Loading...
HomeMy WebLinkAbout13-5979 Supreme Co i; ; ennsylvania COUr »O &CO fleas For Prothonotary Use Only: G i erJS` f Docket No: ts. CU .8— R Nb` County 13 - IY 1 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: S [E Complaint E! Writ of Summons ' Petition Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: CITIMORTGAGE, INC., SUCCESSOR BY MERGER T� MICHAEL T. CHANDLER & KAY L. CHANDLER A/K/Ag T Dollar Amount Requested: Dwithin arbitration limits I Are money damages requested? 0 Yes 0 No (check one) [ H ] outside arbitration limits O N Is this a Class Action Suit? i3 Yes Ej No Is this an MDJAppeal? [] Yes 'x No A Name of Plaintiff /Appellant's Attorney: POWERS, KIRN & JAVARDIAN, LLC 1 Check here if you have no attorney (are a Self- Represented jPro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle Debt Collection: Other 0 Board of Elections E3 Nuisance 0 Dept. of Transportation 0 Premises Liability Statutory Appeal: Other S 0 Product Liability (does not include I= 3 Employment Dispute: E mass tort) Slander/Libel/ Defamation Discrimination C 0 Other: 0 Employment Dispute: Other 0 Zoning Board � Other: T I 0 Other: O MASS TORT Asbestos N 0 Tobacco 0 Toxic Tort -DES _ 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other: 0 Ejectment 0 Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation 0 Declaratory Judgment Ground Rent Mandamus 0 Landlord/Tenant Dispute 0 Non - Domestic Relations x: Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition 0 Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical 3 Other: 0 Other Professional: Updated 1/1/2011 POWERS, KIRN & JAVARDIAN, LLC Gregory Javardian, Esquire Id No. 55669 Jill Manuel- Coughlin, Esquire Id No. 63252 Mary F. Kennedy, Esquire Id No. 77149 j r THE P R S T H OIN O j A f {';' Meghan K. Boyle, Esquire Id No. 201661 20 �� i { Sean P. Mays, Esquire Id No. 307518 Daniel C. Fanaselle, Esquire Id. No. 312292 Richard J. Nalbandian, III, Esquire Id No. 312653 CUMBERS- COUIN T Y 1310 Industrial Boulevard, Suite 101 PE Southampton, PA 18966 (215) 942 -2090 ATTORNEYS FOR PLAINTIFF CITIMORTGAGE, INC., SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO ABN AMRO MORTGAGE GROUP, INC. CIVIL DIVISION 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 CUMBERLAND COUNTY PLAINTIFF �y L— NO. ,tt� � �7 � � � /u cC VS. COMPLAINT IN MORTGAGE FORECLOSURE MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERS 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011 DEFENDANTS CIVIL ACTION MORTGAGE FORECLOSURE 1. CitiMortgage, Inc., Successor By Merger to ABN AMRO Mortgage Group, Inc. (hereinafter referred to as "Plaintiff') is a Corporation with a principal place of business in O'Fallon, Missouri. 2. Michael T. Chandler and Kay L. Chandler a/k/a Kay L. Myers (hereinafter referred to as "Defendants ") are adult individuals residing at the address indicated in the caption hereof. 3. Plaintiff brings this action to foreclose on the mortgage between Defendants and itself as Mortgagee. The Mortgage, dated December 14, 2001, was recorded on December 19, 2001 in the Office of the Recorder of Deeds in Cumberland County in Mortgage Book 1742, Page 4987. A copy of the Mortgage is attached and made a part hereof as Exhibit 4 A'. 4. The Mortgage secures the indebtedness of a Note executed by the Defendants on December 14, 2001 in the original principal amount of $112,113.00, which is payable to Q y 2 94- Plaintiff in monthly installments with an interest rate of 6.625 %. A copy of the Note is attached and made a part hereof as Exhibit `B'. 5. The land subject to the mortgage is 3010 Morningside Drive, Camp Hill, PA 17011. A copy of the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated herein. 6. Michael T. Chandler is the Record Owner of the mortgaged property located at 3010 Morningside Drive, Camp Hill, PA 17011. 7. The Mortgage is now in default due to the failure of Defendant to make payments as they became due and owing. As a result of the default, the following amounts are due: Principal Balance $94,915.28 Interest to 10/01/2013 $10,480.20 Accumulated Late Charges $636.39 Inspections $229.50 Escrow Advance Balance $4,887.02 Less Unapplied Funds ($798.20) TOTAL $110,350.19 plus interest from 10/02/2013 at $17.2278 per day, costs of suit and attorney's fees. 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendants in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. 9. If Defendants have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 10. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor with a Notice of Homeowners' Emergency Mortgage Assistance ( "Act 91 Notice ") 35 P.S. Section 1680.403c. I L' The Notice of Homeowners' Emergency Mortgage Assistance was required and Plaintiff sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to the Defendants by regular' and certified mail on March 19, 2013. . A copy of the Notice is attached and made a part hereof as Exhibit `C'. WHEREFORE, Plaintiff requests the court enter an in rem judgment against the Defendants, in the sum of $110,350.19, together with interest, costs, fees and charges collectible under the mortgage, including, but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgaged property. POWERS, KIRN & JAVARDIAN, LLC BY: ❑Gregory Javardian, Esquire Id. No. 55669 ❑Jill Manuel- Coughlin, Esquire Id. No. 63252 ❑Mary F. Kennedy, Esquire Id. No. 77149 ❑Meghan K. Boyle, Esquire Id. No. 201661 ❑ Sean P. Mays, Esquire Id. No. 307518 )LDaniel C. Fanaselle, Esquire Id. No. 312292 ❑Richard J. Nalbandian, III, Esquire Id. No. 312653 Attorneys for Plaintiff POWERS, KIRN & JAVARDIAN, LLC Gregory Javardian, Esquire Id No. 55669 Jill Manuel - Coughlin, Esquire Id No. 63252 Mary F. Kennedy, Esquire Id No. 77149 Meghan K. Boyle, Esquire Id No. 201661 Sean P. Mays, Esquire Id No. 307518 Daniel C. Fanaselle, Esquire Id. No. 312292 Richard J. Nalbandian, III, Esquire Id No. 312653 1310 Industrial Boulevard, Suite 101 Southampton, PA 18966 (215) 942 -2090 ATTORNEYS FOR PLAINTIFF CITIMORTGAGE, INC., SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO ABN AMRO MORTGAGE GROUP, INC. CIVIL DIVISION 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 CUMBERLAND COUNTY PLAINTIFF NO. VS. COMPLAINT IN MORTGAGE FORECLOSURE MICHAEL T. CHANDLER KAY L. CHANDLER A/KJA KAY L. MYERS 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011 DEFENDANTS NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 717- 249 -3166 800 - 990 -9108 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.0 § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. EXHIBI"F "A" .F ;?F'CDS i GOJ'dTY —FQ '01 DEC 19 AE1 9 57 When recorded mail to% ABH AMRO MORTGAGE GROUP, INC. P.O. BOX 5064 TROY, MICHIGAN 48084 ATTNtFINAL /TRAILING DOCUMENTS Parcel Number: [Space Above Thh Line For Recording Data] FHA Case No. ennsylvania MORTGAGE 4416766986 -703 THIS MORTGAGE ( "Security Instrument") is given on, DECEMBER 14, 2001. The Mortgagor is RAY L. CHANDLER, A MARRIED COUPLE AND MICHAEL T. CHANDLER, A MARRIED COUPLE, ( "Borrower "). This Security Instrument is given to ABN AMRO MORTGAGE GROUP, INC., A DELAWARE CORPORATION which is organized and existing under the laws of THE STATE OF DELAWARE and whose address is 2600 W. BIG BEAVER RD. , TROY, MICHIGAN 48084 ("Lender"). Borrower owes Lender the principal sum of * * ** *ONE HUNDRED TWELVE THOUSAND ONE HUNDRED THIRTEEN AND NO/ 100* xxxxxxxxrxxxa* xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx Dollars (U.S. $112,113.00 ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, ifnot paid earlier, due and payable on JANUARY 1, 2032. This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security ofms ce [/ 4C curity�� Initials: C, FHA Pennsylvania Mortgage - 4/96 Page I of 9 PAVFHADE PALFHADE 0101 BK 1742PG4987 Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrumen the Note. For this purpose, Borrower does hereby mortgage, grant and convey to the Lender the following described property located in CUMBERLAND County, Pennsylvania: SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF, which has the address of 3010,MORNINGSIDE DRIVE, CAMP HILL _ [Street. City]. Pennsylvania 17011 ( "Property Address "); [zip Caael TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All ofthe foregoing is referred to in this Security Instrument as the' `Property." BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrowerwarrants and will defend generally the titleto thePropertyagainstall claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non - uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. t. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by, pder to /p� Initials: /hc 101 FHA Pennsylvania Mortgage - 4I% Page 2 of 9 PALFHADE BK ! 742PG4988 the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the T Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and bold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required forBorrower's escrow account underthe Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et seq. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ( "RESPA "), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tendersto Lender thefid] paymentofall such sums, Borrower's acoountshall be credited with thebalance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with arty balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paragraphs 1 and 2 shall be applied by Lender as follows: Fier , to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; Fourth, to amortization of the principal of the Note; and Fifth, to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly toI ender, instead oftoBorrowerandtoLenderjointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction ofthe indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in theorderinparagraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event offoreclosure of this Security Instrument or othertransferof title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. m e & Initialer � l� �t FRA Pennsylvania Mortgage - 4/96 Page 3 of 9 PALFHADE 8KI742PG4989 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property-.as Borrower's principal residence within sixty days after the execution of this Security instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires feetitle to the Property, the leasehold andfee title shall notbe merged unless Lenderagrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct orconsequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment ofprincipal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly famish to Lender receipts evidencing these payments. If Borrower fails to make thesepayments or the payments required bypamgraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender, (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. initials: 9 C 7t FHA Penn:ylraWs Morteaee - 4M Page 4 of 9 PALFHADE BK 1742PG4990 8. Fees, Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of payment defaults, require immediate payment in full of all sums secured by this Security Instrument if (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument (b) Sale Without Credit Approval, Lender shall, if permitted by applicable law (including Section 34l(d) of the Garn -St Germain Depository Institutions Act of 1982, 12 U.S.C. 1701 j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if (i) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantoe as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full. but Lender does not require such payments. Lender does not waive its rights with respect to subsequent events. (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined tobe eligib lefor insurance under theNational Housing Act within 60 days from the date hereof Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument A written statement ofany authorized agentofthe Secretarydated mbsequent to 60 days from thedatehereof, decliningto insure this Security InstrrmrentandtheNote, shallbe deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrumentand theobligations thatit securesshall remain in effect as ifLenderhadnot required immediate payment in full. However, Lender is not required to permit reinstatement if. (i) Lender has accepted reinstatement after the commencementofforcclosure proceedings within twoyears immediately preceding the commencement ofacurrent foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or BonrowerAsy Initials: FHA Peano*anfn Mortgage _ 41% Page 5 of 9 PALFHADE 7 BK 1742PG499 in interest. Lender shall not be required to commence proceedings against any successor in interest or muse to extend time for payment orotherwise modify amortization ofthe sums secured by this Security Instrumentby reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co -signs this Security Instrument but does not execute the Note: (a) is co- signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and anyotherBorrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it orby mailing it byfirst class mail unless applicable law requires use ofanothermethod. The notice shallbedireoted to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause orpermit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly giveLender written notice ofany investigation, claim, demand, lawsuit or otheraction by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal orother remediation ofanyHazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxicpesticides and herbicides, volatile solvents, materialscontaining asbestos orformaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON - UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers toLender all the rentsand revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of arty covenant or agreement in the Security Instrument, Borrower shall col Initialsr AAA Pennxyhwda Mortgage - 4196 Page 6 of 9 PALFHADE BK 1742PG4992 and receive all rents and revenues of the Property as trustee for thebencfit ofl ender and Borrower. Thisassignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower hasnotexecated any priorassignment ofthe rentsand has notandwill notperform anyact thatwould prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control ofor maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9. Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. H the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ( "Act ") (12 U.S.C. 3751 ef seq. ) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums socured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases arry error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 23. Interest Rate AfterJudgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. Ifone or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)] O Condominium Rider D Growing Equity Rider O PlannedUnit Development Rider O Graduated Payment Rider O Other(s) [specify] Initialat FAA Pe mVWanln Mortgage - 4/96 Page 7 of 9 PALFHADE BK 1742PG4993 BY SIGNING BELOW, Borrower accepts and agrees to the terns contained in this Security Instrument and _ in any rider(s) executed by Borrower and recorded with it. Witnesses: n �� � � • 1. � Q/� L�`• -C��J (Seal ) RAY L. CHANDLER (Seal) MICHAEL T. CHANDLER t Certificate of Residence do hereby certify that the correct address of the within -named Lender is 2600 W. BIG BEAVER RD. , T ROY, MICHIGAN 48084 Witness my hand this L l day of C (A l IS t� / o1 Afl Agee) of under FHA PemuylvWa Mortgage - 4196 Page 8 of 9 _ PALFHAD BK 1742PG4994 r COMMONWEAL 7F PENNSYLVANIA, �"�'� County ss: On this ,I day of [) c C&Nm 6 6k , 10o I before me, the undersigned officer, personally appeared RAY L. CHANDLER AND MICHAEL T. CHANDLER known to me (or satisfactorily proven) to be person S whose name.! subscribed to the within instrument and acknowledged that executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and o icial seal. ;yy, My Commission Expires: ElIzW M NOTARIAL MoTYER, Notary Public Camp MU Bo CumbMand Conriy 0 7 & 6G 1 MY Commieabn Explree Dao.1r% 2003 Member, Ponnsykvia Assodaft of P tares fine of Officer initials t FAA Penneytvwds MoTteage - Page 9 of 9 PALFHADE gX 1742PG4995 EXHIBIT "A" - MORTGAGE LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron pin, said iron pin being 735 feet East of the northeast corner of Thirty- Second Street and Momingside Drive; thence eastwardly along the northern side of Morningside Drive, 60 feet to an iron pin; thence northwardly along the line of property now or formerly of Harry R. Lukens and Daisy N. Lukens, his wife, 150 feet to an iron pin; thence westwardly along the line of property now or formerly of the Pennsylvania Railroad, 60 feet to an iron pin; thence southwardty along the line of propp" now or formerly of Luther W. Andrews and Agnes E. Andrews, his wife, 150 feet to an iron pin, the place of BEGINNING. HAVING THEREON erected a dwelling known as 3010 Momingside Drive. I L,l. '.ire to bc iec'0 i'!0 N (Chandler.pWCHANDLER/23) BK1742PG4996 EXHIBIT "B" OCT, 23. 