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HomeMy WebLinkAbout13-5764 Supreme Court•of Pennsylvania Cou�of " Pleas Mfr, For Prothonotary Use Only: Civil'Cover, Docket No: TIIIf •S;, l Cumberland; �r , ._ County t� The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: 0 Complaint ❑ Writ of Summons ❑ Petition ❑ Notice of Appeal ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead PlaintifPsName: Lead Defendant's Name: T Members 1 st Federal Credit Union Richard K. Kanneg & Betty Jo Kanneg r ❑ Check here if you are a Self - Represented (Pro Se) Litigant O Name of Plaintiff /Appellant's Attorney: Karl M. Ledebohm, Esq. N Are money damages requested? : NYes ❑ No Dollar Amount Requested: within arbitration limits (Check one) x outside arbitration limits A is this a Class Action Suit? ❑ Yes 0 No Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Zoning Board S ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) Employment Dispute: ❑ Slander/Libeil Defamation Discrimination C ❑ Other: ❑Employment Dispute: Other T Judicial Appeals ❑ MDJ - Landlord/Tenant I ❑ Other: ❑ MDJ -Money Judgment O MASS TORT ❑ Other: ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non- Domestic Relations 0 Mortgage Foreclosure Restraining Order PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto ❑ Dental ❑ Quiet Title ❑ Replevin ❑ Legal ❑ Medical ❑ Other: ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 212010 OF Tfr �tPROTHONOTARY CUMBERLAND COU14TY PENNSYLVANIA Karl M. Ledebohm, Esquire P.O. Box 173 • `a New Cumberland, PA 17070 -0173 (717)938 -6929 MEMBERS ST FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. z : NO S ell! t'v RICHARD K: KANNEG a/k/a RICHARD KIRBY KANNEG and ' ' CIVIL ACTION — LAW BETTY .JO KANNEG a/k/a BETTY J. KANNEG DEFENDANTS MORTGAGE FORECLOSURE 'N A . ! ? NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED PTO OUR CLIENT. ANY INFORMATION OBTAINED FROM'YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action Within twenty (2O) days after this Complaint and Notice are served by entering a'written appearance personally or by attorney and filing in writing with the Court your defenses' or objections to the claims set forth against you., You are warned'that if you fail to do so, ilie case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY c l* )9)?- P-"-Ctb LA03 e Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 (717) 938 -6929 MEMBERS 1 sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: RICHARD K. KANNEG A/K/A RICHARD KIRBY KANNEG; and BETTY JO KANNEG A/K/A BETTY J. KANNEG; DEFENDANTS : CIVIL ACTION - LAW- MORTGAGE :FORECLOSURE COMPLAINT AND NOW, comes Members 1 St Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1 1. Plaintiff, Members 1 St Federal Credit Union ( "Members I"), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Defendants, Richard K. Kanneg a/k/a Richard Kirby Kanneg and Betty Jo Kanneg a/k/a Betty J. Kanneg (collectively "Defendants "), are adult individuals having a last known address of 203 North Baltimore Avenue, Mount Holly Springs, PA 17065. 3. On or about July 9, 2004, Defendants borrowed from and agreed to repay to Members 1 St ONE HUNDRED TWENTY -FOUR THOUSAND TWO HUNDRED FIFTY -THREE AND 05 1100 ($124,253.05) dollars (the "Loan "). The Loan is evidenced by a Closed -End Note, Disclosure, Loan and Security Agreement dated July 9, 2004 (the "Note ") executed and delivered to Members 1 st by Defendants. A copy of the Note is attached hereto as Exhibit "A" and made part hereof. 4. As security for the Loan, Defendants executed and delivered to Members lst a mortgage ( "Mortgage ") on all that certain real estate and improvements erected thereon situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, known and numbered as 203 North Baltimore Avenue, a/k/a 203 _and 205 North Baltimore Avenue, a /k/a 205 North Baltimore Avenue, Mount Holly Springs, PA 17065 (the "Property "). At all times relevant hereto, Defendants have been and continue to be the record and sole owners of the Property. A description of the Property is attached hereto as Exhibit "B" and made part hereof. 2 5. On or about July 16, 2004, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office at Mortgage Book 1873, Page 4022. A true and correct copy of the Mortgage is attached hereto as Exhibit "C" and made part hereof. 6. The Mortgage has never been assigned by Members 1 St and is still held by it as a valid and subsisting obligation of Defendants. 7. Pursuant to the terms and conditions of the Note, Defendants agreed to pay to Members 1 St weekly installments of principal and interest in the amount of at least $241.83, which amount was subsequently adjusted to $241.63, beginning on July 30, 2004 and continuing each week thereafter. 8. Defendants are in default of their obligations under the Note and the Mortgage as a result of Defendants' failure to make the weekly payments due to Plaintiff as set forth therein in the amount of $241.63 for September 7, 2012 and each week thereafter through September 27, 2013, as more particularly described, in part, in the Act 91 Notice attached hereto as exhibit "D" and made part hereof. 9. As a result of Defendant's defaults, Members 1 St caused to be given written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. seq., ( "Act 6 ") and in particular section 403 thereof, and of Defendants' rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. M. ( "Act 91 "), by letter dated August 22, 2013, addressed to Defendants via certified mail, return receipt requested. 3 A copy of the said notices is attached hereto as Exhibit "D" and made part hereof. 10. Simultaneously, Members 1 St caused to be forwarded to Defendants the same Notices as set forth in paragraph 9 above (the "Notices ") addressed to Defendants by United States mail, first class, postage prepaid, bearing the return address of Members 1 The Notices forwarded to Defendants in said manner have not been returned to the offices of Members P as undeliverable or otherwise. 11. Any and all applicable stay periods imposed under Act 6 and /or Act 91 have expired. 12. Defendants are indebted to Members 1 St in the amount of ONE HUNDRED FOUR THOUSAND NINETY -SEVEN AND 03/100 ($104,097.03) dollars itemized as follows: a. Outstanding principal $89,050.70 b. Interest to October 4, 2013 1,577.32 c. Late Fees 0.00 d. 2009 -2012 Real Estate Taxes 12,169.01 e. Attorney's fees 1,300.00 f. Total due to Members 1" $104,097.03 13. Defendants also agreed under the terms and conditions of the Note that in the event of default there under Defendants would pay, in addition to the amounts set forth in paragraph 12 above, costs incurred by Members 1 St as a result of the institution and prosecution of these legal proceedings. 4 14. The obligation owed to Members I" continues to accrue interest at the rate of $14.6141 per day through the date of payment and continues to accrue attorney's fees and costs. 15. Members 1 St is not seeking a judgment of personal liability (or an in personam judgment) against Defendants; however, Members I" reserves the right to bring a separate action to establish that right, if such right exists. If one or more of Defendants have received a discharge of personal liability in a bankruptcy proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the Property in accordance with Pennsylvania law. 16. As set forth above, Members 1 St has made demand upon Defendants to make payment of the amounts due to Members 1 St under the Mortgage and the Note. However, as of the date hereof, Defendants continue to fail and refuse to pay such amounts to Members 1St WHEREFORE, Plaintiff, Members 1 St Federal Credit Union, demands judgment, IN REM, against Defendants, Richard K Kanneg a /k/a Richard Kirby Kanneg and Betty Jo Kanneg a/k/a Betty J. Kanneg, in the amount of ONE HUNDRED FOUR THOUSAND NINETY -SEVEN AND 03/100 ($104,097.03) DOLLARS plus interest at the rate of $14.6141 per day, through the date of judgment entered on this complaint, and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage, and for 5 foreclosure and sale of the mortgaged property to constitute a judicial sale of the premises. Respectfully submitted, Date: /C2 - Karl ,. Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 Attorney for Plaintiff 6 CLOSED-END NOTE,D18CLOtiURE, tSr AN AND f F(`l1kITY AAkFF FNT 6000 Louise Drtvs,P.O.Box 40 001>1OA£96teWEANDADDRESS Mechanicsburg,PA 17055 RICHARD KKANNEO 0 OR7 SALT{MORE AVE ititu'irimireS„oe _- 6ER W&F 1"RIrI �,�- 5.99 NUM OflOE80RRWrER'S pP� OU AMNT B R CO-aORRO'yIFRE E 00 M ©FMD VARIABLE ❑ ANNUALPERCEN7AQE FINANCE CHARGE: AmoultFinancad:The amount ot Total ofPaymeMs;The amount RATE; The cost of your credit as a The dollar amount the,Credit WIR credit provided to you or on your YOU Will have paid after y9v have yearly rate.