a) a E b j.,' .-J E--∎ fi, ca - zoo • M CERTIFIED MAILTM RECEIPT CERTIFIED MAILTM RECEIPT m (Domestic Mail Only;No Insurance Coverage Provided) (Domestic Mail Only;No Insurance Coverage Provided) m c^ For delivery information visit our website at www.usps.com® For delivery information visit our website at www.usps.com® p-• Er r-R 17" Postage $ rr Postage $ O Certified Fee ■_ " Certified Fee ._ m \--..---Postmark m Postmark O Return Receipt Fee "'� Here M Return Receipt Fee Here 1= (Endorsement Required) ' n0 (Endorsement Required) Restricted Delivery Fee 'd Restricted Delivery Fee (Endorsement Required) m (Endorsement Required) t ..n Total Postage&Fees $ 'a•;•' m Total Postage&Fees $ in ru ) rr p 'Sent To pt p C(��-�ru 1-4 Sent To (&SS @.t9 fuelk5 Mw_ KosSC a c(a!1`i im Street,Apt.No.; im Street,Apt.No.; e/ N or PO Box No. °Z-Z‘ got) �j.7(vl�S,Oa lc S Ci r l I � or PO Box No. } 3 t''A Terra C City,State,ZIP+4 / Z City State,ZIP+4 &-W • C CL -3-1•0 - 0- C.I4, — r., r l— 7 0 2-<"'1 4+ S" PS Form 3800,August 2006 See Reverse for Instructions PS Form 3800,August 2006 See Reverse for Instructi' U.S. Postal Service TM U.S. Postal Service,. CERTIFIED MAILTM RECEIPT CERTIFIED MAILTM RECEIPT ru (Domestic Mail Only;No Insurance Coverage Provided) m (Domestic Mail Only;No Insurance Coverage Provided) Er For delivery information visit our website at www.usps.com® cr For delivery information visit our website at www.usps.com® < .. .;'' ass t .. _/ .._ ....., r 4 Er Postage $ Cr Postage $ P .jg76 '° O C3 . "� Certified Fee Certified Fee 0 Return Receipt Fee icPostmark m ostmarkS CI (Endorsement Required) Here E3 Return Receipt Fee r C] (Endorsement Required) f " Here O t -) .'°' Restricted Delivery Fee CI Restricted Delivery Fee (Endorsement Required) .,-• i ) ■CI (Endorsement Required) ..D tkt /t;; .- Total Postage&Fees $ 4 . '• Total Postage&Fees $ ��.. 1\ In ,,'� fr I Sent To(L(,. ru �: Sent To rr4 i i 4 4 �1 el) �(,cjak. ri -14(� \ - 1 (^ Street,Apt.No.; _ ``L L L,R. Fr�G t S m orPOBoxNo. g( rm Street,Apt.No.; 1., 'q'�1 J E pear( I e'✓„Zi.c e N or PO Box No. -zT% 14, 4 ,.1 4. 1:`sh t (.. _ j)„i V$ City,State,ZtP+4 City,State,ZIP+4 �s�F:rIJ�T J �C{tc { ri, 3'Zt�L� L.. + , `f- • F.r a g ii. .-R- •r -fo nsr hi I PS Form 3800,August 2006 See Reverse for Instructions COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW CHRISTINA C. VIOLA, ESQUIRE STERN AND EISENBERG, PC 1581'Main Street, Suite 200 ° : C_ Warrington, PA 18976 (215) 572-8111 I.D. #308909 FREEDOM MORTGAGE CORPORATION 907 Pleasant Valley Ave., Ste. 3 =� r Civil Action Number: 13-2122- rte: Mount Laurel,NJ 08054 < � V. Russell W. Franks, Sr. 198 SE Pearl Terrace Lake City, FL 32025-1865 MORTGAGE FORECLOSURE AND Michele R. Franks a/k/a Michele R. I. Franks 591 Geneva Drive, 19 Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE OF SERVICE I,CHRISTINA C.VIOLA,ESQ.,attorney for the within Plaintiff,hereby certify that the notice of the Sheriff's Sale was mailed the Defendant(s) by certified mail, return receipt requested on July 12,2013 and received by the Defendant(s)on July 19,2013 as evidenced by copy of certificates of mailing and signed green card attached. I further certify that notice of the Sheriff's Sale was mailed to all lienholders by regular, first-class,postage prepaid mail on July 12, 2013 as evidenced by copy of certificates of mailing attached hereto. ST D IS NB G, PC BY: A IOLA, ESQ. �1�� Attorney for Plaintiff Name and STERN&EISENBERG Address 1581 Main Street,Suite 200 of Sender Warrington,PA 18976 Line Article Name of Addressee,Street,and Post Office Address Postage Fee Number 1 **** Sunguild III Condo Assocation 1076 Lancaster Boulevard,Apt. 1 Mechanicsburg, PA 17055-4491 2 **** PA Department of Revenue Bureau of Compliance w Box 281230 Harrisburg, Pennsylvania 17128 -:: 3 **** Domestic Relations Cumberland County 2 13 North Hanover Street D Carlisle, PA 17013 co C m 4 **** Tax Claim Bureau t�.3 Cumberland County Courthouse 0 One Courthouse Street Carlisle, PA 17013 5 Tenant(s)/Occupant(s) i 591 Geneva Drive, 19 � `' Mechanicsburg, PA, 17055. **** RE: LOANCARE- FRANKS- NOS Total Number of Total Number of Pieces Postmaster,Per(Name of Pieces Listed by Sender Received at Post Office Receiving Employee) (�$ 2. 