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HomeMy WebLinkAbout13-6266 p, Supreme Count of Pennsylvania COU ( ':O � M 011 y 'leas For Prothonotary Use Only: ? Cv4 �Ctt3!ver�Sheet Docket No: ) a` CUfBERLAIVD' �y County 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 x Complaint [3 Writ of Summons ® Petition Transfer from Another Jurisdiction r-1 Declaration of Taking °E C Lead Plaintiff's Name: Lead Defendant's Name: T CITI MORTGAGE, INC., SUCCESSOR BY MERGERTO,J DAVID L. WRIGHTSTONE & EMILY A. WRIGHTSTONE Dollar Amount Requested: Elwithin arbitration limits I Are money damages requested? 0 Yes 0 No (check one) E]outside arbitration limits O N Is this a Class Action Suit? ® Yes 0 No Is this an MDJAppeal? Yes 0 No A Name of Plaintiff /Appellant's Attorney: POWERS, KIRN & JAVARDIAN, LLC L_ ® Check here if you have no attorney (are a Self - Represented [Pro Sej Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution Q Debt Collection: Credit Card 0 Board of Assessment E] Motor Vehicle Debt Collection: Other El Board of Elections 0 Nuisance ® Dept. of Transportation S 1] Premises Liability Q Statutory Appeal: Other Product Liability (does not include mass tort) n Employment Dispute: E 0 Slander/Libel/ Defamation Discrimination C n Other: Employment Dispute: Other [3 Zoning Board T [3 Other: .I Other: O MASS TORT El Asbestos N [3 Tobacco l- Toxic Tort -DES © Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste ® 1 Ejectment Other: J Common Law /Statutory Arbitration B El Eminent Domain /Condemnation Declaratory Judgment OJ Ground Rent [3 Mandamus ® Landlord/Tenant Dispute Non- Domestic Relations F Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY n Mortgage Foreclosure: Commercial Quo Warranto l- Dental M Partition 13 Replevin El Legal lA Quiet Title M Other: Medical Other: Other Professional: r Updated 1/1/2011 POWERS, KIRN & JAVARDIAN, LLC Gregory Javardian, Esquire Id No. 55669 i' 1 -'?t" Jill Manuel - Coughlin, Esquire Id No. 63252 k i (rte �� z�� (;�. (i TN �s Mary F. Kennedy, Esquire Id No. 77149 Meghan K. Boyle, Esquire Id No. 201661 f� #fir' �: Sean P. Mays, Esquire Id No. 307518 Daniel C. Fanaselle, Esquire Id No. 312292 C U; , R L A 1j l) CC i .Y Richard J. Nalbandian, III, Esquire Id No. 312653 P ti,J y L`A i 1310 Industrial Boulevard, Suite 202 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 0 n/,, a NO. � —� ? tL�l.(J VS. COMPLAINT IN MORTGAGE FORECLOSURE DAVID L. WRIGHTSTONE EMILY A. WRIGHTSTONE 205 WEST MAIN STREET NEWBURG, PA 17240 _ 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 /02 �s � C7 aol -7 3s� 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. i 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, 111, Esquire Id No. 312653 1310 Industrial Boulevard, Suite 202 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 DAVID L. WRIGHTSTONE EMILY A. WRIGHTSTONE 205 WEST MAIN STREET NEWBURG, PA 17240 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. David L. Wrightstone and Emily A. Wrightstone (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 November 15, 2005, was recorded on November 21, 2005 in the Office of the Recorder of Deeds in Cumberland County in Mortgage Book 1931, Page 3241. A copy of the Mortgage is attached and made a part hereof as Exhibit 4 A 1 . 4. The Mortgage secures the indebtedness of a Note executed by the Defendants on November 15, 2005 in the original principal amount of $66,700.00, which is payable to Plaintiff in monthly installments with an interest rate of 6.375 %. A copy of the Note is attached and made a part hereof as Exhibit `B'. 5. The land subject to the mortgage is 205 West Main Street, Newburg, PA 17240. A copy of the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated herein. 6. The Defendants are the Record Owners of the mortgaged property located at 205 West Main Street, Newburg, PA 17240. 7. The Mortgage is now in default due to the failure of Defendants to make payments as they became due and owing. As a result of the default, the following amounts are due: Principal Balance $59,840.38 Interest to 10/05/2013 $2,902.91 Accumulated Late Charges $145.60 Inspections $40.50 Escrow Advance Balance $2,895.81 O/S BPO Fee $150.00 Release Fee $55.50 TOTAL $66,030.70 plus interest from 10/06/2013 at $10.4516 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. 11. 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 April 5, 2013. A copy of the Notice is attached and made a part hereof as Exhibit `C'. 