• cost you. behalf. made ail paymarb as scheduled, 6.00% e $ 84,367.39 • $124,283.08 e $ 10f1,620.68 e Variable Roy:II yourlean has a variable taus as Indicated above the Annual Percentage Rate may Incease dating the term of Ihls Imnsmion If the (IndatO changes.Tina txudV Imlon wN add a msruln of to the Index value.The rate will change mont*/on the first dsy ofthe month,The rate will never be higher than the moxlmum rata allowed by Ittw,andl wtfl never ho lose 91an, Any interest rate increases will result In more payments oft ba same amount For Example,If your loon was for 35,000 at 16%for 48 months and the Annual Percentage Rate Inveased by 2%after one year,the term d your ban would Increase by two month forced Ofolhooked,tholollo wetg epprles la your loan: Automatic PsymentDlaoounletl AaU Beaauaa you have agtacd fo mekayour reVwred monthly payments through sn automatic deduetrori tmm ya+r CherkbOlsavings ccounl,your ANNUAL PERCENTAGE RATE has been dcoounled by,20%.The/WNUAL PERCEpITAOE RATE tllsrf¢estl above!n the ANNUAL PERCENTAGE RATE box 4+ the Auiomal(e Payment Discounted Rala This rstawil unease by,2056)F you cease the subma¢o am arrangamura or IQ to molmatn ardflOwd funds In your account to cover the automatic payments.In such a case,the effect of the Increase will be to extend am farm your loon.For ewemple Ifgqopur Automallo Payment Discounted Rats it 10% m a 36,006.00 ban for 60 months and you come the automatic payment amangomonl your rate Wit lrrr:reeae to 10,20%,Riuilino In 1 additional payment. Varfable,Rata Prararrad Loalto.N yyour ban Is a variable role ban and you availry,for a prafined rate,your preferred discount Is taken at the time you take out your loan.This Indlat profam'd ANNUAL PEROENrAOE RATE will then vary emonit1yr1g to changges h the index(as disclosed above.Far exampe g a vataule rate loan's initlal ANNUAL j PERCENTAGE RATE b 12%at fie llme you lake ale loan,your hrllafprelarred ANNUAL PERCENTAGE RATE vri�ba NW%.Vour Initial preferred ANNUAL PERCENTAGE RATE tMg then very according to the Index,as disclosed N 11re"Verteb)e Rate'provision above, Plxad Rate Preferred Loans.If your ban Is a Usd rata loan and you quality for a preterred tale,your ANNUAL PERCENTAGE RATE Will be the preferred ANNUAL PERCENTAGE RATE disclosed above for as long as our rorched status remain ht tYBoct. Number of payments Amount of Payments Payment ROqueney When Psymenb Are Due p�ropperty ttlsurarics;You may ebtaill property InaUf6a TOM anyone you Ward a b acceptable to payer 770 $241.89 Weekly•Beginning 07/80/2004 coo credit union,If YOU get the Insurance from the credit union you wtiI pay wiles 1 $236,61 FinalDUe-On 07106120`19 $NIA 81¢urRyt Co a securing other loans with the credit union the goods or property other w0 also aetaae this loan,You arc giving a sacudtY Interest M heing pun:tleaed, C(onnorlbe); you shares sndlorpdaeyppoek in the credl union,and: X ry g bete cllarged a.lima(s.WitlS%Way«u�'edledulad paymeiil.0"Ai nok keN(o amount yaarrre�TWhreed deposit balonsee,V any. jINIAPa�� SN1A lung insurance: ymmt: YWt Pay,at• .You PY•P• You,+ a r a:rll sea n noM•Y ,wW-W a e• cam aaanae. Ina W1adula i prepgman rararlds errs Parraltac 8 IZA i AMOUNT FINANCED $ 124,253.06 Amount Paid tootharean your behalf'(Describe) AMOUNT GIVEN TO YOU DIRECTLY$ 98,824.00$"'o-o' To Mnede Lye $ TO $0.00 ToMllnssotoLN $ To AMOUNT PAID ON YOUR ACCOUNT$ 1 84,975.86 $ To $ TO $ To $oho To PREPAID FINANCE CHARGE $ 0.00$ To Atied8dalons $ TO ai ad goUams _ - 8EO1jKrrYINFF4RMATION AKw E MODEL PAR A,MIABtR E VALUE OTHER(Describe):208 NORTH BALTIMORE AVE MT HOLLY SPRINGS PA 17005 Du 7 p e ge S AMOUNT ACCOUNr NUhj8ER AMOUNT ACCOUNT NUMBER andlor Depo8ii8 of 1$ $ YOu strut drat tho lanns end oondilloru In the disclosure slatemerrl sad the loan emu aoatdlY agmemants loeetad m papa 2 N Bite document ahall apply to this Ion..If Mere I•more Ow one borrower,we agree that all Old condlflotts of No loea end eemltlly agreemente 00 00 loan shall it pp to both Jointly and severally You acknowledge that you have moetved a copy arts boo and saoutity agreerte.la and disclosure statemsrd.Cosigner;If you are alga{ng as voaWner,you aeknowladie racefpt orlhe nonce to co-slpner contained on paggZ RRO U DATE co- KER '0TH -0 ER ' 0.6IG ER DATE X. (SEAL) X (SEAL) ❑ CO-MAKER ❑•0 HE C]•'00-810MER DATE ❑ CO-MA OTHER OWNER[].•C SIGNER DATE X (SEAL) (SEAL) Q CO-MAKER O'OTHER OWNER 0-00-310KI'l DATE ❑ MMAKER 0"OTHER OWNER❑ •-CO.StONER DATE X (SEAL) X (SEAL) 'OntiRp�N�Ampwaa,Nee Aa•pt�+p,ee`rY.an110dwrWw••t nnHr arHawwnnp WaaYaw4raae6wr eel WMlaraiu h.a.taeglp naneq uneaa•a•aeaaMkaM1YnMean IW by you aloV4MUa4nhrnla Ww omdamknhariamn9r Y49h/fi Mmlr VVaWrr,ea In tlra saourWAONrmrnL'•OOilehEk Ua•n dehuarYeenalm(enmaytaW lnana,a4•tr.9alvm,threau.rte arenYMW eA amN diewlaa lnMTa guar anrrPhnae nulk•b WafoNlr•a itwwuuie=wa bewweae MYM. APPLICATION FOR GROUP CREDIT thISURANC£ ��hwvee))wsappfgt,g a nce coverage s) an aeranmpsY Ue reWV pram m n rr� F 1• ury nwN, m s�erppe t r. m(Wa1e romyl tt�r,llweltaWppumlraGe oufxWlsnhwre�xveUrol unLVyornnwasna requlraa In wtlatoaeebua6rmAw thall(wo)mry to-mtnloe al any ama. (go)uroamnnnad vxg2tlAflyorrM1116e i1Pncaron-cAOI m wa 9ba"ret°'na WNtlene l MM z°mucl bey lamwerod i�dtcohr�mine aryd(aar)e iOWSa�y roniins3 sncy ince Y�tS ND YE ado T I. µ(AppliceMsto lealwurance aWtaag•onWW14 you bs ceder see TO more achO&Wtayaftalty doled yourtoan? 1ou 0 ❑ 0X7 ❑ Ma omuLVU-'fddn9m,y�ouo hromr. vyo�ao;aoa�bewgen�rRwfcM urrm°reo erMakmeuldhavabae��iugr�anwewor In oor doe%Mffi=N�sad � ❑ DX ❑ a da.Mel+if rPd e�•p 76pratcir BYnrEma.sWvN08RdaledGmQ'm l73iUrrecleokaoo'ansrY elerytleeaaa euak6, ❑ hhNry(akl mdwen Nsaoeve rvm sraew to ew ba.tpnN out Wdl non Wlmerod.IFnpm-�pfmsdorlaroaer'Yes•bq.+aesm8,we WuWnd�oIrovdlagr•d m thdan b xels le ahrc a maYyg xtetwr N"oqan/afloe2yBlAG MVMhls hnet9 xlurinnameand bmmuoaedMra The~w dAU linayma�coWll an d�aof Bre bertm.Aay on vAw broaln ly nod Wahl alto dea•ud snyi aanrlGO nrpmy or otlror paroortmw sn gpot�neon TOr lulupme our atalenHM O}xraka b9 rryaBylYaaWaon arca/adOrlhe pt,rNPOaco mhleadhrp,lnformdlon oon�m{r..B8asYYhc�rnoloNal``hereto aomm{tao kentlulantlmurerwa acT w7tkhlaa crime earl aub)aote alrrdr taaon to edrT,trml ana eMlpanalUas po na[eynmW aPP'ralle.Ust�y dip cable epaaa an_ganK�ra•appnacbon win nor b•uNOlrt wmaat ll•a applkablo blankap¢wc have trot1»•a eomPfatsq Tina opptorha!no1919mdand dated the a&NOX09 and aUra•PP ks►not5ey1WInas d CREDIT INSURANCE APPU9D POP: NOTE:ONLY ONE APPLICANT MAY APPLY POR DMABILITYCOVERAGE. 1 I ❑Yea 0 No Single Credit Life j Total Premium ❑Yea [�] No Credit Disability Total premium EX]Yes ❑ No Joint Credit Life Indlcmowhich Opplic att(s): Z APPllcmd a C.Applloant; $4,20.03 Indicate which applkam(s): ❑ Applicant Qo-Apptload $0,00 You as wreml¢ fype.d opwarEstalar ts~a charge is In loded an this applaabea APPU fl DATE OF BiRTH DATE PL T'8 BIG UR DATE OK Elm, DATE X WITNESS 9EGONDAf2Y BENFAGMY(APPLICANT) CONOARY SCNEFIC Y(00-APPUCANT) MHGa9-4380-V A I&M-M-620a37 LA88"VORD F.437a6 R.Y.1101 oono1n10 CONN Sir ISO?Mbeeroto Muluel Omperfee,Ina AN dghb roaervcd. _.�. ,..�. .._. .,._. . _.. ..._,... Exhibit "q„ _...._.._.._.._, .