10 Postal rvice,. �Mfrlirltiiii IL Co CERTIFIED MAIL,, RECEIPT Keg; No Insurance .. Ir a- -3 inn a a flPostage $ Q Postage $ ,x$976 Ra Certified Fee Certified Fee M m -:; O Return Receipt Fee Mimark` C] Return Receipt Fee ;r 'ostmark., i ED (Endorsement Required) �` Here O (Endorsement Required) ;y' r Here i C7 '. h � Restricted Delivery Fee Restricted Delivery Fee M (Endorsement Required) P 1 � (Endorsement Required) f 11 1ti 11 Total Postage&Fees $ Total Postage&Fees $ M m Faty, To Sent To a a O Street,Apt.No.;ru � t Apt.No.; ----°--------°---------------------O Box No. C ce or PO Box No. a.}1 S-State.ZlP+4 M •----- -- ----- City State.Z%P+4 - �j -`--! PS Form 3800.August 2006 See Reverse for Instructions Postal Service,. CERTIFIED MAIL,., RECEIPT y=WlIt 1:411jTI_11W10*91413 ru (Domestic Mail Only;No Insurance Coverage Provided) Ln Ir a Cr a^ k t• Q' Postage $ Q' Postage $ Certified Fee Certified FeeAere'- m ..._., m , C7 Return Receipt Fee tmark p �[��o'stmark § C] Return Receipt Fee C3 (Endorsement Required) �-' Here w O (Endorsement Required) ,.. Restricted Delivery Feed+ 7 Restricted Delivery Fee C7 (Endorsement Required) , (Endorsement Required) Total Postage&Fees Total Postage&Fees t '�•„�. nJ Sent To !' ni FSent r of reet Apt.No.; -------°---°- - - °- p pt.No.;or PO Box No p� x No, _ -----------zip+ N Ciry,State,ZIP+4 City,State,ZlP+4 1�+41c C iT-L L 3 Z aZ SS !r W e C FL-. 3 PS Form 3800,August 2006 See Reverse for lnstructior� PS Form 3800,August 2006 See Reverse for Instructions DER:-COMPLETE-TH��-�SECTION COMPLETE THIS SECTION ON DELIVERY a Complete items 1,2,and 3.Also complete A. $ ft item 4 if Restricted Delivery is desired. Agent Addressee a Print your name and address on the reverse I - so that we can return the card to you, B. Rece' (Pr C. Date of Delivery U Attach this card to the back of the mailplece, t or on the front if space permits. D. Is delive "di t from item V? ❑Yes 1. Article Addressed to: If YE e s below: ❑No Russell W.Frank',SR 225 N.W.Spanish Oaks Circle,Apt.101 3. Sprvice -4 NiVU-i press Mail Lake City,FL 32055 Certified ifid Mar ❑Registered VRXturn Receipt for Merchandise 13 Insured Mail 0 G.O.D. -4. Restricted Delivery?(Extra Foe) 0 Yes 2. Article Number 7012 3460 0003, 0919 4953 (Transfer from service label) 102595-02-M-1540 Domestic Return Receipt ._�7;Form 3811,February 2004 SEND'ER:COMPLETE-THIS,SECTIO k COMPLETE THIS SECTION ON DELIVERy 2 Complete items 1,2,and 3.Also complete A. T item 4 if Restricted Delivery is desired, ❑Agent ■ Print your name and address on the reverse WAddressee so that we can return the card to you. B. Receive V(I I 0 Attach this card to the back of the mallpiece, C. Date of Delivery or on the front if space permits, 0-3 1. Article Addressed to: D. I erent from item 1? ❑Yes enter d W: 0 N6 I Y enter de ddress below: Michele R.Franks a/k/a Michele R.1.Franks 225 N.W.Spanish Oaks Circle,Apt.101 67 1 3. rVS,4W1,-,1 Lake City,FL 32055 Certified Mail gExpress Mail 0 Registered XJ Return Receipt for Merchandise. ❑Insured Mail 0 C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7`012 3460 0003 0919 4939 (Transfer from service label) PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540�, COMPLETE THIS SECTION ON DELIVERY SENDER: COMPLETE THIS SECTION III Complete items 1,2 and 3.Also complete A. Sign item 4 if Restricted 6elivery is desired. JKAgent III Print your name