11 ry WHEREFORE, Plaintiff requests the court enter an in rem judgment against the Defendants, in the sum of $$66,030.70, 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 ❑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 Maniel C. Fanaselle, Esquire Id. No. 312292. ❑ Richard J. Nalbandian, III, Esquire Id. No. 312653 .Attorneys for Plaintiff YL��,flklB IT U q S t� � 1-800-542-9512 �( GAIL DECKER l�S " INTERINTERFIRSTEDRIVSMORTGAGE LENDIN YI ANN ARBOR, HI 48108 When recorded mail tot - ABN AMRO MORTGAGE GROUP INC. 1201 EAST LINCOLN MADISON HEIGHTS MICHIGAN 48071 -4171 1au ATTR t FINAL /TRAILING DOCUMENTS U P� v APN f: APN #: � [Space Above This Una For Recording Dam] MORTGAGE DEFINITION Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11, 13, 18,20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 16. (A) "Security Instrument" means this document, which is dated NOVEMBER 15, 2005, together with all Riders to this document. (B) "Borrowel"is DAVID L WRIGHTSTONE AND EMILY A WRIGHTSTONE, HUSBAND AND WIFE. Borrower is the mortgagor under this Security Instrument (C) "Lender"is ABU AMRO MORTGAGE GROUP, INC. Lender is a CORPORATION organized and eAsting under the laws of DELAWARE. Lender's address is 2600 W. BIG BEAVER RD., TROY, MICHIGAN 48084. Lender is the mortgagee under this Security Instrument. Initials s - PENNSYLVANIA- Single Family-- Fannle Mae/Preddre Mac UNIFORM INSTRUMENT Form 30391 0 1999.2004 Online Documents, Inc. Page 1 of 14 PAUDEED PAUDEDL 0411 11 -14 -2005 6146 SKI 931 PG324 I LOAN Ili =773 (p) "Note" means the promissory note signed by Borrower and dated NOVEMBER 15, 2005. The Note states that Borrower owes Lender r; at+ }Y } RY } } }r } Rr *YY # Rrtw } } #r } *SIXT2 SIX THOUSAND SEVEN HUNDRED AND NO /100 Dollars (U.S. $66,700.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than DECEMBER 1, 2035. (E) " Property" meansthepropertythatisdescribedbelowundertheheading "TransferofRightsinthe Property." (F) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due under the Note, and all sums due under this Security Instrument, plus interest. (G) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicable): =Adjustable Rate Rider =Condominium Rider =Second Home Rider =Balloon Rider =Planned Unit Development Rider =Other(s) (specify] =1-4 Family Rider =Biweekly Payment Rider =V.A. Rider (H) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and administrative rules and orders (thathave the effectof law) as well as all applicable final, non - appealable judicial opinions. (I) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (J) " ElectronicFundsTransfel" meansanytransferoffunds, otherthanatransactionoriginatedbycheck, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an account. Such term Includes, but is not limited to, point-of -sale transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers. . (K) "Escrow Items" means those items that are described in Section 3, (L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or pro- ceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (Iv) misrepresentations of, or omissions as to, the value and /or condition of the Property. (M) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the Loan. (N) "Periodic Payment" means the regularly scheduled amount due for n principal and interest under the Note, plus (1i) any amounts under Section 3 of this Security Instrument. (0) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. §2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed In regard to a "federally related mortgage loan" even it the Loan does not qualify as a "federally related mortgage loan" under RESPA. (P) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or not that party has assumed Borrower's obligations under the Note and /or this Security Instrument TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrument secures to Lender: () the repayment ofthe loan, and all renewals, extensions and modifications of the Note; and (11) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant d convey o Initials, (� PENNSYLVANIA - Single Family - Fannin Mae /Fraddla Mae UNIFORM INSTRUMENT Form 30391/01 ® 1999 -2004 Online Documents, Inc Page 2 of 14 PAUDEDL 0411 11 -14 -2005 6146 BK1931PG3242 ti: Lender the following described property located in the COUNT LOAN 773 iType of Recording Jurisdiction] Of CUMBERLAND IName of Recording Jurisdiction]: SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF. which currently has the address of 205 W MAIN ST, NEWBURG, [street) icyyl Pennsylvania 17240 ( "Property Address "): lZi Code] TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to In this Security Instrument as the "Property." BORROWER COVENANTS that Borrower Is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property Is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non - uniform covenants with limited variations by jurisdiction to constitutea uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S. currency. However, N any check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security instrument be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, withoutwaiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not ap lied earile(, initials, +-�- PENNSYLVANIA-Single Family-Fannie Moo/Freddie Mac UNIFORM INSTRUMENT Form 30.191101 m 1999-2004 Online Documents, Inc. Page 3 of 14 PAUDEDL 0411 11 -14 -2005 6e46 SK 1931 PG3243 LOAN #: 16773 such funds will be applied to the outstanding principal balance under the Note Immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrowerfrom making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described In this Section 2, all - payments accepted and applied by Lender shall be applied in thefollowing order of priority-. (a) interest due under the Note; (b) principal due underthe Note; (c) amounts dueunder Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. M Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be appliedto any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3. Funds