�_. ._. RnaWERa IM-ANNUM, !A: NUMBER T60F RICHARD K )tM WG 07109M004 6N WWN7 VHE WORDS WED1T UNION' MEANS MEMBERS iST FEDERAL CRE01T UMON. THE MRDS'YOW 'yoUR' Ako - You RS MEAN THOSE LOAN AGREEMENT SECURITY AGREEMENT Pe t1Ce 119 s: For Malt a , flIved, yw p m se to ey, at 1. to eo a tmt of Ma I end aI a dtturos fr trot eredn Ihd Cra�(r ll or s ee Q11 emount due, lUt yrnerits steal {tram de uro�l�n n c on t Ih thPs �rr 6 anp mg o a sn�cvr� s N Ou a m tO 1 e dtst pre ststasrtem o0 Or tt+i,4 meat. ou a vn.n �,� �`,u t t pF'�a r� sDtnd �tthp drarga anft pa s on e t s .ppppg� a o a s ��me� rl , s asas � �r graDosed T Drin Itt a' all Nri'enls ue w on erasacue yono - elf €ai a t e If a the adredV ot ttlfUe eat( and , U hhaava qu lat3TTI sawre`�/ropen . art�(a��gd rote th8t u contlnIT to satisfy o f of that p alted Goss•w)1�t0 a l�,�, gtv as�5ac� t� for I Tai s Ioan or for orp. hole. if ou fal(IO q[ lnstallmont by the Hma l�s due, yell wll Pay ben HOr` mlie B`�ire,�,it,,y {rsec" edc0bl�el InWrest oh th�overdus am00nt � p o hl r �q s cUro�h(s�oen�suc rt ` � ry Allocation of payments and AddltlDnal Payments: P4Yme and mv�r s ° nd I r enc w sa the sa re cleft shall be a pppp lied In rile foil rider. any amounts past due, airy �e d dr{�er la at requ omenes ma , orato r*ngwrr�ase aatt&g dhtng, Includnp any prance premium; al:ecrr��gg1� htlarest fees or ch ? you a sa tbmof. aePortrenster IM cotleteml uidros you haw orrmanoocher�, oUtstanding pu rDld Payments made In addition to the �hu s r tvRlen �naem rtsgulariy schedalad paymame sfwll bb eppD6d in tha.same order• s you nm m tmt u nav 1e to ns sot mG(�e d at Imcrosts Prer Rate; u 9 for a prBf s old ratq es dlsGwod orl ge T of o r�iat o�ue Y io ° UIe C ,, ar�efcwG erN�I o tl0a9flellt Or M�� gg{NefOtt@tl late ad 68 In.YOu UCt0 l8fltl �garfiroWrrarMllw aAateral Whc Acs sgneottm.egr6omunt Dt V>e meellhe n �le dISCIU rIa 6' r a 1 t11e Pw�• rage and mast c {{ue to n rat osst��lt�ats In o�ue �o yep e. �Nou,�,1�a� a r�eaat ees,�nd ge m — pp A at or Seat: tt Iha a FE reteu to tomes rat n t ns, ourrotewl 61� pYfp` ° t`� ° e Ss°�mPmY r�cf8B8prgSB, thBraalOMay�BpX�ttl�ynoWtliisrmMglatehSeelt�e�r {oru�gaa yWX fin. YOpAfdnlse to eonN�Ua 41) a she lo au a r� (�, Bonn gWsta m yo k U n61 t a reo t ', preferred ratoUDrls tattler tl'115 Agmattrent even 1 0 N � parcy delmi un sr ost mr S. Yw ufJl Artam ]nsraa corm ve rde ar rpoa a wMcfr dro Late s; If yy ppUU metro o a I® pay L g agree to pay a late charge Y %I v un as s e sL @ace I a f nd e 6 analsd ` I9 &. " On . ocurn a� ao�I�an�dl a 1 wd P r ln , uproncortplf g u Ae secured p., Rotor Ve a a �S+s �� o I� an �f enrea(a�l muS18ln1 urance tihrrip ht acredt �S t awe motes a sn �}`tRs nw�iw ` un an t n ar�q g gs oovet a 1rH pp0lty cumsoro s h em t a m rmou� _wtLLttcr Ins ace {nust.be 8 �a t0 the c�atlit un {Orr. a �KY mGst� a to a on co f ats of at�`n�n at astfue, txm a ®Vona. s n coplsl �,F(9�,°n�°m a to eo tic a e rn s su t must w a e I a ygb1a dou se from nom na the e a uaance a tnosa to s o ro Ct 1 un as IItotpr holder You bM hr 1NS I�mur rice from an artt of � rr and datsLt the apem io credit ungon a copy oyt I y p p�then aun,ortca n,e seeaalntumntmlt� �ma���e yyaqw Irutvmue Servke Cerwl oYky. nttk the necessary ntorrmtfoa rot watlao�tfanor eoogaate wrerage, Debtor Res sfDllky, Yott�tt pppiiry00misg (p nod ��gdi tmbn 0j epy CtjOnpp in � vladOO ms�hmu an�o o net ysto the o� cad�ae M yO lt Hama ardT of O7ItpWVmen4 YQtI pppr 1 riot to 8pD14 Tdr r caBfl U u at[•Derco to you ua s pr er apt o krro l�1em Ss a retrs0ABt W1ty Uwl you writ De IIrfA are a to & the ad unbn I al on tlmUe s R sere Has I 4 o pL7 OO➢ga aC MI R c M COfoing l re ms.ol t o rx tt e ou xrbnston. a apla5� m �n veftro, or re Q rr��sawr uro0. yw Inform Cte u on of Uny n r nfrmiEt ot�h relarcg to our ebildy to �� > da w tavaac� F ay r obVp .You Pr a rset10 s else w IM we a' u ne�ssa m metre untpn a8o posy crC� ma�onnr Wtl It u ���eq atrmtbn regeraIngyou Cremtwo thinass, loss tt sterdtllg; or Itl t ups y. 7. o d os del nod tp ttW sAou a sbdgt hos efauiC Y u shag be torts red r do It Uarty Or the fa CC t�r 1) e ty aeon su cykLa �Y 14 esa en sc s oberer w uI P 1s Des p9 III mere ar. n � , wse, I n a Ueda pnktt 1rou broa an rpm trrtp l L n teem m or f re aamta t u�oiu a em wh he ro� aw Anr6amCSII or �? o ft tlo not use t�e money cr�d -12 to e e � �o rTf 1 1 111111-u eft to yours Icauav or 3) ti ae un h tw rrro rope u �tm Un U1 p m dk o w�at� on 8+c ear re co sera arrest t o (C 9 uU ed; o' II Gie: IX 5 �UIa. 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COSt6 o coUecdOrltJda� bGt are taques�t ass roD na r pro cro R not w W, toO� fe9s a rofs8ls, 8 ronmarrt�I site wPn l a Waee r s t B an utrton aai4�s to asSassslnonls, Cdsua smaO0 (rtsp} nee C to g9 Md tttttMnso foes for vtava�hb Oeraul, h wp�rot ale Wa any oNer aUDSeg an actlOn take0 by ah aU0rrt8 sl groat tQ factlh(s 1�rt pr preserve or e. 1tm cra bn aDpoNwd as AitorrwY At FatX letvel irgTn the Cr t s i ono r9mDtll05. lndudlrrA vRtltaUt lMatatlon ens tyrci r t} n ia rrowi l0oa are �t rte procaG ere c pit s pe>rl�nds fo pOYmont pp wslrA modtehon of set�lame rA sacumy er r tM cD a4reeme, s I ns, Iva I n pnt185aa5 u gm8rH O( la Cfotlqq (I7NaQ0Ss d g, , ty p f1 v A 4 pra l3 mote lyron one noMOr db eUora tnh apee��SCero ooaa Oil In b m st r g 9 , eprn a dl C `Inehidir�, ,IOMl eau sovor0l, eaeti ee�nq equell to luNll terms s ivhlro 'm , fill fl fn p s ofetWrrb puF.su47� fa @rmaaMS aareemami. eflTeenram Li tors, arra ufsuaiq ccoomm n rroUorts an I at testa If to a i hl t n d 1a ornmm rm orry Dwc6 you,'DUt yore e»3daors, adminbAatas, a o at�y yf8y 1 dl urti s ala p_( r hoot m era paymeU, collateral I 9 !_d gllgrA nen•berWtrDCY pttS� 8tlR9it ep p01 ���111111666 prmcJ Dandnceln 0efslat 51te 1 bear rm, and the r�Mra= tat& en: If ggttaaaut,tory roypuu era In dnfeult,1 Brae hrH a{vos Ore Clod'A Urtl ttm rinhtI abD IMD�mn h MdINV 0bdslnWLos Id��at UUf Te I � bb y �l o to s t it v�MlteAn�movce �`jpt° y are o all faulG the Cr t 9.7 tus f im�er n ihls" en inn vA hart i IreIII, of d o txadl I"a ularPa ants: IroCe oaf lOto a rASOr pal , I m , ov thoud �pnyrnen n� �rrp any bf Ua DtlTdll It rtgn 98 �1g ftry s lpp g ld r h1 9 tl5S Or( pre9m@n acO yyy D C � ag o �t��y k A a t r +� s ro i s n f y � o t�l u sfete wi111 Uf8 bOrtoWOr, but Wl IXu�pm�8te to • elUlet or 6or b( The des ottt>< iserm to that thh a� re� ` ro se arty sowrlry vAtt�ro ty�ng ra Bas np y u ro 0100 � Fasyponl t�b t t poncreetUal rkdge d 5hafnv: Ygy plodge dl you shm�ea and daoasDs 11 the Ueda Unlafr. Melud yD,Npr fuoaa addldorry ae n rot Uric login, to Cesa YOu dalatd4 the credhttrd8rs mqy�r * ftcsa atlnras end dappooshs to Um paymmnt ofall auma dw at the IArra ofdeteut4 lncludl rg costa MCO110CUon ad6 reasambte ariarrwys feoa. that dw UOdh uM troy Incur u r ''R f wa rnpafd pnne}fol ealna�nlyd truarest. Ho hewn rtolnto tmrness a 4la� on . prW R artte�ir u ron z r Aacb p 1017 oaogn Pla �arosVrtach may De Wd In a a TICE TO CO-SIGNER IEEE= rtt1 asked f tmrarY,ee s debt, TFVnk eorafutl Dp oresure yell ten aHbad to h09e to, an0 Utet yell want to eccaptllUs re atbility. ave to pay up to the iWl a rrrount of lfre deM 1 Itre borrowis this D rr agge�m borrQ oi�str as s p hlrrp��5 rl0tico is not the mmreGt Thal moHas you Na a fOr th6 debt. 1 F. 43769IM2 aiPRe Syrtams tee. aae•rola Page 2 of 2 1 ALL THAT CERTAIN LOT OF GROUND SITUATE ON THE WEST SIDE OF NORTH BALTIMORE AVENUE IN THE BOROUGH OF MOUNT HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, THE~ SAID LOT OF GROUND SPING BOUNDED AND DESCRIBED AS FOLL-OWS: BEGINNING AT A POINT ON THE NORTHWEST INTERSECTION OF SAID NORTH BALTIMORE AVENUE AND CHURCH STREET, THENCE ALONG SAID CHURCH 5TREE f' NORTH 89 DEGREES 59 MINUTES WEST, A DISTANCE OF 175.65 FEET TO AN IRON PIN IN THE EASTERN Slpl` OF A PUBLIC ALLEY; THENCE ALONG THE EASTERN SIDE OF SAID PUBLIC ALLEY NORTH 0 DEGREES 10 MINUTES WEST, A DISTANCE OF 80 FEET TO A POINT; THENCE ALONG THE LANDS OF S. J. HOZA SOUTH 89 DEGREES 59 MINUTES EAST, A DISTANCE OF 175.65 FEET TO A POINT IN THE WESTERN SIDE OF SAID NORTH BALTIMORE AVENUE; THENCE ALONG THE WESTERN SIDE OF SAID NORTH BALTIMORE AVENUE, SOUTH O DEGREES 10 MINUTES EAST, A DISTANCE OF 80 FEET TO A POINT, THE PLACE OF BEGINNING. THIS DESCRIPTION IS IN ACCORDANCE WITH A SURVEY MADE BYTHOMAS ALVIN NEFF, REGISTERED SURVEYOR, ON THE 5 T11 DAY OF MAY, 1970, A PLAT OF SAME IS ATTACHED HERETO AND MADE A PART HEREOF. BEING IMPROVED WITH A DOUBLE FRAME DWELLING HOUSE AND A FRAME GARAGE, KNOWN AND NUMBERED AS 203 AND 205 NORTH BALTIMORE AVENUE. Also known as 205 North Baltimore Avenue, Mount Holly Springs, PA 17065 Being the same premises which Edward O. Kanneg, Jr., by his deed dated May 13, 2003 and recorded in the Cumberland County Recorder of Deeds Office at Deed Book 257, page 92, granted and conveyed onto Richard K. Kanneg and Betty Jo Kanneg. Being Tax No.: 23- 32- 2336 -138 Exhibit "B" After Recording ReturnTot St fet P,ci'.I" , . :IEGLER ci i� iicv;lt .L.iS 4r DEEDS OOUNTY -PA MBMBBRS�i° 6 n� ISEDRI eH '04 JUL 16 AN 1Q SB " '!+ MECHANIC BURG, P 0 A 17066 MORTGAGE Made 07/09/2004 , Between 1 RICHARD K KANNI30 8s, 13ETTY JO KANNBG ` (hereinafter called "Mortgagor ") I And MEMBERS 1 FEDERAL CRE)DZT UNION ( hereinafter called "Mortgagoo ") Whereas, Mortgagor has.gxeolttcd and delivered to Mortgagee a certain Mortgage Note (hereinafter called the "Note ") of even date herewith, payable to the order of Mortgages in the principal awn of 124,253,05 , lawful money of the United States of America, and has provided therein for payment of any additional moHeya loaned or advanced thereunder by Mortgagee together with interest thereon at the rate provided in the Note, in the manner and at the times therein set forth and i containing certain other terms and conditions, all ofwhioh are speclflcally Incorporated herein 6y reference; Now, Therefore, Mortgagor, In cpnsideration of said debtor principal sum and as security far the payment ofthe same and interaat"es aforesaid, together with all other surna payable hereunder or under the terms of the Note, does grant and convey unto Mortgagee, ' All that certain property of the Mortgagor locatod In MTHOLLY SPRINGS AORO iGF7 ` Cumberland only, Pennsylvania DEED DATED 6-13-03 BOOK 267 PAGE 82 i a i which currently has the address'of . 