and address on the reverse Cl Addressee so that we can return the card to you. B. Rec 1 y a C. Date of Delivery ■ Attach this card to the back of the maliplece, t ° D. J:7 or on.the front if space permits. D. Is delive Cjs 3 t from Rem I? r-I Yes 1. Article Addressed to: If YE `en elTiety ss below: ❑ No Russell W.Frank$,SR. 198 SE Pearl Terrace "Al 3. S rvicNc*i V"' lake City,FL 32025-1865 ;9 Certified-gaTi "'?Express Mail 13 Registered P(Retum Receipt for Merchandise 0 Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) 0 Yes 2. Article Number 7012 3460 0003 0919 4946 (transfer from service label) PS'Form 3811,February 2064 Domestic Return Receipt 102595-02-M-1540 SENDER:COMPLETE THIS SECTION i COMPLETE THIS SECTION ON DELIVERY ■ Complete items 1,2,and 3.Also complete A. Si t item 4 if Restricted Delivery is desired. X E3 Agent ■ X ,Print your name and address on the reverse 11 Addressee so that we can return the card to you. B. Rec i e Na t Date ■ Attach this card to the back of the mailplece, eof Delivery or on the front if space permits. I 1� Article Addressed to: D. s delivery address different from item 1? 0 Yes If YES,enter delivery address below: 0 No Michel6jrTfanks 5/k/a Michele R.1.Franks 198 SE Pearl Terrace 3. S ice Type City,FL 32025-1865 Wcertified Mail 13—P1press Mail 0 Registered J25 etum Receipt for Merchandise 0 Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) El Yes 2. Article Number 7012 3460 0003 0919 4922 (rransfer ft rn service labe)-, PS Form 3811,February 2004 Domestic Return Receipt 102595-02-,M-1540' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - Sheriff z Jody S Smith 3a Chief Deputy , Richard W Stewart Solicitor OFFICE OF THE SHERIFF Freedom Mortgage Corporation Case Number vs. 2013-2121 Russell Franks, Sr. (et al.) SHERIFF'S RETURN OF SERVICE 06/10/2013 Ronny R. Anderson, being duly sworn according to law, states he served the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Russel W. Franks, Sr. at 225 N.W. Spanish Oakds Circle,Apt 101, Lake City FL 32025 06/10/2013 Ronny R. Anderson, being duly sworn according to law, states he served the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Russel W. Franks, Sr. at 225 N.W. Spanish Oakds Circle,Apt 101, Lake City FL 32025 07/01/2013 07:37 PM - Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 591 Geneva Drive 19, Upper Allen -Township, Mechanicsburg, PA 17055, Cumberland County. 07/12/2013 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice of Sheriffs Sale and Legal Description by certified mail, return receipt requested, to the within named defendant, to wit: Russell Franks, Sr., by mailing a copy of the within documents to the defendant's last known address of 225 N.W. Spanish Oaks Circle,Apt 101, Lake City, FL 32055, on 7/1/13 The return receipt card was recieved by the Cumberland County Sheriffs Office on July 12, 2013 signed by Michele Franks on July 8, 2013. The return receipt card is hereto attached. 07/24/2013 Ronny R. Anderson , Sheriff,who being duly sworn according to law, states that he served the within Real Estate Writ, Notice of Sheriffs Sale and Legal Description by certified mail, return receipt requested,to the within named defendant, to wit: Michele R. Franks, a/k/a Michele R.I. Franks, by mailing a copy of the within documents to the defendant's last known address of 225 N.W. Spanish Oaks Circle,Apt 101, Lake City, FL 32055 on 07/03/13 The return receipt card was recieved by the Cumberland County Sheriffs Office on 7/23/13 signed by Michele Franks on 07/15/13. 09/04/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Kevin Diskin on behalf of Freedom Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,000.79 SO ANSWERS, October 03, 2013 RONR ANDERSON, SHERIFF /� LL7( /el- k c;CountySuite Sheriff (Teleosoft,Inc. (� %33 >b 01 a