2012 12:37PM WELLS FARGO 6126678615 NO, 596 P. 11/39 FHA Cam No. .. NO'S'E 4415766986 -70 Multistate DECEMBER 14, 2001 CAME' HILL, PENNSYLVANIA [Date] [City] [State] 3010 MORNINGSIDE DRIVE, CAMP ,HILL, PA 17011 [Property Address] 1. PARTIES "Boxrower " means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means ABN AMRO MORTGAGE GROUP, INC., A DELAWARE CORPORATION and its successors and assigns. 2. 3101MOW ER'S PROMISE TO PAY, INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of *ONB' R iDRED TWELVE THOUSAND ONE HUNDRED THIRTEffid AND Dollars (U.S. $112,113.00 ),plus interest, to the order of Lender. Interest will be cbargeftn unpaid principal, frown the daft of disbutsemen t of the loan proceeds by Lender, at the rate of $ I% AND FIVE - EIGi3 percent ( 6.625% )per year until the full amount of ptincipal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrumeart that is dated the same date as this Note and called the "Security Instrument" The Security Instrument protects the Lender froru losses which might result if Borrower defaults under this Note. 4. KAIiMR Ole PAYMENT (A) Time Borrower shall make a payment of principal and interest to bender on the 1ST day oftach month beginning on FEBRUARY 1, 2002. Any principal and interest remaining on the 1ST day of JANUARY, 2032 will be. due on that date, which is called the "Maturity Date." (B) Place Paymcm shall be made at 4242 N. HARLEM AVE. NORRjDGE, IL 60706 ATTN: CASHIERING or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each zkoathly payment of principal and interest will be in the amount of U. S. $717.87. This amount will be part of a larger monthly payment required by the Security Insmiment, that shall be applied to principal, interest and other items in the order described in the Security Instrument (D) Allonge to this Note for payment Adjustments If art allongr providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants o£ this Note as if the allouge were &part of this Note. [Check applicable box] O Graduated Payment Allonge D Crowing Equity Allonge D Other [spay] 5. BOItROVI'ER'S RIGHT TO PLAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or pex ty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays iurtaest on tip amount prepaid for the remainder of the month to the extent required by Leader and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment tutless Under agrees in writing to those changes. 6. BORROW)LRIS Xt•AZ URE TO PAY (A) bate Charge for Overdue Payments Ifl.ender has not received the full montbly payment required by the Security Instrument iment as desca' bed in Paragraph 4(C) ofthis Note, by the end of is calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR percent ( 4.0 0 sk ) of the overdue amauut oftach Payment- (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may. except as Utiiited by regulations of the Secretary in the me ofpayment defaults, require immediate payment in full of the principal balance remainingdae and all accrued interest Leader may choose not to exercise this option without waiving its rights in the event of any sebsequeW default In many cireumstaaces regulations issardbythe Secretary will limitLender'srightstorequire immediatepayMmartiafuilinthecaseOfpayment FHA MaXatate Fixed roe Note .10/95 Page 1 of 2 P8700NOT 0001 OCT.23.2012 12:36PM WELLS FARGO 6126676615 N0.596 P. 12/39 def nilm nisNotedoes not authorize acceleration when not permitted byHUD regulations. Asusediu thisVote, "Secretary 'means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in fall, as described above, Lender may require Bormwem pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by- applicable law. Such fees and costs shall beax interest from the date of disbursement at the same rate as the principal of this Note. 7. WAVERS Borrower and any other person who has obligations under this Note waive the rights of preseotmaat and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. S. GIVING OF NOTICES Unless applicable law requires a diffment method, any notice that must be given to Borrower rmderthis Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lendu:r a notice of Borrower's different address. Anynoticethatmustbegiventol enderuxiftthisNotewillbegivenbyfirstolassmailtoLenderetthcaddress stated inParagraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER TM NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of4he promises made in this Note, inclndingthepromisetopaytheftill amount owed Any person who is aguarantor, surety or endonexd41tisNoteisalso obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, smetpor endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights undertitrs Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in ¢dote. RAY L, CHANIDLER (SEAL).. MICHAEL T. CHANDLER (SEAL PAY TO THE ORDEFI OP WITHOUT RECOURSE A8 AMRQ MORTGAGE GROUP, INC. k MARGeET A. 8 VICE PRESIDENT FHA NgWkstate Rxed zta*z N ote -10195 Page 7 of 2 "700NOT EXHIBIT "C" CitiMortgage, Inc PRESORT PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S. Postage and Fees Paid W SO 7196 9006 9296 6066 8028 Send Payments to: CitiMotgage, Inc PO Box 689196 Des Moines, IA 50368 -9196 20130319 -168 I lr l ll l �l� ulll ����l n l�l l � r ' �� ' �I1�1'��'�II I � L I IIu I I � n ' I �I��� KAY L CHANDLER 3010 MORNINGSIDE DR Send Correspondence to: CAMP HILL, PA 17011 -5818 CitiMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 W! i6f CITIPAACT91 Date: 03/19/2013 Sent Via Certified .Mai] 7196 9006 9296 6066 8028 KAY L CHANDLER 3010 MORNINGSIDE DR CAMP HILL, PA 17011 -5818 RE: Property Address: 3010 MORNiNGSIDE DR CAMP HILL, PA 17011 CitiMortgage Loan #: ACT 91 NOTICE TAB ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at (800) 342 -2397. (Persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, 1•W '= CITIPAACT91 Page 2 of 9 7196 9006 9296 6066 8026 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 PRESTAMO 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. HOMEOWNER'S NAME(S): KAY L CHANDLER MICHAEL T CHANDLER PROPERTY ADDRESS: 3010 MORNINGSDDE DR CAMP HILL, PA 17011 LOAN ACCT. NO.: ORIGINAL LENDER ABN AMRO MORTGAGE GROUP, INC. CURRENT LENDEWSERVICER CitiMortgage, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE 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 STAY OF FORECLOSURE - Under the Act, you are entitled to a temporajy 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 Arith one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF TIIIS 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 AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty CITIPAACT91 7196 9006 9296 6066 8028 Page 3 of 9 (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. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the stature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the Program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLI'C, tTION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGALVST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION GALLED "TEMPORARY STAY OF FOREC.LOSUkE. " 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 ACT ak, BUT IF YOUR APPLICATION IS EVENTUALLY APPROPED AT ANY TlA E BEFORE .4 SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited They will be. disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that tirrte, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You 14411 be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. CITIPAACT91 7196 9006 9296 6066 8028 Page 4 of 9 NOTE. IF YOU ARE CURRENTLY PROTECTED BY TIfE FILIAIG OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS \TOT ICE IS FOR INFORM4 TION PURPOSES ONLY AND SHOULD .NOT BE CONSIDERED AS ANA TTEMPT TO COLLECT THE DEBT. (Ifyou have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bung it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 3010 MORNINGSIDE DR CAMP HILL, PA 17011 IS SERIOUSLYIN DEFAULT because: YOU HAM NOT MADE MOArTHLY MORTGAGE PAYMENTS for the following months and the following amounts are nowpast due: 03/01/12 through 11./01/12 9 @ $1016.70 /month 9 @ $40.66 /late charge/month $951624 12/01/12 through 03/01 /13 4 @ $990.53 /month 4 @ $39.61 /late charge /month $41 20.56 Previous Tate Charge(s): $119.61 Delinquency Expense(s): $202.50 Unapplied Funds: ( $798.20) TOTAL AMOUNT PAST DUE: $13,160.75 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $13,160.75, PLUS ANYMORTGAGE PAn1F,ATTSAIVD LATE CHARGES WHICHBECOME DIM DURING THE THIRTY(30) DAYPERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: CitiMortgage, Inc. P.O. Box 790005 St. Louis, MO 63179 -0005 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the leader intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If furll payment of the total amount past due is not made within THIR IT (30) DA YS, the lender also intends to instruct its attorney's to start legal action to foreclose upon your mortgaged properly. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay qff the mortgage debt. If the leader 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, zip to $50.00_ However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even: if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within Ilse THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all CITIPAACT91 7196 9006 9296 6066 8028 Page 5 of 9 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) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do. so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by pet forming any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CitiMortgage, Inc. Address. P.O. Box 790005 St. Louis, MO 63179 -0005 Phone Number: 1- 877 - 362 -0175 Monday through rriday 8 AM - 5 PM CST. TTY Services are also available. To access: Dial 711 from the United States or Dial 1- 866 - 280 -2050 from Puerto Rico. Fax Number: 1- 866 - 940 -8147 Contact Person: MarkAnthony Hartland E -Mail. Address: markanthony.b.hartland�cilciti.com EFFECT OF SHERIFF'S SALE - You should realize ihat 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 OFMORTGAGE - You may not 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 other requirements of the mortgage are satisfied. I A ! CITIPAACT91 7196 9006 9296 6066 8028 Page 6 of 9 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO T13E 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 AN I OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OT14ER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCATED ON THE ATTACIIED LIST In accordance with the Fair Debt Collection Practices Act, Title 15, U.S.0 1692(8), you may dispute the validity of this debt, or any portion thereof; if you do so in writing within thirty (30) days after the receipt of this notice. If you dispute the validity of this debt, or any portion thereof; within this thirty (30) days period we will provide you with written verification thereof, otherwise the debt will be assumed to be valid. Sincerely, CitiMortgage, Inc. P.O. Box 790005 St. Louis, MO 63179 -0005 CITIPAACT91 7196 9006 9296 6066 8028 Page 7 of 9 • MEMAP Consumer Credit Counseling Agencies YORK County Repwt last updated: 02/19/2013 04:29 PM Advantage Credit Counseling Service/CCCS of Western PA Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road 55 Clover Hill Road Harrisburg, PA 17102 Dallastown, Rk 17313 888 -511 -2227 888 -511 -2227 Base, Inc. Housing Alliance of York/Y Housing Resources 447 South Prince Street 290 West Market Street Lancaster, PA 17603 York, PA 17401 717- 392 -5467 717 - 855 -2752 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717 -334 -1518 HC Page 8of9 7196 9006 9296 6066 6028 HEMAP Consumer Credit Counseling Agencies "CUMBERLAND. County Repeat last updated: 02) 19/2013 04:29 PM Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Deny Street Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717- 232 -9757 Housing Alliance of YorUY Housing Resources Maranatha 290 Rest Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717- 855 -2752 717- 762 -3285 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717 -234 -6616 717- 264 -5913 PA Interfaith Community Programs Inc PHFA 40 E I-3igh Street 211 North Front Street Gettysburg, PA 17325 Iarrisburg, PA 17110 717 -334 -1518 717- 780 -3940 800 -342 -2397 HC Page:9of9 7196 9006 9296 6066 6028 CitiMortgage, Inc PRESORT PO Box 9090 First-Class Mail Temecula, CA 92589.9090 U.S. Postage and Fees Paid W SO 7196 9006 9296 6066 8066 Send Payments to: CitiMortgage, Inc PO Box 689196 Des Moines, IA 50368 -9196 20130319 -168 MICHAEL T CHANDLER 3010 MORNINGSIDE DR Send Correspondence to: CAMP HILL, PA 17011 -5818 CitiMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 CITIPAACT91 Date: 03/19/2013 Sent Via Certified Mail 7196 9006 9296 6066 8066 MICHAEL T CHANDLER 3010 MORNINGSIDE DR CAMP HILL, PA 17011 -5818 RE: Property Address: 3010 MORNINGSIDE DR. CAMP HILL, PA .17011 CitiMortgage Loan #: �- ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCYMORTGAGE ASSISTANCE PROGRAM ( HEMAP) maybe able to help save your home. This Notice explains how the program works. To see if HEMAP can help, you trust MEET WITH CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll -free at (800) 342 -2397. (Persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, 'iO CITIPAACT91 Page 2 of 9 7196 9006 9296 6066 8066 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 NOTIFICACI6N OBTENGA UNA TRADUCCION INMEDIATAMENTE LI..AMA.NDO ESTA AGENCIA (P.ENNSYLVANIA. HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA. PERDIDA. DEL . DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): MICHAEL T CHANDLER KAY L CHANDLER PROPERTY ADDRESS: 3010 MORNINGSIDE DR CAMP HILT., PA 17011 LOAN ACCT. NO.: ORIGINAL LENDER ABN AMRO MORTGAGE GROUP, INC. CURRENT LENDER/SERVICER: CitiMortgage, Inc. HOMEOWNER'S EMERGENCY .MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MASS FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOVG NER'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 STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF T111S NOTICE. IF YOU DO NOT APPI Y 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 AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty CITIPAACT91 7196 9006 9296 6066 8066 Page 3 of 9 w (30) days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face- to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specie information about the nature of your default). You have the right to apply for f nancial 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 Penns ' vlvania Housing Finance. Agency. To temporarily stop the lender from fling a foreclosure action, your application MUST be,forwarded to PHFA and received within thirty (30) days of your face -to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE: IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGALVST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAYF. 