205 NORTH BALTIMORE AYE MT HOLLY SPRINOS Perinsylvanla [street] 170 5 [City) [Zip Code] Together with the buildings and Improvements erected thereon the appurtenances thereunto belonging and the reversions, remainders,. rents, Issues and profits, tjtera0E To Have and To Hold the.-same unto Mortgagee, Its successors and assigns, forever. Provided, However, That If Mortgagor shall pay to Mortgagee the afurwaid debt or principal sum, Including additional loans or advances and all other su is payable by Mortgagor to Mortgagee hereunder and under the terns oftho Note, together with Interest thereon, and shall. keep and potform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become Vold. AcatNa APPID 71868 Bff 1673P�40•22 Exhibit "C" i This Mortgage is executed and delivered subject to the following ooveaants, conditions and agreements: (1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any future Loans or advances that may be made by Mortgages to Mortgagor at any time or times hereafter and Intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt f2) From time to tfma until Raid debt and interest are fully paid, Mortgagor shall: (a) pay and dischharge, when and as the same Well become due and payable, all taxes, assessments, sower and water i rents, and all other charges and claims assessed or levied from time to time by any lawtltl authority upon any part ofthe mortgaged and -which shall or might have priority in lien or payment to the debt sacarod hereby, (b) pay all ground' rents reserved from the mortgaged premises and pay and discharge all . l mechanios' liens whioli may be filed against said premises and which shall or might have priority in lion or payment to the debt secured hereby, (o) pay and discharge any documentary stamp or other tax, f Including Interest and penalties thereon, If any, now or hereafter becoming payable on the Note l evidencing the debtaccured hereby, (d) prov(do, renew and keep alive by paying the neoossary promiume and charges thereon such policies of hhazard and liability Insurance as Mortgagee may from time to time require upon the bu[Idfngs end lmproveroante now or beraatber erected upon the mortgnged premises, W"' loss a oblo clauses In favor of Mortg$agor and Mortgagee as their respective tntereats may aapppear, j end (e) promptly aubmitto Mortt evidence of iha doe end punctual payment of all the fdregoing charges; provided, however thatZvIatgagea may elite option faqulre that auras euffloiantto discharge the foregoing charges be pad In installments ta Mortgagee. E (3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage In good and { substantial repair, as determined by Mortgagee, Mortgagee shall have the right to enter upon the mortgaged promises at any reasonable hour for the purpose of Inspecting the order, condition and repair t of the buildings and Improvements erected thereon, (b) In the event Mortgagor neglects or refoses to y the charges mentioned at(2) above, or Ihils to I maintain the buildings and Improvements as aforesaid, Mortgagee may do so, add the cost thereofto the 1 principal debt secured herc�*end colleot the some as a part of said principal debt { a j and•a permit part rt 5 aged Mortgagor an d or oovenan eb llen qr charge t which would be ior to, or on a parr it with lion mortgaged of this Mortgage. gp �' Y tr r 0 P , parity , th , (6) In case default'be mare for the space of thirty (30) days in the payment of any installment of principal or interest purauan, td'th6'taims oftho Note, or In the parformance Mortgagor of any of the other obligations oftheNotd br'thia Mortgago, the entire unpaid balance of sai d principal sum, additional loans or advances and all oth8r'IJnfs paid by Mort to pursuant to the terms of the Note or this Mortgage, together with unp9ld'Ititarest thereon, shallf othhe option of Mortgagee and Without notice become Immediately due and'pp aa�Able, and foreolosure proceedings may be brought forthwith on this Morigago and prosecuted to jddgrriont, execution and sale for the ooileotion of tho sari, together with I costs ofsuit hnd an attorney's o6mtnlasion for collection of five percent (5 1 /6) of the total indebtedness or $200, whichever is the larger aniottnt Mortgagor hereby forever waives and releases all errors In said proceedings, waives stay of oxeoutlon, the right of Inqquisition and extension of time of payment, agrees to oondetnnation of any patty levied upon by vhtuo of any such execution, and waives all exemptions i from levy and sale of any proporty lthat now is or hereafter may be exempted by law. ! (7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void, .Aftersuoh occurrence, Mortgagee shall discharge and satisfy this Mortgage. i Mortgagor shall pay any rccordott6n costa. Mortgagee may charge Mortgagor a fee for releasing this Mortgage, but only Ifthe fee•liTald•to athird party for services rendered and the charging ofthe fee Is permitted under Applicable Law. The covenants, oondltions'andagreemonts eontahmd In (his Mortgage shall bind, and the benefits shall Inure to, the reapeetivo parties hereto and their respective heirs, executors, administrators, successors and assigns, and If this Mortgage Is executed by more than one party, the undertakings and liability of each ; shall, be joint and several, ..., .� .., Amino jjjjl@!M+ Appr 71869 �1f i 873PG4G23 Witness the due execution horeofthe day and year first above written. Y Commonwealth ofPennsylvarrin ssa ' County of CtVIBE111M ) On this, the 9 day of 2004 , before �Bpr�P.an J orl . "�ieundersigned officer,personallyappearod VANNM satisfactorily proven to Me to be lho person (a) wb�ose nam s) Islam subscribed to the within ov7Trtgaga, and acknowledged that { he /she executed the same for the purposes therain'contained. S In Witness W hereof, l hereunto aet my hand and official semi. I 1 My commission expires: olactat 8eai tsodean Worley, Nota Publfo t owar Allepp wp, Comhada County f My mmtssfon SR5 Mar, 7, 8005 Member FemO4nkAswdellonotNoMes ! �0rtiflcate Qj itavfdenee oflVlortoar!no Members Isr Federal Credit Union, Mortgagee within named, hereby certifies that its residence ! Is 5000 Louise Drlve, Meohani -�vrg, PA 17055. I I Certify this - to lit; tecoxtled in Cumberland Cou>ity PA Recorder of Deeds I I A%iNo App1D U& BIB f87.3P64Q 4 (Rev. 912008) Date: August 22, 2013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This iS an official notice that the mortgage on your home Es in default and the lender intends to foorgc ose Specific information about The nature of the default is grovided in the attached pages The HO ME!QWNER's EMERGENCY MORTGAGE A I T NCE PROGRAL4 E A maybe able to help to save Xour home This Notice explains how the program works see if HEMAP can ust MEET WITH A CONSUMER CREDIT COUNSELI AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you &hen you meet with the Counseling Agency The name, address and phone number of ConsgMer Credit Counseling Agencies serving youE CountX are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800- 342 -2397. (Persons with impaired _ Baring can call (717) 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRtSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. — — -- p 1 of S - Exhibit "D" HOMEOWNER'S NAME(S): RICHARD K KANNEG BETTY JO KANNEG PROPERTY ADDRESS: 203 N BALTIMORE AVE MT HOLLY SPRINGS, PA 170650000 LOAN ACCT. NO,: ORIGINAL LENDER: Members 1' Federal Credit Union CURRENT LENDER/SERVICER: Members 1" Federal Credit Union HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL. ASSISTANCE WHICH CAN SAUC YOUR HQME FROM FORECLOSURE AND HELE YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: _ • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY dTAY OF FORFCLQ5 -UI2F. -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice, THIS ME, E,ETIN MUST OCCUR WITHIN THIRTY -THR 4, {, (33) DAYS OF THE DATE, OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING ArEN T,S — If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting, The names, addresses and telephone numbers of designated consumer credit 