for Escrow Items, Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note is paid in full, a sum (the "Funds') to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender In lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These Items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, in any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lenderwaives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing- In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due forany Escrow Items for which payment of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall forall purposes be deemed to be a covenantand agreement contained In this Security Instrument, as the phrase "covenant and agreement" is used in Section 9. if Borrower is obligated to pay Escrow Items directly, pursuant to awaiver, and Borrowerfails to paythe amountdueforan Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 910 rep ay to Lender any such amount Lender may revokethewaiver as to any orall Escrow Items at anytime by a noticegiven in acccrdancewith Section 15 and, upon such revocation, Borrower shall pay to Lender al Funds, and in such amounts, that are then required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficientto permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, it Lender is an institution whose deposits are so insured or Initials: G ZV PENNSYLVANIA - Single Family-- Fannle MaelFreddle Mee UNIFORM INSTRUMENT Form 30391/01 6:999 -2994 Online Documents, Inc. Page 4 of 14 PAUDEDL 04:: 11 -14 -2005 6 :46 9K 1931 PG3244 LOAN tl: -8773 in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless tender pays Borrower interest on the Funds and Applicable law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable taw requires interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held In escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there Is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Chargos; Ltena. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3. 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, butonly so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded; 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 ofthe Property is subject to a lien which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above In this Section 4. Lender may require Borrower to pay a one -time charge for a real estate tax verification and /or reporting service used by Lender in connection with this Loan. S. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one -time charge for flood zone determination, certification and tracking services; or (b) a one -time charge for flood zone determination and certification services and subsequent charges each time remappings or similar changes occurwhich reasonably might affectsuch determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. If Borrower fails to maintain any ofthe coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense, Lender is under no obligation to urchas ny� Initials: W PENNSYLVANIA - Single Family - Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 0039//01 ® 1995.2004 Online Documents, Inc. Page 5 of 14 PAUDEDL 0411 11 -14 -2005 6146 9K 1931 PG3245 V LOAN #s =8773 particular type oramountofcoverage. Therefore, such coverage shall cover Lender, but might or might not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Instrument These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and /or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of Insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payee. in the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss d not made promptly by Borrower. Unless Lender and Borrower otherwise agree In writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such Inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as thework Is completed. Unless an agreement Is made in writing orApplicable Law requires interestto be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees forpublic adjusters, crotherthird parties, retained by Borrower shall notbe paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economlcallyfeasible or Lender's security would be lessened, the insurance proceeds shall be appledto the sums secured bythis Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in Section 2. If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related matters. if Borrower does not respondwithin 30 days to a notice from Lenderthat the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30- day period will begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the Insurance proceeds either to repair or restore the Property orto pay amounts unpaid under the Note or this Security instrument, whether or not then due. S. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as Borr ower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property, Inspection& Borrower shall not destroy, damage cr impairthe Property, allow the Property to deteriorate or commitwaste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Properly in order to prevent the Property deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section 5 thatrepairorrestorationisnateconomicallyfeasible, Borrower shelf promptly repa' e ry�PJ�ropeerArty_ initials s PENNSYLVANiA -angle Family- Fannle Mae /Freddie Mac UNIFORM INSTRUMENT Form 3c3a o ® 1999 -2004 online Documents, Ins. Page 6 of 14 PAUDEDL 0411 11 -14 -2005 6146 8!