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. AGENCY ACTION - Available fzrnds 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 noticed directly by the Pennsylvania Housing Finance Agency of its decision on your application. CITIPAACT91 71% 9006 9296 6066 8066 Page 4 of 9 NOTE. IF YOU ARE CURR7 NTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, TIME FOLLOWING PART OF THIS NOTICE 1S FOR LNFOR41ATIONPURPOSES ONLYAAW SHOULD .NOT BE CONSIDERED AS ANA TTEMPT TO COLLECT THE DEB 7. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brnlg it up to date). NATURE OF THE DEFAULT - The.MORTGAGE debt held by the above lender on your property located at: 3010 MORNINGS IDE DR CAMP HILL, PA 17011 IS SERIOUSLYIN DEFAULT because: YOU HA ME A'OT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 03/01/12 through 11/01/12 9 @ $1016.70 /month 9 @ $40.66 /late charge /month $9516.24 12/01/12 through 03/01/13 4 @ $990.53 /month 4 @ $3,9.61/late charge /month. $4120.56 Previous late Charge(s): $119.61 Delinquency Expense(s): $202.50 llnapplied Funds: $7( 9$.20) TOTAL AMOUNT PAST DUE: $13,160.75 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $13,160.75, PLUS ANY,LIORTGAGE PAYMENTS AND LATE CHARGES WHIC,II BECOME DUE DURING THE THIRTY (i0) DAYPF.RlOD_ Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: CitiMortgage, Inc.. P.O. Box 790005 St. Louis, MO 63179 -0005 IF YOU 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 to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If fitll payment of the total amount past due is not made within THIRTY (30) DA YS, the lender also intends to instruct its attorney's to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay q ff the mortgage debt. If the lender refers your case to its atforneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (3 0) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all CITIPAACT91 7196 9006 9296 6066 8066 Page 5 of 9 x 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 Sheriff's Sale_ You : may do. so by paying the total amount then past due, plus any late or other charges then due., reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements corder the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It. is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this 'notice. A notice of the actual date of the Sheriff's 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. HO TO CONTACT THE LENDER: Name of Lender: CitiMortgage, Inc. Address: P.O. Box 790005 St. Louis, MO 63179 -0005 Phone Number: 1- 877 - 362 -0175 Monday through Friday 8 AM - 5 PM CST. TTY Services are also available. To access: Dial 711 from the United States or Dial 1- 866 - 280 -2050 from Puerto Rico. Fax Number: 1 -866- 940 -8147 Contact Person: Mark-Anthony Hartland E -Mail Address: markanthony.b.hartland @citi.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of (lie 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 not 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 other requirements of the mortgage are satisfied. W . l k CITIPAACT91 71% 9006 9296 6066 8066 Page 6 of 9 r ` YOU MAY ALSO HAPE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF T14E 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 DEPAULT 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. CONSUMER CREDIT COUNSELING AGENCIES SERYING YOUR COUNTY CAN BE LOC,4TED ON TUE ATTACHED LIST In accordance with the Fair Debt Collection Practices Act, Title 15, U.S.0 1692(8), you may dispute the validity of this debt, or any portion thereof; if you do so in writing within thirty (30) days after the receipt of this notice. If you dispute the validity of this debt, or any portion thereof, within this thirty (30) days period we will provide you with written verification thereof, otherwise the debt will be assumed to be valid. Sincerely, CitiMortgage, Inc. P.O. Box 790005 St. Louis, MO 63179 -0005 CITIPAACT91 7196 9006 9296 6066 8066 Page 7 of 9 r HEMAP Consumer Credit Counseling Agencies YORK County Report last updated: 02!19/2013 04:29 Pbi Advantage Credit Counseling Service/CCCS of Western PA Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road 55 Clover Hill Road Harrisburg, PA 17102 Dallastown, PA 17313 888 -511 -2227 888 -51.1 -2227 Base, Inc. Housing Alliance of York/Y Housing Resources 447 South Prince Street 290 West Market Street Lancaster, PA 17603 York, PA 17401 717- 392 -5467 717 -855 -2752 PA Interfaith Community Programs Inc 40 E Iiigli Street Gettysburg, PA 17325 717 -334 -1518 HC Page80179 7196 9006 9296 6066 8066 r HEMAP Consumer Credit Counseling Agencies CtMBLRLAND County Repot last updated: 02/19/2013 04:29 PM Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Streit Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717 -232 -9757 Housing Alliance of York/Y Housing Resources Maranatha 290 NA , est Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717 -8S5 -2752 717 -762 -3285 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717 - 234 -6616 717 -264 -5913 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front. Street Gettysburg, PA 17325 Harrisburg, PA 17110 717 -334 -1518 717 -780 -3940 800 - 342 -2397 HC Page 9 of 7196 9006 9246 6066 81766 t w VERIFICATION Nicole M. Talbot hereby states that he /she is employed as Vice President — Document Control of CitiMortgage, Inc., the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AFFIANT: By: VJL Print: Nicole M. Talb Title: Vice President — Document Control employed by CitiMortgage, Inc. Plaintiff CitiMortgage, Inc. Date: OCJDM ?i 3 FILE #: 13 -1145 NAME: CHANDLER, MICHAEL T. & KAY L. A/K/A MYERS, KAY L. POWERS, KIRN & JAVARDIAN, LLC Gregory Javardian, Esquire Id No. 55669 .e t D - Cf i t' P C L. Jill Manuel- Coughlin, Esquire Id No. 63252 C r= !; 3=1 s ri F3 u ! Mary F. Kennedy, Esquire Id No. 77149 Meghan K. Boyle, Esquire Id No. 201661 iJ 13 OCT 14 1 1 11-110* 1 Sean P. Mays, Esquire Id No. 307518 Daniel C. Fanaselle, Esquire Id. No. 312292 C, U M P E' R L A N D C C U 1 T i' Richard J. Nalbandian, III, Esquire Id No. 312653 PENNSYLVANIA 1310 Industrial Boulevard, Suite 101 Southampton, PA 18966 (215) 942 -2090 ATTORNEYS FOR PLAINTIFF CITIMORTGAGE, INC., SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO ABN AMRO MORTGAGE GROUP, INC. CIVIL DIVISION 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 CUMBERLAND COUNTY PLAINTIFF NO. 13 _ 99'7 VS COMPLAINT IN MORTGAGE FORECLOSURE MICHAEL T. CHANDLER KAY L. CHANDLER AWA KAY L. MYERS 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011 DEFENDANTS 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 2439400 extension 2510 or 800 8225288 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 THESTEPS REQUIRED BY THIS NOTICE THIS PROGRAM IS FREE. tO- y 1013 Date Respectfully submitted, ❑Gregory Javardian, Esquire Id. No. 55669 ❑Jill Manuel - Coughlin, Esquire Id. No.63252 ❑Mary F. Kennedy, Esquire Id. No. 77149 ❑Meghan K. Boyle, Esquire Id. No. 201.661 ❑ Sean P. Mays, Esquire Id. No. 307518 9tDaniel C. Fanaselle, Esquire Id. No. 312292 ❑Richard J. Nalbandian, III, Esquire Id. No. 312653 Attorneys for Plaintiff 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 CUSTOMER/ PRIMARY APPLICANT 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: Number of people in household How long: CO- BORROWER Mailing Address: City: State Zip: Phone Numbers: Home: Office: Cell: Other: Email: Number of people in household How long: FINANCIAL 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: t 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) Model: Year: Amount owed $: Value: $ MONTHLY INCOME Name of Employers 1. 2. 3. Additional Income Description (not wages): I. 