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 of your intentions. ® PLI .AT1M_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 lender from filing a foreclosure action, your application MUST be forwarded to PFIFA and received within thirty (30) days of your face -to -face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A .MEETING WITH A i COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AN D FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Page 2 of 5 AGENCY. ACTION -- Available fiends for emergency mortgage assistance are very limited. They will be. disbursed by the Agency under the eligibility criteria established by the Act, The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE .DEBT. (If you have Bled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MQRTGAGE DEFAULT (Bring it UR to date) NATURE OF THE DEFAULT - -The MORTGAGE debt held by the above lender on your property located at: 203 N BALTIMORE AVE NIT HOLLY SPRINGS, PA 170650000 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $114.10 for September 7, 2012, $241.63 for each weekly payment for 49 weeks *om September 14,2012 to August 16, 2013 Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $11,953,97 B. YOU HAVE FAILED TO TARE THE FOLLOWING ACTION ( not use if not applicable) HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 11,953.97 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pgymments must be made either by cash, cashier's check,_ certified check or money order made payable and sent to: Members I Federal Credit Union, ATTN: 1.xnn Unger j 5000 Louise Drive Mechanicsburg, PA 17055 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable Page 3 of 5 1E XQU DO NOT CURE THE DEFAULT _ -If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends exercise its rights ,10 accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon y„ ux modgaged nrouer�tw IF THE MORTGAGE 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 care the default within the THIRTY (30) DAY ern iod, Xott will 1 he regpired to pay attorneX'g fees OTHER i,F, MER REMEDITS -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage, RIGHT TO CURE. THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You mU 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 aLiy 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 POSSIJIL , SHERIFF'S SALE DAI -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately Three (3) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. j HOW TO CONTACT THE LENDER: ! Name of Lender: Members 1 s t Federal Credit Unign Address: 5000 Louise Drive Mechanicsburg, PA 17055 I!hQne NjImbere (717)795-5188 o[ (800) 2832328 Ext 5188 Fax Number: (7121795 -5207 Contact Person: Lynn Unger E-Mail Address: ungerQ�mem hers .Ist.org rrFE CT_OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 5 YOU MAY ALSO HAVLJ 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. CON5U,MLi RCREDIT COUNSELING AGENCIES SERVING YOUR COUNTY i1l in s lkt of Counseling A e ties listed in en x C. I' R THE COU n hi h the r e t i located, using additional naees if necessarEk Certified Mail # 9171999991703178343947 i Page 5 of 5 X011 MAY ALSO HAYL4 'SHE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, •` TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONS u MER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ii l in -Co ns li A e c'e A d F U t o e IU located (gjag additionaljiages_if necessarvl Certified Mail # 9171999991703178343954 Page 5 of 5 Servicemembers Civil U.S. Department of Housing MB Approval No. 2502 -0566 Relief Act and Urban Development (exp4/30/2007) Notice Disclosure Office of Housing Legal Rights ad Protections Under the SCRA Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act (50 USC App, §§ 501 -596) (SCRA), Who Be Entitled to Legal Protections Vnder the SCRA? ♦ Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard, and active service National Guard; ♦ Active service members of the commissioned corps of the National Oceanic and Atmospheric Administration; ♦ Active service members of the commissioned corps of the Public Health Service; ♦ United States citizens serving with the armed forces of a nation with which the United States is allied in the prosecution of a war or military action; and ♦ Their spouses. What Legal Protections Are Servicemembers Entitled To Under the SCRA? The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent during the period of military service. ♦ The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days after the servicemember's military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate. ♦ The SCRA contains many other protections besides those applicable to home loans. IL]Zgs A Ser- Acemember or Dependent Request Relief Under the SCRA? ♦ In order to request relief under the SCRA, a servicemember or spouse, or both, must provide a written request to the lender, together with a copy of servicemember's military orders. The Lender providing this Notice is Members I" Federal Credit Union, AT. TN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The phone number is toll free (800) 283 -2328. How Does a Servieememhgx or Dependent Obtain InforMation_About the SCRA? ♦ The U. S. Department of Defense's information resource is "Military OneSource ". Website: hQ: / /www,militgaonesource.com The toll free telephone number for Military OneSource are: • From the United States: 1 -800- 342 -9647 • From outside the United States (with applicable access code): 800 -3429 -6477 • International Collect (through long distance operator): 1- 484 -530 -5908 ♦ Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal assistance office locator for all branches of the Armed Forces is available at littp.Hlegalassistaiice.law.af.mil/content/lorator.12hp form HUD -92070 (2/2007) ' �_ Comprehensive Housing PENN+SY1VA ff 5 - RG ^ FIhtANGE .AG11tCY Counseling Agencies Agencias de Consejo al Ciiente para Vivienda Cumberland County "CCCS of Western PA - York 55 Clover Hill Road Dallastown PA 17313 886.511,22271888.511.2227 www.ccc S sna.orc Community Action Commission - Capital Region 1514 Derry St Harrisburg PA 17104 717.232,9757 www. cacidcounto. ora Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717,238,9540 Housing & Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle PA 17013 866,683.5907 / 717,249.0789 www.cohra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www.rurallso.org/pDibBlgna_pA Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1618 www.adarnscha.orc f I NOTE: Many of the agencies offer workshops at various locatio si tes; call to find a location near you. Report last updated: 4/30/2012 9:03 :04 AM � Page 1 of 1 02/0/2006 07:49 7179320317 KARLLEDEBOHM PAGE 10/10 MEMBERS IST FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. NO.: RICHARD K_ KANNEG A/K/A. RICkJA,RD KIRBY KANNEG; and BETTY JO KANNEG A/K/A BETTY J. K„A.NNEC : DEFENDANTS : CIVIL ACTION -LAW- MORTGAGE :FORECLOSURE VERIFICATION I, Lynn Unger,,Bankruptcy Specialist for Members I' Federal Credit Union, being authorized to do so on behalf of Members 1 °t Federal Credit Union, b.ereby verify that the statements made in the foregoing pleading are true and correct to the best of my information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. Members l Federal, Credit Union Date: September, q , 2013 By Lyn nger, Bankruptcy Specialist i 4 7 Pt " t! #70idCt OC T — 4 01 Karl A Ledebohm, Esquire P.O. Box 173 f t # . � r ly� r i s� 41Ut'1' New Cumberland, PA 17070 -0173 F F r 3 y (717)938 -6929 MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: RICHARD K. KANNEG aWa RICHARD KIRBY KANNEG and CIVIL ACTION — LAW BETTY JO KANNEG a/k/a BETTY J. KANNEG DEFENDANTS MORTGAGE FORECLOSURE NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respec 11 su ed, Date: October 1, 2013 C arl . Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717) 938 -6929 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City; State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? TINANCIAL - INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed,: Value: Other transportation (automobiles boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. 2. 3. Additional Income Description tot wages): 1 • monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Pa meats Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. SEending Mone Da /Child Care/Tuit. Other Ex enses-- Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION ti I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Y Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriffs 4ar ,p�, ( r qtr �, si>.