(1931 PG3246 r Irr # 773 it damaged to avoid further deterioration or damage. H insurance or condemnation n p prose s aze p — aid In connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only it Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in asingle payment or In a series of progress payments as the work is completed, lithe insurance or condemnation proceeds are notsuffiaent to repair orrestore the Property, Borrower its not relieved of Borrower's obligation for the completion of such repair or restoration. Lender or its agent may make reasonable entries upon and inspections of the Property. If It has reasonable cause, Lender may inspect the interior of the Improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an Interior Inspection specifying such reasonable cause. S. Borrower's Loan Application. Borrower shall be In default it, during the Loan application process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, misleading, or inaccurate Information or statements to Lender (or failed to provide Lender with material information) in connection with the Loan. Material representations include, but are notlimited to, representations concerning Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest In the Property and Rights Under this Security Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a legal proceeding that might significantly affect Lender's interest in the Property and /or rights under this Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and•rlghts under this Security Instrument, including protecting and /orassessing the value of the Property, and securing and/ or repairing the Property. Lender's actions can include, but are not limited to; (a) paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable attorneys' fees to protect its interest In the Property and /or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, butis not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. it is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument, These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such Interest, upon notice from Lender to Borrower requesting payment. H this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. Borrower shall not surrender the leasehold estate and interests herein conveyed or terminate or cancel the ground lease. Borrower shall not, without the express written consent of Lender, alter or amend the ground lease. 11 Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Mortgage Insurance. if Lender required Mortgage Insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain the Mortgage Insurance In effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such Insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortga a In uran e� Initials: PENNSYLVANIA - Single Famity •Fannle Mae /Froddta Mac UNIFORU INSTRUMENT Form 30391/01 m l9s9-2W4 onrne, Documents, Inc. Page 7 of 14 PAUDEM 0411 IL -14 -2005 6:46 BK 1931 PG3247 LOAN It =773 l coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a non - refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non - refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such loss reserve. Lendercan no longer requireloss reserve payments if Mortgage Insurance coverage (in theamount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage insurance. if Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage insurance in effect, or to provide a non- refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lende? providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses itmay incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into agreements with other parties that share or modify their risk, or reduce losses. These agreements are on terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. These agreements may require the mortgage insurer to make payments using any source offends that the mortgage insurer may have available (which may include funds obtained from Mortgage Insurance premiums). As a resultof these agreements, Lender, any purchaser ofthe Note, another insurer, any reinsurer, any other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchangefor sharing or modifying the mortgage insurer's risk, orreducing losses. ff such agreement provides that an affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid to the Insurer, the arrangement is often termed "captive reinsurance," Further: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not Increase the amount Borrower will owe for Mortgage Insurance, and they will not eW* Borrower to any refund (b) Any such agreements will not affect the rights Borrower has - If any - with respect to the Mortgage Insurance under the Homeowners Protection Actof 1998 oranyotherlaw. These rights may include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any Mortgage Insurance premiums that were unearned atthe time of such cancellation or termination. 