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 $ 2nd Mortgage $ Utilities $ Car Payment(s) $ Condo/Neigh. Fees $ Auto Insurance $ Med not covered $ Auto fuel /repairs $ Other prop payment $ Install Loan Payment $ Cable TV $ Child Support/Alimony $ Spending Money $ Day /Child Care Tuition $ Other Expenses $ Amount Available for Monthly Mortgage Payments Based on Income Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes please provide the following information Counseling Agency: Counselor: Phone Office: Fax: 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 known regarding your lender's or lender loan servicing company Lender Contact (Name) Phone Servicing Company (Name) Contact: Phone AUTHORIZATION 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 Uwe 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 Gregory Javardian, Esquire, lender counsel: Proof of income Bank statements to cover the last 60 day period If self employed, we must have the last 3 bank statements from both their business and personal bank accounts. Proof of any expected income for the last 45 days Dodd Frank Certificate 4506T -EZ form Copy of last two months utility bill Letter explaining reason for delinquency and any supporting documentation Hardship letter Listing agreement if property is currently on the market Gregory Javardian, Esquire 1310 Industrial Boulevard 2 °d Floor, Suite 202 Southampton, PA 18966 (tel) 215- 942 -2090 (fax) 215- 942 -8661 Attention: Panjola Alikaj Paniola.alikai@pkjllc.com (tel) 215- 942 -2090 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ofraratr Jody S Smith Chief Deputy .., 0x;1 ?9 Richard W Stewart f Solicitor .E��r ref Citimortgage, Inc Case Number vs. Michael Chandler(et al.) 2013-5979 SHERIFF'S RETURN OF SERVICE 10/18/2013 06:56 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Michael Chandler at 3010 Morningside Drive, Lower Allen Township, Camp Hill, PA 17011. RYAN BURGETT, DE 10/18/2013 08:34 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Kay L Chandler at 1117 White Dawn Lane, Upper Allen, Mechanicsburg, PA 17055. RYAN BURGETT, DEPUTI\ SHERIFF COST: $72.25 SO ANSWERS, October 21, 2013 RON R ANDERSON, SHERIFF Powers, Kirn & Javardian, LLC ` t ; .t.. Gregory Javardian, Esquire Id. No. 55669 Jill Manuel-Coughlin, Esquire Id. No. 63252 : =i 2 u a ( Daniel C. Fanaselle, Esquire Id. No. 312292 Matthew J. McDonnell, Esquire Id. No. 313549 'LY1SY .''ANlA 1310 Industrial Boulevard 2' Floor, Suite 202 Southampton,Pa 18966 (215)942-2090 CITIMORTGAGE, INC., SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO ABN AMR()MORTGAGE GROUP, INC. CUMBERLAND COUNTY 1000 TECHNOLOGY DRIVE O'FALLON,MO 63368 No.: 13-5979 vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES 3010 MORNINGSIDE DRIVE CAMP HILL,PA 170111 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against MICHAEL T. CHANDLER and KAY L. CHANDLER A/K/A KAY L. MYERES, Defendants for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As Set forth in Complaint $110, 350 . 19 Interest 10/02/13 to 03/24/14 $2997.50 TOTAL $113,347.69 I hereby certify that(1)the addresses of the Plaintiff and Defendants are as shown above, and (2)that notice has been given in accordance with Rule 237.1, ,.y attached. I 3 ogh ❑ Gre • Javar i ian,Esquire Id.No. ' :•9 in,/ Jill . uel-Coughlin,Esquire Id.N,. .3252 Daniel C.Fanaselle,Esquire Id.No.312292 ❑ Matthew J.McDonnell,Esquire Id.No.313549 Attorneys for Plaintiff Damages are hereby assessed as indicated. 1 VA j DATE: JI `114 ",.; PROTI1 'OTARY ,a III.6op atii- 4(.? Nau. p 413-1145 POWERS,KIRN JAVARDIAN,LI..0 GREGORY JAVARDIAN,ESQUIRE ID.NO.55669 JILL MANUEL-COUGI-1LIN,ESQUIRE ID.NO.63252 JOLANTA PEKALSKA,ESQUIRE ID.NO.307968 DANIEL C.FANASELLE,ESQUIRE ID. NO.312292 RICHARD J.NALBANDIAN,III,ESQUIRE ID.NO.312653 MATTHEW J.MCDONNELI.,ESQUIRE ID.NO.313549 1310 INDUS"IRIAL.BOULEVARD 2`D FLOOR,SUITE 202 SOUTHAMPTON,PA 18966 (215)942-2090 ATTORNEYS FOR PLAINTIFF CITIMORTGAGE,INC.,SUCCESSOR BY MERGER IN TI 1E COURT OF COMMON PLEAS TO ABN ANIRO MORTGAGE GROUP, INC. CUMBERLAND COUNTY PLAINTIFF VS. NO. 13-5979 MICHAEL T.CHANDLER KAY L.CHANDI.ER A/K/A KAY L.MYERS DEFENDANTS Kay L.Chandler a/k/a Kay 1..Myers Michael T.Chandler 3010 Morningside Drive 3010 Momingside Drive Camp Hill.PA 17011-5818 Camp Hill,PA 17011-5818 Kay L.Chandler a/k/a Kay L.Myers 1117 White Dawn Lane-Upper Allen Mechanicsburg,PA 17055 DATE OF NOTICE:December S ,2013 NOTICE,RULE 237.1 IMPORTANT NOTICE You are in default because you have hailed to take action required by you in this case. Unless you act within ten(10)days from the date of this notice.a judgment may be entered al_ainst you without a hearing and you may lose your properly or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can 1get legal help_ MidPenn Legal Services Cumberland County Bar Association 8 Irvine Row 32 S.Bedford Street Carlisle,PA 17013- Carlisle,PA 17013- Phone:717-243-9400 Phone:717-249-3166 Powers,Kim&Javardian, L.LC I3Y: o Gregory Javardian,Esquire Id.No.55669 o .till Manuel-Coughlin,Esquire Id_No.63252 ❑ Jolaata Pekalska.Esquire Id.No.307968 Daniel C.Fanaselle,Esquire Id.No.312292 ❑ Richard J.Nalhandian,LII,Esquire Id.No.312653 o Matthew J.McDonnell.Esquire Id.No.313549 Usted se encuentra en estado de rebeldia por no haher tornado la action requiida de su pane en este caso. AI no tomar is action debida dentro de un termino de diez(10)dias de esta notification,el tribunal podra,sin necesidad de compararecer usted en torte o escuchar prucha alguna,dictar sentencia en so contra,usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notification a un abogado immediatemente si usted no tiene abogado,o si no tiene dincro suliciente para tal servicio, vaya en persona o(lame porteipfono a In oficina,cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. "NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES AG"T THIS IS AN AYIEMPTTO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL.BE USED FOR TI IAT PURPOSE" Powers, Kirn & Javardian, LLC Gregory Javardian, Esquire Id. No. 55669 Jill Manuel-Coughlin, Esquire Id. No. 63252 Daniel C. Fanaselle, Esquire Id. No. 312292 Matthew J. McDonnell, Esquire Id. No. 313549 1310 Industrial Boulevard 2nd Floor,Suite 202 Southampton, Pa 18966 (215)942-2090 CITIMORTGAGE, INC., SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO ABN AMRO MORTGAGE GROUP, INC. CUMBERLAND COUNTY vs. No.: 13-5979 MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES VERIFICATION OF NON-MILITARY SERVICE Jill Manuel-Coughlin,Esquire,hereby verifies that he/she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts,to wit: (a) Defendants, MICHAEL T. CHANDLER and KAY L. CHANDLER A/K/A KAY L. MYERES, is/are not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C.S. Appx. §§ 501 et. seq. (b) Defendant, MICHAEL T. CHANDLER, is over 18 years of age, and resides at 3010 MORNINGSIDE DRIVE, CAMP HILL, PA 170111. (c) Defendant, KAY L. CHANDLER A/K/A KAY L. MYERES, is over 18 years of age, and resides at 1117 WHITE DAWN LANE, MECHANICSVILLE,PA 17055. (d) Plaintiff, CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMRO MORTGAGE GROUP, INC., is an institution conducting business under the Laws of the Commonwealth of Pennsylvania with an address of 1000 TECHNOLOGY DRIVE, O'FALLON, MO 63368. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. POWERS KIRN & JAVARDIAN, LLC I , BY: I. , I ,4 ..�∎. 