� Jody S Smith rx, r,3 Chief Deputy 1� '': m.. :1Y:41A 3, [l Richard W Stewart r Solicitor r,','fi,C ,,,rw:, SA.ER1€ f PEN I L, t a Members 1st FCU vs. Case Number Richard Kanneg (et al.) 2013-5764 SHERIFF'S RETURN OF SERVICE 10/08/2013 09:00 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Betty Kanneg, 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 203 North Baltimore Ave., Mt. Holly Springs Borough, Mt. Holly Springs, PA 17065. Deputies were advised by Richard Kanneg that the defendant has moved to 163 Johns Lane, Bunn, North Carolina 27508. 10/08/2013 09:05 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Richard Kanneg at 203 North Baltimore Ave., Mt. Holly Springs Borough, Mt. Holly Springs, PA 17065. C--- 0.1.4.7Y% g .DAWN KELL, DEPUTY 10/09/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 203 North Baltimore Ave., Mt. Holly Springs Borough, Mt. Holly Springs, PA 17065. There are no other Occupants other than defendant Richard Kanneg. SHERIFF COST: $73.37 SO ANSWERS, October 09, 2013 RONiR ANDERSON, SHERIFF ,,,Coi1tvSi `e- 1,f'Ted,,osoii :.._. Members 1St Federal • IN THE COURT OF COMMON PLEAS Credit Union : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff • • v. : Docket No. 13-5764 Richard K. Kanneg and 07)r M-o Betty Jo Kanneg .• : CIVIL ACTION- - Defendants : MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of MidPenn Legal Services on behalf of the Defendant, Richard K. Kanneg, in the above matter,representing the Defendant in the Cumberland County Residential Mortgage Foreclosure Diversion Program. Respectfully Submitted, MIDPENN LEGAL SERVICES DATE: o f- ø(3 (44.1_4_ me M. Haley, Esquire Attorney for Defendant Supreme Ct. ID #205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 Members 1st Federal : IN THE COURT OF COMMON PLEAS Credit Union : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff . V. : Docket No. 13-5764 =-- Syr ca • --<- -- Richard K. Kanneg and • ' wi, Betty Jo Kanneg : : CIVIL ACTION- �=m Defendants : MORTGAGE FORECLOSURE REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012, governing the Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned hereby certifies as follows: 1. Defendant is owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. • 11111ia ......t......./ --1--e" , 01201-/ i o is( /7.0(_. Signa ure of Defendant's Counsel/Appoi ted Date Legal Re eresentative /0/31//3 Signature of Defendant Date l 'f Members 1st Federal : IN THE COURT OF COMMON PLEAS Credit Union : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. : Docket No. 13-5764 • • Richard K. Kanneg and • Betty Jo Kanneg : CIVIL ACTION- Defendants : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendant, Richard K. Kanneg , hereby certify that I am serving a copy of the Praecipe for Entry of Appearance and Request for Conciliation Conference on the Plaintiff, through their attorney, on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Karl M. Ledebohm,Esq. P.O.Box 173 New Cumberland, PA 17070-0173 MIDPENN LEGAL SERVICES DATE: f (-3((20 (3 C 6644, Jai 0:706644, e M. Haley, Esquire Y q Attorney for Defendants Supreme Ct. ID #205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 Members 1St Federal : IN THE COURT OF COMMON PLEAS Credit Union : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff • v. : Docket No. 13-5764 K. Kanneg and f,l c Betty Jo Kanneg • • : CIVIL ACTION- `_. r--"; • Defendants : MORTGAGE FORECLOSURE c;- . rfl PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of MidPenn Legal Services on behalf of the Defendant, Richard K. Kanneg, in the above matter, representing the Defendant in the Cumberland County Residential Mortgage Foreclosure Diversion Program. Respectfully Submitted, MIDPENN LEGAL SERVICES DATE: 16 tz0(f (3 n� / �= `I,' , J ime M. Haley, Esquire Attorney for Defendant Supreme Ct. ID #205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 IL Members 1st Federal : IN THE COURT OF COMMON PLEAS Credit Union : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff : c ._ c.. v. : Docket No. 13-5764 n v Richard K. Kanneg and • Betty Jo Kanneg • �''_ co : CIVIL ACTION- Defendants : MORTGAGE FORECLOSURE CASE MANAGEMENT ORDER AND NOW, this GO'day of , 2013,the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a courts-o supervised• conciliation Conference on %1,l� 3 LW/Y at //..170/ in 6100,714,4„, 41/'/ GO `7 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made and may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. DISTRIBUTION: Jaime M. Haley, Esquire MidPenn Legal Services 401 E. Louther Street, Ste 103 Carlisle,PA 17013 For the Defendant rl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 For the Plaintiff 'ES o Lc L _Lir? OF THE PROTHO OTA.. Y 283 DEC ' 6 PM 3:23. CUMBERLAtdfl':CO�NTY PENNSYLVANIA Karl M.Ledebohm,Esquire P.O.Box 173 'New Cumberland,PA 17070 (717)938-6929 MEMBERS 11T FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. NO.: 13-5764 Civil Term RICHARD K. KANNEG a/k/a RICHARD KIRBY KANNEG and BETTY JO KANNEG a/k/a BETTY J. KANNEG CIVIL ACTION- LAW DEFENDANTS MORTGAGE FORECLOSURE RETURN OF SERVICE To the Prothonotary: A true and correct copy of the Notice of Residential Mortgage Foreclosure Diversion Program,Notice to Defend and Claim Rights and Complaint in Mortgage Foreclosure filed in the above captioned matter were served upon Betty Jo Kanneg a/k/a Betty J.Kanneg on November 19,2013 as set forth in the Affidavit of Service attached hereto as Exhibit"A"and made part hereof. AKb mitted, Date: December 4,2013 hm,E ID#59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff MEMBERS ls7 FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: 13-5764 RICHARD K. KANNEG A/K/A RICHARD KIRBY KANNEG; and BETTY JO KANNEG A/K/A BETTY J. KANNEG; DEFENDANTS : CIVIL ACTION-LAW-MORTGAGE AFFIDAVIT OF SERVICE OF NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM,NOTICE TO DEFEND AND CLAIM RIGHTS AND COMPLAINT IN MORTGAGE FORECLOSURE 1, FR o AF,6a yic. (Position)for Front Range Legal Process Service,being over 18 years of age,hereby swear and affirm that I have this � _day of A>��,��, try , 2013 at approximately ": A.M! M)(circle one) served the Notice of Residential Mortgage Foreclosure Diversion Program, Notice-'to Defend and Claim Rights and Complaint in Mortgage Foreclosure in the above captioned matter (copies of which are attached hereto) upon Betty Jo Kanneg a/k/a Betty J. Kanneg as follows (check and complete one): a. By personally handing said documents to an adult female acknowledging herself to be Betty Jo Kanneg a/k/a Betty J. Kanneg, the defendant in the above captioned matter at (6 p 3 Us {.I K. nom, NC, '2-%j)5 (address); or, b. By personally handing said documents to __ , an adult member of the family Betty Jo Kanneg a/k/a Betty J. Kanneg being her Exhibit „A„ ��.� (1) (relation status)at (address); or, C. By personally handing said documents to , an adult person in charge of the residence of Betty Jo Kanneg a/k/a Betty J. Kanneg at (address). �G�--- Date: 11�2t?�►3 _A�.?'�L)�. (print name) Sworn before me, a notary public this---ACr day of 1Q0\1Q-M6e Y' , 2013. My commission expires: 3z) l GIOVANNI PINEDA ' Notary Public tDurharn Co.,North Carolina My Commission Expires Aug,30.2Q#7 -7Z09-0) trtd? 117' /tt4 t dill tf,, '�'R `7 N !0 35 5 CUMBERL ND PENNSYLVANIA COUNTY Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 (717) 938 -6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Vs. : NO.: 13 -5764 Civil RICHARD K. KANNEG A /K/A RICHARD KIRBY KANNEG; and BETTY JO KANNEG A /K/A BETTY J. KANNEG; DEFENDANTS : CIVIL ACTION - LAW- MORTGAGE :FORECLOSURE MEMBERS 1ST FEDERAL CREDIT UNION Petitioner /Movant v. BETTY JO KANNEG A /K/A BETTY J. KANNEG; Respondent MEMBERS 1sT FEDERAL CREDIT UNION'S PETITION/MOTION FOR RULE TO SHOW CAUSE WHY PLAINTIFF SHOULD NOT BE GIVEN LEAVE OF COURT TO AMEND THE COMPLAINT IN FORECLOSURE FILED BY PLAINTIFF IN THE ABOVE CAPTIONED MATTER TO CONFORM TO THE 1 EVIDENCE AS TO DAMAGES AND TO REMOVE AS A PARTY DEFENDANT FROM THE COMPLAINT RICHARD K. KANNEG A/K/A RICHARD KIRBY KANNEG, NOW DECEASED, AND WHY THE PROTHONOTARY SHOULD NOT BE DIRECTED TO AMEND THE CAPTION TO REMOVE AS A PARTY DEFENDANT RICHARD K. KANNEG A/K/A RICHARD KIRBY KANNEG, PURSUANT TO Pa. R.C.P. 1033 AND NOW, comes Members 1st Federal Credit Union ("Members 1 st"), the Plaintiff/Petitioner/Movant in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and requests that a rule be issued upon defendant Betty Jo Kanneg a/k/a Betty J. Kanneg, to show cause why Plaintiff should not be given leave to amend the complaint in foreclosure filed by Plaintiff in the above captioned matter to conform to the evidence as to damages and to remove as a party defendant from the Complaint, Richard K. Kanneg a/k/a Richard Kirby Kanneg, now deceased, and why the Prothonotary should not be directed to amend the caption to remove as a party defendant Richard K. Kanneg a/k/a Richard Kirby Kanneg pursuant to Pa. R.C.P. 1033 and avers in support thereof as follows: 1. No attorney has entered an appearance on behalf of either Richard K. Kanneg a/k/a Richard Kirby Kanneg or Betty Jo Kanneg a/k/a Betty J. Kanneg (collectively herein "Defendants") and concurrence in this Petition/Motion of counsel could therefore not be sought. 