11. Assignmentof Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair ofe Property, lithe restoration or repair is economically feasible and Lender's security is notlessened. During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to Inspect such Property to ensure the work has been completed to Lender's satisfaction, provided thatsuch inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any Interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would be lessened, the Miscellaneous Proceeds shall be applied tothe s secured Initials, PENNSYLVANIA - Single Family- Fannle Mae /Freddie Mac UNIFORM INSTRUMENT Form 3039lAn 0 1999.2004 Online Documents, Inc. Page 8 of 14 PAUDEDL 041 f 11 -14 -2005 6:46 BK 1931 PG3248 s , LOAN #s 773 by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of th a Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property Immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following traction: (a) the total amount of the sums secured immediately before the partial taking, destruction, orloss in value divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower. In the event of a partial taking, destruction, or lass in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lenderto Borrower that the Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower falls to respond to Lender within 90 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's judgment, could result In forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, it acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument The proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy including, without limitation, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the exercise of any right or remedy, 13, Joint and Several Liability; Co- signers; Successors and Assigns Bound. Borrower cov- enants and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrowerwho co -signs this Security Instrument but does not execute the Note (a "co- signer "): (a) Is co- signing this Security Instrument only to mortgage, grant and convey the cc- signer's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to th sums Initials PENNSYLVANIA - Single Family- Fannle Mae /Fraddle Mac UNIFORM INSTRUMENT Form 30391/01 ® i9g9.2004 Onlina Documents. Inc. Page 9 of 14 PAUDEDL 0411 11 -14 -2005 6:46 BK 193 1 PG3249 4 � LOAN tl: M773 secured by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without the co-signer's consent. Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's obligations underthis Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and agreements of this Security Instrument shall bind (exceptas provided In Section 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but notlimited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower shall notbeconstrued as a prohibition on the charging of suchfee. Lender may not charge fees that are expressly prohibited by this Security Instrument or by Applicable Law, If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected In connection with the Loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct paymentto Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 15. Notices. All notices given by Borrower or Lender in connection with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrumentshall be deemed to have been given to Borrowerwhen mailed by first class mail or when actually delivered to Borrower's notice address ff sent by other means. Notice to anyone Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only report a change of address through that specified procedure. There may be only one designated notice address under this Security Instrument at any one time. Any notice to Lender shall be given by delivering it or by mailing it by first class mail to Lender's address stated herein unless Lender has designated another address by noticeto Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been given to Lender until actually received by Lender, tf any notice required by this Security Instrument is also required under Applicable Law, the Applicable Law requirement will sail sty the corresponding requirement under this Security Instrument. 16. Governing Lew; Severabllity; Rules of Construction. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations contained in this Security instrument are subject to any requirements and limitations of Applicable Law, Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but such silence shall notbe construed as a prohibition against agreement by contract. 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. As used in this Security Instrument: (a) words of the masculine gender shall mean and include corresponding neuterwords or words of the feminine gender; (b) words in the singular sWm initials: PENNSYLVANIA- Singla Famlly- Fannle Mae /Freddie Mae UNIFORM INSTRUMENT Form 30391/01 0186 &2004 Online Documents. Inc. Page 10 of 14 PAUOEDL 0411 11 -14 -2005 6 :46 BK 1931 PG3250 r j LOAN R: -8773 include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take any action. 17. Borrower's Copy. Borrower shall be given one copy ofthe Note and ofthis Security Instrument. 