'l A ❑ .rego!Javard�. F,� squire Id.No. 5 6. ! Jill Manuel-Coughlin,Esquire Id.No. + 252 Daniel C.Fanaselle,Esquire Id.No. 31' 92 Date: ❑ Matthew J. McDonnell, Esquire Id.No.313549 Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KAY L. CHANDLER A/K/A KAY L. MYERES 1117 WHITE DAWN LANE MECHANICSVILLE, PA 17055 CITIMORTGAGE, INC., SUCCESSOR COURT OF COMMON PLEAS BY MERGER TO ABN AMR() MORTGAGE GROUP, INC. CUMBERLAND COUNTY Plaintiff No.: 13-5979 vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES Defendants NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania,you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default ry, Money Judgment s*Jud g t _Judgment in Replevin Judgment for Possession by Default SI)CL��y _Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Powers, Kim&Javardian,LLC at this telephone number: (215)942-2090. • f OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MICHAEL T. CHANDLER 3010 MORNINGSIDE DRIVE CAMP HILL, PA 170111 CITIMORTGAGE, INC., SUCCESSOR COURT OF COMMON PLEAS BY MERGER TO ABN AMR() MORTGAGE GROUP, INC. CUMBERLAND COUNTY Plaintiff No.: 13-5979 vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES Defendants NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Judgment _Judgment in Replevin ,& Judgment for Possession by Default c,44y _Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Powers, Kim&Javardian, LLC at this telephone number: (215) 942-2090. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMR() MORTGAGE GROUP, INC. 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES 3010 MORNINGSIDE DRIVE CAMP HILL, PA 170111 COURT OF COMMON PLEAS CUMBERLAND COUNTY ▪ ., -va- m�> in No.: 13-5979 cra PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due Interest from 03/25/2014 to 12/03/2014 Date of Sale @ $18.63 per diem Subtotal (Costs to be added) COMA n,SO p8 Gt `7a. as Ur- t( lip. So t(Du .0 ll $113,347.69 $ 4,713.39 ❑Jill Manuel -Coughlin, E quire Id. No. 63252 ❑P e M. Bellino, Esqu. e Id No. 309091 arry B. Reese, Esquire Id No. 310501 ❑Katherine Lopez, Esquire Id No. 311713 ❑Daniel C. Fanaselle, Esquire Id No. 312292 Attorneys for Plaintiff 1310 Industrial Boulevard 2nd Floor, Suite 202 Southampton, PA 18966 (215) 942-2090 • k(i/ oc ,Thrueel POWERS, KIRN & ASSOCIATES, LLC JILL MANUEL-COUGHLIN, ESQUIRE ID. NO. 63252 PAIGE M. BELLINO, ESQUIRE ID NO. 309091 HARRY B. REESE, ESQUIRE ID NO. 310501 KATHERINE LOPEZ, ESQUIRE ID NO. 311713 DANIEL C. FANASELLE, ESQUIRE ID. NO. 312292 1310 INDUSTRIAL BOULEVARD 2ND FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 (215) 942-2090 CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMRO MORTGAGE GROUP, INC. vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES f� r . 0.1' SUM r PENNS I. NV; COUNTY' COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 13-5979 CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certify this Property is: FHA Tenant Occupied Vacant Commercial As a result of Complaint in Assumpsit Act 91 complied with ❑Jill 114�nue1-Coughlin, Esq re Id. No. 63252 ❑P e M. Bellino, Esquire d No. 309091 arry B. Reese, Esquire Id No. 310501 Katherine Lopez, Esquire Id No. 311713 ❑Daniel C. Fanaselle, Esquire Id No. 312292 Attorneys for Plaintiff CITIMORTGAGE, INC., SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO ABN AMRO MORTGAGE GROUP, INC. CUMBERLAND COUNTY vs. No.: 13-5979 5- MICHAEL T. CHANDLER z KAY L. CHANDLER A/K/A KAY L. .•c7.' MYERES AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3010 Morningside Drive, Camp Hill, PA 170111: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Michael T. Chandler Kay L. Chandler A/K/A Kay L. Myeres 3010 Morningside Drive Camp Hill, Pa 170111 1117 White Dawn Lane Mechanicsville, Pa 17055 2. Name and address of Defendant(s) in the judgment: Michael T. Chandler Kay L. Chandler A/K/A Kay L. Myeres 3010 Morningside Drive Camp Hill, Pa 170111 1117 White Dawn Lane Mechanicsville, Pa 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Members First Credit Union PA Department of Revenue Citibank (South Dakota) Last Known Address (if address cannot be reasonably ascertained, please indicate) 5000 Louise Drive Mechanicsburg, PA 17055 109 Louisa Lane Mechanicsburg, PA 17128 701 E. 60th Lane Sroux Falls, SD 57117 Brightwater Capital, LLC 1835 Market Street, Ste 501 Philadelphia, PA 19103 Lower Allen Township Authority 120 Limkiln Road New Cumberland, PA 17070 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Secretary Housing & Urban Development 451 Seventh Street, SW Washington, DC 20410 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau PA Department of Public Welfare Bureau of Child Support Enforcement 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Old Courthouse, Room 106 Carlisle, PA 17013 Health and Welfare Building — Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 Pennsylvania Office of Attorney General 16th Floor, Strawberry Square Harrisburg, PA 17120 Commonwealth of PA, Department of Revenue, Bureau of Compliance, Clearance Support Section Dept. 280948 Harrisburg, PA 17128-0948 X 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 3010 Morningside Drive Camp Hill, Pa 170111 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. 0Ji11`Manuel-Coughlin, Es ire Id. No. 63252 C7Pa. M. Bellino, Esquir Id No. 309091 arry B. Reese, Esquir Id No. 310501 Katherine Lopez, Esquire Id No. 311713 ❑ Daniel C. Fanaselle, Esquire Id No. 312292 Attorneys for Plaintiff July a 2014 POWERS, KIRN & ASSOCIATES, LLC JILL MANUEL-COUGHLIN, ESQUIRE ID. NO. 63252 PAIGE M. BELLINO, ESQUIRE ID NO. 309091 HARRY B. REESE, ESQUIRE ID NO. 310501 KATHERINE LOPEZ, ESQUIRE ID NO. 311713 DANIEL C. FANASELLE, ESQUIRE ID. NO. 312292 1310 INDUSTRIAL BOULEVARD 2ND FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 (215) 942-2090 CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMR() MORTGAGE GROUP, INC. vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES 20/4, jo4 CUt`ll 1r, PE-Va /J COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 13-5979 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael T. Chandler 3010 Morningside Drive Camp Hill, Pa 17011 Your house (real estate) at 3010 Morningside Drive, Camp Hill, Pa 170111, is scheduled to be sold at Sheriff's Sale on December 3, 2014 at 10:00 A.M., in the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $113,347.69, obtained by Citimortgage, Inc., Successor By Merger To Abn Amro Mortgage Group, Inc. , against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 942-2090. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-2090. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Powers, Kirn & Associates, LLC at (215) 942-2090. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 7 POWERS, KIRN & ASSOCIATES, LLC JILL MANUEL-COUGHL1N, ESQUIRE ID. NO. 63252 PAIGE M. BELLINO, ESQUIRE ID NO. 309091 HARRY B. REESE, ESQUIRE ID NO. 310501 KATHERINE LOPEZ, ESQUIRE ID NO. 311713 DANIEL C. FANASELLE, ESQUIRE ID. NO. 312292 1310 INDUSTRIAL BOULEVARD 2N° FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 (215) 942-2090 CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMRO MORTGAGE GROUP, INC. vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES 4 irit. ,13 f-'6AWS COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 13-5979 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kay L. Chandler A/K/A Kay L. Myeres 1117 White Dawn Lane Mechanicsville, Pa 17055 Your house (real estate) at 3010 Morningside Drive, Camp Hill, Pa 170111, is scheduled to be sold at Sheriffs Sale on December 3, 2014 at 10:00 A.M., in the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $113,347.69, obtained by Citimortgage, Inc., Successor By Merger To Abn Amro Mortgage Group, Inc. , against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 942-2090. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of, stopping the sale. (See notice on page two on how to obtain an attorney.) • YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling (215) 942-2090. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Powers, Kirn & Associates, LLC at (215) 942-2090. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMRO MORTGAGE GROUP, INC. Vs. NO 13-5979 Civil Term CIVIL ACTION — LAW MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $113,347.69 L.L.: Interest FROM 3/25/2014 TO 12/03/2014 DATE OF SALE @ $18.63 PER DIEM - $4,713.39 Atty's Comm: Atty Paid: $221.00 Plaintiff Paid: Date: 7/17/14 (Seal) Due Prothy: Other Costs: David D. Buell, Prothonota Deputy REQUESTING PARTY: Name: HARRY B. REESE, ESQUIRE Address: POWERS, KIRN & ASSOCIATES, LLC 1310 INDUSTRIAL BLVD., 2ND FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-2090 Supreme Court ID No. PLAINTIFF POWERS, KIRN & ASSOCIATES, LLC JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252 JOLANTA PEKALSKA, ESQUIRE Id No. 307968 HARRY B. REESE, ESQUIRE Id No 310501 DANIEL C. FANASELLE, ESQUIRE Id No. 312292 MATTHEW J. MCDONNELL, ESQUIRE Id No. 313549 Eight Neshaminy Interplex, Suite 215 Trevose, PA 19053 215-942-2090 Attorney for Plaintiff CitiMortgage, Inc. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. 13-5979 Kay L. Chandler Michael Chandler Defendant AFFIDAVIT PURSUANT TO Pa.R.C.P. 3129.2 Plaintiff, by and through its undersigned counsel, say: 1. On October 7, 2014, a copy of the Notice of Sheriff's Sale of Real Property was served upon the defendant, Kay L. Chandler , by a private process server. 2. On October 24, 2014, a copy of the Notice of Sheriff's Sale of Real Property was served upon the defendant, Michael Chandler, by a pri- process server. &41`Icsr.21,2014 1 3. On October 8, 2014, a notice of Sheriff's a e was served upon lien holders of record A and interested parties by ordinary mail. A copy of the certificate of mailing is attached hereto and made a part hereof as Exhibit "B". I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Jim ani -Coughlin, Esquire c No. 63252 Jolanta Pekalska, Esquire, I•. o. 307968 Marry B. Reese, Esquire .. No. 310501 Daniel C. Fanaselle, .:quire, Id. No. 312292 Matthew J. McDonnell, Esquire Id. No. 313549 Attorneys for Plaintiff Dated: 1'Z EXHIBIT "B" NAME AND ADDRESS OF SENDER INDICATE TYPE OF MAIL CHECK APPROPIATE BLOCK FOR POSTMARK AND DAT Powers, Kirn & Associates 1310 Industrial Boulevard. Suite 101 Southampton, PA 18966 X Certificate Mailing 0 Insured 0 COD 0 Certified Mail Registered Mail: 0 With Postal Insurance 0 Without Postal Insurance Affix stamp or for here if issued as certificate of mailing additional copies of this bill. Line Number of Article Name of Addressee, Street, and Post -Office Address Cumberland County Domestic Relations 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If C.O.D. R.R. Fee S.D. Fee S.H. Fee PSN.1 73 IVR:"`" Zi 3 PITNEY o0Wes 3 ",, rk 003.290 , o T 02 1P R. I , �. •t 0003194302 OCT 08 2014 H ; T k. m ',.FJe•..A v11I. MAILED FROM ZIP CODE 19053 1 2 Cumberland County Tax Claim Bureau 1 Courthouse Square Old Courthouse, Room 106 Carlisle, PA 17013 3 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building — Room 432 P.O. BON 2675 Harrisburg, PA 17105-2675 4 k OCT U 8 2J14 O Off, "? 4 Pennsylvania Office of Attorney General 16111 Floor, Strawberry Square Harrisburg, PA 17120 �.• USPS 5 Commonwealth of PA, Department of Revenue, Bureau of Compliance, Clearance Support Section Dept. 280948 I larrisbure. PA 17128 6 Secretary Housing & Urban Development 451 Seventh Street, SW Washington, DC 20410 7 Lower Allen Township Authority 120 Limkiln Road New Cumberland, PA 17070Th Total Number of Pieces Listed by Sender —_, I C 1 _ �na`t�- V� �, `� S POSTMAST" (Name of ' -, PER -ceiving e. ployee) The full declaration registered documents 550,000 per maximum S500. The for COD and Third- and special handling of value is required on all domestic and international mail, The maximum indemnity payable for nonnegotiable under Express Mail document reconstruction insurance is piece subject to a limit of 550,000 per occurrence. The indemnity payable on Express Mail merchandise insurance is maximum indemnity payable is S25,000 for Registered Mail, 5500 S500 for Insured Mail. Special handling charges apply only to Fourth -Class parcels. Special delivery service also includes service. PS FORM 3877 (00401776) Name and Fite Number GISTERED, INSURED, C.O.D., CERTIFIED, AND EXPRESS 1 r YvoC !1C' APPROPIATE BLOCK Powers, Kirn & Associates 1310 Industrial Boulevard, Suite 101 Southampton, PA 18966 X Certificate Mailing ❑ Insured 0 COD 0 Certified Mail Registered Mail: 0 With Postal Insurance 0 Without Postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Line Number of Article Name of Addressee, Street, and Post -Office Address Brightwater Capital, LLC 1835 Market Street, Ste 501 Philadelphia, PA 19103 Postage Fee Handling Charge Act. Value (If Re ice— Insured Value Due Sender If C.O.D. R.R. Fee S.D. Fee 1 2 Citibank (South. Dakota) 701 E. 6011 Lane Sroux Falls, SD 571.1.7 _ SPIT ,cabosozcsnw ply )2 1P $ �+ )003194302 OC• 4AILED FROM ZIP CC 3 PA Department of Revenue�r� 109 Louisa Lane Mechanicsburg, PA 171287 4('7.- / V1' ' � sr:�i 4 Members First Credit Union 5000 Louisc Drive Mechanicsburg, PA 17055 / ( OCT $ Zoic , "' ) 5 Tenants/Occupants 3010 Morningside Drive Camp Hill. Pa 170111 6 '\`;S ,........--` 7 Total Number of Pieces Listed by Sender 5 C V\C' h 61 t r. t--� t V J I POSTMASTER 'ER (Name of rec: ving em. eyee) '' The full declaration of va ue is required on all domestic and international registered mail. The maximum indemnity payable for nonnegotiable documents under Express Mail document reconstruction insurance is S50,000 per piece subject to a limit of S50,000 per occurrence. The maximum indemnity payable on Express Mail merchandise insurance is S500. The maximum indemnity payable is S25,000 for Registered Mail, $500 for COD and $500 for Insured Mail. Special handling charges apply only to Third- and Fourth -Class parcels. Special delivery service also includes special handling service. PS FORM 3877 {00401770} Name and File Number FOR REGISTERED, INSURED, C.O.D., CERTIFIED, AND EXPRESS MAIL NAME AND ADDRESS OF SENDER INDICATE TYPE OF MAIL. CHECK APPROPIATE BLOCK FOR POSTMARK AND DATE OF Powers, Kirn & Associates 1310 Industrial Boulevard, Suite 101 Southampton, PA 18966 X Certificate Mailing 0 Insured 0 COD 0 Certified Mail Registered Mail: 0 With Postal Insurance 0 Without. Postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Line Number of Article Name of Addressee, Street, and Post -Office Address Postage Fee Handling Charge Act. Value Of Regis.) Insured Value Due Sender if C.O.D. R.R. Fee S.D. Fee S.H. Fee Rest. Del. Fee --------- Remarks 1 Lower Allen Township 2233 Gettysburg Road Camp Hill, PA 170112 _ F.a •- s • 9g Q•�� 4 3 ' 4 '- j �rLI���QQ V"(SI �et,i - • •' ,.. is $25,Uw handling delivery ..., , I 69-,.., c.,..„:4 1%:i` Q. �' o iron 6 rya ooQ . Express payable Special Special '• .w ti ' Total Number of Pieces Listed by Sender POSTMASTER, PER (Name of receiving employee) rC ( ! The full declaration of value is a registered mail. The maximum documents under Express Mai S50,000 per piece subject to a .,.. maximum indemnity payable on S500. The maximum indemnity for COD and S500 for Insured Mail. Third- and Fourth -Class parcels. special handling service. .. V rational able ince is The ._The ,urance is Mail. S500 charges apply only to service also includes PS FORM 3877 (00401776) File Name nd Number f �j"fatltt4 FOR REGISTERED, INSURED, C.O.D., CERTIFIED, AND EXPRESS MAIL POWERS, KIRN & ASSOCIATES, LLC JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252 JOLANTA PEKALSKA, ESQUIRE Id No. 307968 HARRY B. REESE, ESQUIRE Id No 310501 DANIEL C. FANASELLE, ESQUIRE Id No. 312292 MATTHEW J. MCDONNELL, ESQUIRE Id No. 313549 1310 INDUSTRIAL BOULEVARD 2nd Floor, SUITE 202 SOUTHAMPTON, PA 18966 215-942-2090 CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMRO MORTGAGE GROUP, INC. vs. MICHAEL T. CHANDLER KAY L. CHANDLER A/K/A KAY L. MYERES COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 13-5979 NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for December 3, 2014 at 10 A.M. in the above -captioned matter has been continued until March 4, 2015 at 10 A.M. Date: Z -'L Prs,`Kirn & Associates, C ❑Jill Manuel -Coughlin, Esq 're Id. No. 63252 ❑Jo)ta Pekalska, Esquire, d. No. 307968 arry B. Reese, Esquire, Id. No. 310501 ❑Daniel C. Fanaselle, Esquire, Id. No. 312292 ❑Matthew J. McDonnell, Esquire Id. No. 313549 Attorneys for Plaintiff