2. No judge has ruled on any is,sue in the above captioned foreclosure action (the "Foreclosure") or any related matter. 3 On October 4, 2013, Members 1st filed the complaint in foreclosure against Defendants in the above captioned matter (the "Complaint") foreclosing the lien of the mortgage (the "Mortgage") identified in the Complaint as to the Property owned by Defendants known as 203 North Baltimore Avenue, a/k/a 203 and 205 North Baltimore Avenue, a/k/a 205 North Baltimore Avenue, Mount Holly Springs, PA 17065 (the "Property"). 4. After the filing and service of the Complaint upon Defendants, defendant, Richard K. Kanneg a/k/a Richard Kirby Kanneg, (sometimes hereinafter "Mr. Kanneg") died on December 13, 2013. 5. At all times relevant to the Complaint, Defendants held title to the Property as husband and wife as evidenced by the deed recorded in the Cumberland County Recorder of Deeds office at Deed Book 257, Page 92, which is incorporated herein by reference pursuant to Pa. R.C.P. 1019(g). 6. Upon the death of Mr. Kanneg, title for the Property vested automatically by operation of law in defendant, Betty Jo Kanneg a/k/a Betty J. Kanneg (sometimes hereinafter "Mrs. Kanneg") and Mrs. Kanneg remains the sole record owner of the Property. 7. For the above reasons, neither Mr. Kanneg nor his personal representative, heirs or devisees possess any interest in the Property and Members 1st is no longer required to name any of Mr. Kanneg, his personal representative, heirs or devisees as a party defendant in the Foreclosure pursuant to Pa. R.C.P. 1144(b) provided that Members 1st sets forth in the Complaint that Members 1st releases such person(s) from liability for the debt secured by the mortgage. 8. Members 1st hereby releases Mr. Kanneg his personal representative, heirs or devisees from liability for the debt secured by the Mortgage. 9. Since the death of Mr. Kanneg, Members 1st has received the proceeds from credit life insurance for Mr. Kanneg in the amount of $50,457.56 and has 3 applied same to the principal outstanding balance of the obligation evidenced by the Mortgage. 10. Additional sums have been incurred or expended on Defendant's behalf since the Complaint was filed and Defendant has been given credit for any payments that have been made since the date of the Complaint. The amount of damages to which Plaintiff is entitled is now in the amount of $45,216.26, calculated as follows: a. Principal balance $89,050.70 b. Less credit life insurance proceeds (50,457.56) c. Outstanding principal after credit life proceeds $38,593.14 d. Interest to March 3, 2014 3,595.54 e. Late Fees 0.00 f. Attorney's fees 2,844.71 g. Filing fees and sheriff's costs 182.87 h. Total due to Member 1st as of 3/3/2014 $45,216.26 11. Interest continues to accrue on the above obligation at the rate of $6.3335 per day and legal fees and costs also continue to accrue on the obligation evidenced the Mortgage. 12. Pursuant to Pa. R. C. P. 1033, Plaintiff requests leave of the Court to amended the Complaint to conform the pleading to the evidence set forth above and as attached hereto as Exhibit "A" and made part hereof and that the Prothonotary be directed to amend the caption to remove Mr. Kanneg as a party defendant to the above captioned matter. 4 WHEREFORE, Plaintiff respectfully requests this Court to issue a rule upon Defendant, Betty Jo Kanneg a/k/a Betty J. Kanneg, to show cause why Plaintiff should not be given leave to amend the Complaint to conform the pleading to the evidence as set forth on Exhibit "A" attached hereto and made part hereof and why the Prothonotary should not be directed to amend the caption in the Foreclosure to remove from the caption Richard K. Kanneg a/k/a Richard Kirby Kanneg as a party defendant. Respectfully bmitted, Karl Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 5 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 (717) 938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. : NO.: 13 -5764 Civil BETTY JO KANNEG A /K/A BETTY J. KANNEG; DEFENDANTS : CIVIL ACTION - LAW- MORTGAGE :FORECLOSURE AMENDED COMPLAINT AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1. Plaintiff, Members 1St Federal Credit Union ( "Members 1st''), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. Exhibit "A 2. Defendant, Betty Jo Kanneg a/k/a Betty J. Kanneg ( "Defendant "), is an adult individual having a last known address of 203 North Baltimore Avenue, Mount Holly Springs, PA 17065. 3. On or about July 9, 2004, Defendant and Richard K. Kanneg a/k/a Richard Kirby Kanneg (hereinafter "Richard Kanneg") borrowed from and agreed to repay to Members 1St ONE HUNDRED TWENTY -FOUR THOUSAND TWO HUNDRED FIFTY -THREE AND 05 /100 ($124,253.05) dollars (the "Loan "). The Loan is evidenced by a Closed -End Note, Disclosure, Loan and Security Agreement dated July 9, 2004 (the "Note ") executed and delivered to Members 15t by Defendants. A copy of the Note is attached to the original complaint filed in the above captioned matter on October 4, 2013 (the "Original Complaint ") as Exhibit "A" and made part hereof. 4. As security for the Loan, Defendants executed and delivered to Members 15t a mortgage ( "Mortgage ") on all that certain real estate and improvements erected thereon situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, known and numbered as 203 North Baltimore Avenue, a /k/a 203 and 205 North Baltimore Avenue, a /k/a 205 North Baltimore Avenue, Mount Holly Springs, PA 17065 (the "Property "). A description of the Property is attached to the Original Complaint as Exhibit "B" and made part hereof 5. On or about July 16, 2004, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office at Mortgage Book 1873, Page 4022. A true 2 and correct copy of the Mortgage is attached to the Original Complaint as Exhibit "C" and made part hereof. 6. The Mortgage has never been assigned by Members 1st and is still held by it as a valid and subsisting obligation of Defendants. 7. At all times relevant to the Original Complaint and the Mortgage, title to the Property was held by Defendant and Richard Kanneg as husband and wife as is evidence by the deed recorded in the Cumberland County Recorder of Deeds office at Deed Book 257, Page 92, which deed is incorporated herein by reference pursuant to Pa. R. C. P. 1019(a). 8. Richard Kanneg died on or about December 13, 2013 whereby, title to the Property vested in Defendant automatically by operation of law. 9. As of the date hereof, Defendant remains to sole owner of the Property. 10. Members 1st hereby releases Mr. Kanneg, his personal representative, heirs or devisees from liability for the debt secured by the Mortgage and Members 1St is therefore not required to name Mr. Kanneg as a party defendant in the above captioned matter pursuant to Pa. R.C.P. 1144(b). 11. Pursuant to the terms and conditions of the Note, Defendants agreed to pay to Members 1st weekly installments of principal and interest in the amount of at least $241.83, which amount was subsequently adjusted to $241.63, beginning on July 30, 2004 and continuing each week thereafter. 12. Defendants are in default of their obligations under the Note and the Mortgage as a result of Defendants' failure to make the weekly payments due to Plaintiff as set forth therein in the amount of $241.63 for September 7, 2012 and each 3 week thereafter through February 21, 2014, as more particularly described, in part, in the Act 91 Notice attached to the Original Complaint as exhibit "D" and made part hereof. 13. As a result of Defendant's defaults, Members 1st caused to be given written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. seq., ( "Act 6 ") and in particular section 403 thereof, and of Defendants' rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. semc. ( "Act 91 "), by letter dated August 22, 2013, addressed to Defendants via certified mail, return receipt requested. A copy of the said notices is attached to the Original Complaint as Exhibit "D" and made part hereof. 