18. Transfer of the Property or a Beneficial interest In Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interestin the Property, including, butnot limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract ores crow agreement, the intent of which is the transfer oftitle by Borrower at afuture date to a purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial Interest In Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice Is given in accordance with Section _ 15 within which Borrower must pay all sums secured by this Security Instrument. if Borrower fails to pay these sums prior to the expiration of this period, Lender may Invoke any remedles permitted by this Security Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. if Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of- (a) five days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any defaultof any othercovenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attomeys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Properly and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Propertyand rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by afederal agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18, 20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower. A sale might result in a change in the entity (known as the 'Loan Servicer'? that collects Periodic Payments due underthe Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will beg iven written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing obligations to Borrowerwill remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security Instrument orthatalleges that the other party has breached any provision of, ora utyo ed Initialsr PENNSYLVANIA—Single Famlly-- Fannle Mao/Freddie Mac UNIFORM INSTRUMENT Form 30381/01 ® 1899.2004 Online Documents, Inc. Page 11 of 14 PAUDEDL 0411 11 -14 -2005 6 :46 BK t 931 PG325 I j LOAN Or =773 by reason of, this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take corrective action. It Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, orwastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos orformatdehyde, and radioactive materials; (b) "Environmental Law" means federal laws and laws of thejurisdictfon where the Property is located that relate to health, safety or environmental protection; (e) *Environmental Cleanup' includes any response action, remedial action, or removal action, as defined In Environmental taw; and (d) an "Environmental Condition "means acondition thatcan cause, contribute to, or otherwise trigger an Environmental Cleanup. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous - Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. 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 (including, but not limited to, hazardous substances in consumer products). Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. NONUNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement In this Security Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default (c) when the default must be cured; and (d) that failure to curothe defoultas specified may result In acceleration of the sums secured by this Security instrument, foreclosure by Judicial proceedmg and sale of the Property. Lender shall further Inform Borrowerof the right to reinstate attar acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure. If the default Is not cured as specified, Lender at its option mayrequlre Immediatepayment Infuil otall sumssecured by this Security Instrument withoutfurther demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred In pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable law. 23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurr L er Initials$ PENNSYLVANIA- Singlefamily- Fannis Mae/Freddie Mae UNIFORM INSYRUMENr Form 30391/01 ® 1889 -2004 Online Documents, Inc. Page 12 of 14 PAUDEDL 0411 11 -14 -2005 Gt46 BK 1931 PG3252 LOAN #:�773 • shall discharge and satisfy this Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower afee for releasing this Security Instrument, but only ifthe fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error j or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any f ( present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument 26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquiretitle tothe Property, this Security Instrument shall be a purchase money mortgage. 27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or In an action of mortgage foreclosure shall be the rate payable from time to time under the Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. QL (seal) DAVID L WRI ITS• t8 _ (Seal) EMILY A 1 I IT ON& PENNSYLVANIA - single Family- Fannie MaelFraddie Mac UNIFORM INSTRUMENT Form 30391/01 O 1998.2004 Online Documents, Inc. Page 13 of 14 PAUDEDL 0411 _ 11 -14 -2005 6146 8K1931PG LOAN #s =773 Commonwealth of PENNSYLVANIA County of Cumberland On this, the 15th day of November, 2005 before me, k , the undersigned officer, personally appeared F DAVID L NRIGHTSTONE AND EMILY A NRIGHTSTONE, known to me (or satisfactorily proven) to be the person whose name(s) is /are subscribed to the within instrument and acknowledged that he /sbe /they executed the same for the purposes therein contained. In witness whereof I hereunto set my hand and o al seal. My commission expires I I NOTARIAL SEAL Title of officer RENEE L MURRAY. Notary Public Carlisle OM, Cumberland County, PA 'Cy Com fton Figures Oec. 13, 2005 J i Certificate of Residence I, George F nglars, W T I hereby certify that the correct address of the MN n -named Mortgagee Is 2600 N. SIG B EAVER RD. , TROY MICHIGAN 48084 Witness my hand this 5th day of A5 ge t. Douglas, Ag7il of Mortgagee Initials s a V " PENNSYLVANIA- Single Family- Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1/01 ® 1999 -2004 Online Documents, Inc. Page 14 of 14 PAUDEDL 0411 11 -14 -2005 6:46 BK1931PG j Exhibit A ALL that certain tract of land with improvements thereon situate in the Borough of Newburg, bounded and described as follows: i ON the South by Main Street; on the East by property now or formerly of Thompson Hamond; on the North by an alley; and on the West by an alley and property now or formerly of Ellis Hefllefinger. Said lot having frontage on Main Street of Forty (40) feet, more or less, and a depth of One Hundred Sixty -nine (169) feet, more or less. CC V Cun 1b 31PG3255 EX LOAN # =773 NOTE NOVEMBER 15, 2005 CARLISLE, PENNSYLVANIA [Date] [C1ty] [State] 205 W MAIN ST, NEWBURG, PA 17240 [Property Address] 1 BORROWERS PROMISE TO PAY In return for a loan that I have received I promise to pay U S $66,700 00 (this amount is called Principal ) plus interest to the order of the Lender The Lender is ABU AMRO MORTGAGE GROUP, INC , A DELAWARE CORPORATION I will make all payments under this Note in the form of cash check or money order i understand that the Lender may transfer this Note The tender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the Note Holder 2 INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid i will pay interest at a yearly rate of 6 375% The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note 3 PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month 1 will make my monthly payment on the 1sT day of each month beginning on JANUARY 1, 2006 1 will make thesepayments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal If on DECEMBER 1, 2035, 1 still owe amounts under this Note I will pay those amounts in full on that date which is called the Maturity Date will make my monthly payments at 4242 N HARLEM AVE HORRIDGE, IL 60706 ATTN CASHIERING or at a different place if required by the Note Holder (B) Amount of Monthly Payments My monthly payment will be in the amount of U S $416 12 4 BORROWERS RIGHT TO PREPAY I have the right to make payments of Principal at anytime before they are due A payment of Principal only is known as a Prepayment When 1 make a Prepayment I will tell the Note Holder in writing that i am doing so I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note I may make a full Prepayment or partial Prepayments without paying a Prepayment charge The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note However the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount before applying my Prepayment to reduce the Principal amount of the Note If I make a partial Prepayment there will be no changes in the due date or rn the amount of my monthly payment unless the Note Holder agrees in writing to those changes 5 LOAN CHARGES If a law which applies to this loan and which sets maximum loan charges is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits then (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit and (b) any sums already collected from me which exceeded permitted limits will be refunded to me The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me If a refund reduces Principal the reduction will be treated as a partial Prepayment 6 BORROWER S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due t will pay a late charge to the Note Holder The amount of the charge will be 5 000% of my overdue payment of principal and interest I will pay this late charge promptly but only once on each late payment (B) Default If I do not pay the full amount of each monthly payment on the date it is due i will be in default (C) Notice of Default If I am in default the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means (D) No Waiver By Note Holder Even if at a time when I am in default the Note Holder does not require me to pay immediately in full as described above the Note Holder will still have the right to do so tf I am in default at a later time initials MULTISTATE FIXED RATE NOTE Single Family Fannie Mae/Freddis Mac UNIFORM INSTRUMENT Form 32001/ot 0 1999 2004 Online Documents Inc Page 1 of 2 F3200NOT 0401 11 -14 -2005 6 46 fl (E) Payment of Note Holder s Costs and Expanses LOAN 773 If the Note Holder has required me to pay immed,ately in,full as described above the Note Holder will have the right to be paid back by me for ail of Its costs and expenses In enforcing this Note to the extent not prohibited by applicable law Those expenses Include for example reasonable attorneys fees 7 GIVING OF NOTICES Unless applicable law requires a different method any notice that must be given to me under this Note will be given by delivering It or by mailing it by first class mad to me at the Property Address above or at a different address if 1 give the Note Holder a notice of my different address Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mad to the Note Holder at the address stated in Section 3(A) above or at a different address If I am given a notice of that different address 8 