14. Simultaneously, Members 1st caused to be forwarded to Defendants the same Notices as set forth in paragraph 13 above (the "Notices ") addressed to Defendants by United States mail, first class, postage prepaid, bearing the return address of Members 1St. The Notices forwarded to Defendants in said manner have not been returned to the offices of Members 1st as undeliverable or otherwise. 15. Any and all applicable stay periods imposed under Act 6 and/or Act 91 have expired. 16. Defendant is indebted to Members 1st in the amount of FORTY -FIVE THOUSAND TWO HUNDRED SIXTEEN AND 26/100 ($45,216.26) dollars itemized as follows: a. Outstanding principal after credit life proceeds $38,593.14 b. Interest to March 3, 2014 3,595.54 c. Late Fees 0.00 d. Attorney's fees 2,844.71 e. Filing fees and sheriff's costs 182.87 f. Total due to Member 1St as of 3/3/2014 $45,216.26 17. Defendant also agreed under the terms and conditions of the Note that in the event of default there under Defendants would pay, in addition to the amounts set forth in paragraph 16 above, costs incurred by Members 1St as a result of the institution and prosecution of these legal proceedings. 18. The obligation owed to Members 1St continues to accrue interest at the rate of $6.3335 per day through the date of payment and continues to accrue attorney's fees and costs. 19. Members 1St is not seeking a judgment of personal liability (or an in personam judgment) against Defendant; however, Members 1St reserves the right to bring a separate action to establish that right, if such right exists. If one or more of Defendants have received a discharge of personal liability in a bankruptcy proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the Property in accordance with Pennsylvania law. 20. As set forth above, Members 1St has made demand upon Defendant to make payment of the amounts due to Members 1St under the Mortgage and the Note. 5 However, as of the date hereof, Defendant continues to fail and refuse to pay such amounts to Members 1St WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment, IN REM, against Defendant, Betty Jo Kanneg a/k/a Betty J. Kanneg, in the amount of FORTY -FIVE THOUSAND TWO HUNDRED SIXTEEN AND 25/100 ($45,216.25) DOLLARS plus interest at the rate of $6.3335 per day, through the date of judgment entered on this complaint, and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage, and for foreclosure and sale of the mortgaged property to constitute a judicial sale of the premises. Date: 3 _ r_ 20/9 6 Respectfully submitted, / arl M. Ledebohm, Esq. / Supreme Court ID # : 59012 l P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 Attorney for Plaintiff 02/26/2014 15:30 7179320317 KARLLEDEBOHM PAGE 14/14 MEMBERS 1.ST FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA V. NO.: 13-5764 Civil BETTY JO KANNEG A/KJA BETTY J. KANNEG; DEFENDANTS : CIVIL ACTION-LAW-MORTGAGE ; FORECLOSURE VERIFICATION I, Lynn Unger, Bankruptcy Specialist for Members Id Federal, Credit Union, being authorized to do so tin behalf of Members 1 d Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and comet to the best of my information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities, Members l Federal Credit Union Date: February, 2014 By Lyn U nger, Bankruptcy Specialist 7 O2/26/214 15:30 7179320317 KARLLEDEBOHM PAGE 07/14 MEMBERS 01 FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Vs. : NO.: 13-5764 Civil RICHARD K. KANNEG A/K/A RICHARD KIRBY KANNEG; and BETTY JO KANNEG A/K/A BETTY J. KANNEG; DEFENDANTS ; CIVIL ACTION-LAW-MORTGAGE ; FORECLOSURE MEMBERS 18T FEDERAL CREDIT UNION Petitioner/Movant V. BETTY JO KANNEG A/K/A BETTY J. KANNEG; Respondent VERIFICATION I, Lynn Unger, Bankruptcy Specialist for Members 1" Federal Credit Union, being authorized to do so on behalf of Members 1" Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswoni falsification to authorities, Members I Federal Credit Union Date: February 2014 By Lynn nger, Bankptcy Specialist 6 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF v. : NO.: 13 -5764 Civil Term : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA RICHARD K. KANNEG a/k/a RICHARD KIRBY KANNEG and BETTY JO KANNEG a/k/a BETTY J. KANNEG DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 6th day of March, 2014, I served a true and correct copy of the foregoing Plaintiff's Motion/Petition for Rule to Show Cause and the proposed Order in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Betty J. Kanneg 203 North Baltimore Avenue Mt. Holly Springs, PA 17065 Date: March 6, 2014 'tted, Karl M. Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 FLED-CiFFICE CE THE PRO THONO TARY 2OILR 1 1 PM 3: 53 CUMBERLAND COUNTY PENNSYLVANIA Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO.: 13-5764 Civil RICHARD K. KANNEG A/K/A RICHARD KIRBY KANNEG; and BETTY JO KANNEG A/K/A BETTY J. KANNEG; DEFENDANTS : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE MEMBERS 1ST FEDERAL CREDIT UNION Petitioner/Movant v. BETTY JO KANNEG A/K/A BETTY J. KANNEG; Respondent ORDER AND NOW, this j )" day of , 2014, upon consideration of the foregoing motion, it is hereby ordered that: (1) a rule is issued upon the Respondent to show cause why the Movant /Petitioner is not entitled to the relief requested; (2) the Respondent shall file an answer to the petition within twenty (20) days of service upon the Respondent; (3) the motion/petition shall be decided under Pa. R.C.P. No. 206.7; (5) argument shall be held . .. • . se if /'C.•j u4. Md 67 Q °"~'� (6) notice of the entry of this Order shall be provided to all parties by the Petitioner /Movant. Defendant: tty J. Kanneg 203 North Baltimore Avenue Mt. Holly Springs, PA 17065 By the Court: Legal Counsel for Members 1St Federal Credit Union: �I�arl M.Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 Cp ES' /7Z 3 1/114{ Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF v. RICHARD K. KANNEG a/k/a RICHARD KIRBY KANNEG and BETTY JO KANNEG a/k/a BETTY J. KANNEG DEFENDANTS : IN THE COURT OF COMMON 1.4.q,EAS : CUMBERLAND COUNTY, -7- : PENNSYLVANIA -- 1 6 rri 7,670 r-- : NO.: 13-5764 Civil Tenn : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE MEMBERS 1 ST FEDERAL CREDIT UNION Petitioner/Movant v. BETTY JO KANNEG a/k/a BETTY J. KANNEG Respondent CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 14th day of March, 2014, I served a true and correct copy of the attached Order in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Betty J. Kanneg 203 North Baltimore Avenue Mt. Holly Springs, PA 17065 Date: March 14, 2014 edebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 1:15:.n-OFF-f7 THE i'=FXTHONG IA:Vf 2011111AR 1 PM Fi 0 C[E..IBERLAND COUNTY PENNS YLVANIA Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA. 17070-0173 (717) 938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Vs. : NO.: 13-5764 Civil RICHARD K. KANNEG A/IC/A RICHARD KIRBY KANNEG; and BETTY JO KANNEG A/K/A BETTY J. KANNEG; DEFENDANTS : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE MEMBERS 1ST FEDERAL CREDIT UNION Petitioner/Movant v. BETTY JO KANNEG A/K/A BETTY J. KANNEG; Respondent ORDER AND NOW, this 1 / day of ►ev)a,re..k , 2014, upon consideration of the foregoing motion, it is hereby ordered that: (1) a rule is issued upon the Respondent to show cause why the Movant /Petitioner is not entitled to the relief requested; (2) the Respondent shall file an answer to the petition within twenty (20) days of service upon the Respondent; (3) the motion/petition shall be decided under Pa. R.C.P. No. 206.7; (5) argument shall be held • - • • • • se 71- - Mg 67 (6) notice of the entry of this Order shall be provided to all parties by the Petitioner /Movant. Defendant: Betty J. Kanneg 203 North Baltimore Avenue Mt. Holly Springs, PA 17065 By the Court: Legal Counsel for Members 1st Federal Credit Union: Karl M.Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF v. RICHARD K. KANNEG a/k/a RICHARD KIRBY KANNEG and BETTY JO KANNEG a/k/a BETTY J. KANNEG DEFENDANTS : IN THE COURT CdiC.911 �V'PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 13-5764 Civil Term : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE MEMBERS 1ST FEDERAL CREDIT UNION Petitioner/Movant v. BETTY JO KANNEG a/k/a BETTY J. KANNEG Respondent PRAECIPE TO SETTLE, DISCONTINUE AND END To the Prothonotary: Please mark the docket in the above captioned matter as settled, discontinued and ended. Date: May 20, 2014 Res . - tfu submitted, r\ IP arl Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929