OBLIGATIONS OF PERSONS UNDER THIS NOTE It more than one person signs this Note each person Is fully and personally obligated to keep ail of the promises made m this Note including the promise to pay the full amount awed Any person who is a guarantor surety or endorser of this Note is also obligated to do these things Any person who takes over these obligations including the obligations of a guarantor surety or endorser ofthis Note is also obligated to keep all of the promises made in this Note The Note Holder may enforce its rights under this Note against each person Individually or against all of us together This means that any one of us may be required to pay all of the amounts awed under this Note 9 WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor Presentment means the right to require the Note Holder to demand payment of amounts due Notice of Dishonor means the right to require the Note Holder to give notice to other persons that amounts due have not been paid 10 UNIFORM SECURED NOTE This Note is a uniform Instrument with limited variations in some jurisdictions In addition to the protections given to the Note Holder under this Note a Mortgage Deed of Trust or Security Deed (the Security Instrument ) dated the same date as this Note protects the Note Holder from possible losses which might result if i do not keep the promises which l makein this Note That Security Instrument describes how and underwhat conditions l maybe required to make immediate payment in full of all amounts I owe under this Note Some of those conditions are described as follows If all or any part of the Property or any Interest in the Property Is sold or transferred (or d Borrower Is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender S priorwritten consent Lender may require immediate payment in full of all sums secured by this Security instrument However this option shall not be exercised by Lender it such exercise is prohibited by Applicable Law If Lender exercises this option Lender shall give Borrower notice of acceleration The notice shall provide a period of not less than 30 days from the date the notice Is given In accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument If Borrower fails to pay these sums prior to the expiration of this period Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower WI NESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED r (Seal) (Baal) DAVSD L NRIOMTSTONE EMr Y A I FITS ONE PAY TO THE ORDER OF NITHOUT RECOURSE A ABN RO MOR'TQAGE t3ROUP iNC p - rd�t5lAr_bt (Sign Original Only] MULTISTATE FIXED RATE NOTE S;ngle Family Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 5200 1/01 ® 1999 2004 Online Documents Inc Page 2 of 2 F3200NOT 0401 - I1 -14 -2005 6 46 Not I I 40�� BIT C' I I f ClflNlortgage, Inc PRESORT ? PO Box 9090 First -Class Mail Temecula, CA 92589 -9090 U.S- Postage and Fees Paid WSO 7196 9006 9296 6422 3865 send Payments to: GIONIctgage, Inc PO Box 689196 Des Mane;, IA 50368.9196 i. 20130405 -168 i'����h"' III' I � I �' I 1 }f� DAVID L WRIGHTSTONE PO BOX 221 Send Correspondence trr NEW BURG, PA 17240 -0221 CitiMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75053 i j i w i I I i 'Y 1� i CITIPAACT91 i I i i Date: 04/05/2013 Sent Via Certified Mail 7196 9006 9296 6422 3865 DAVID L WRIGHTSTONE PO BOY 221 NEWBURG, PA 17240 -0221 i RE: Property Address: 205 W MAIN ST NEWBURG, PA 17240 I CitNortgage Loan #: 8773 I i .ACT 91 NOTICE TAI�E ACTION TO SAVE i YOUR BIOME 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 i the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help save your home. This Notice explains how the program works. ' i To see if HE111AP can help, you must MEET WITH A CONSUMER CREDIT I COUNSELING AGENCY WITHTN 33 DAYS OF THE DATE OF THIS NOTICE. Talce this Notice with you when you meet with the Counseling Agency. I 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 (880) 342 -2397 (Persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, CITIPAACT91 Page 2of9 7196 9006 9296 6422 3665 i 1 I 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 NOTMCACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTLNUAR VMENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION ? INMEDIATAIVIENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SLN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRtSTAMO POR EL PROGRAMA LLAMAUO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVA R SU j CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. i HOMEOWNEWS NAME(S): DAVID L WRIGHTSTONE EMILY A WRIGHTSTONE PROPERTY ADDRESS: 205 W MAIN ST NEWBURG, PA 17240 , LOAN ACCT. NO.: =8773 f ORIGINAL LENDER ABN AMRO MORTGAGE GROUP, INC. s CURRENT LENDER/SERVIGER: CitiMortgage, EaG. i 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 PA EVENTS 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 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 - Mth one of the consumer credit counseling agencies listed at the end of this Notices THIS MEETING ,'t-fUST OCCUR WITHIN TMRTY- THREE (33) DAYS OF THE DATE OF TEAS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUSS` BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOMY TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOMY TO BRING YOUR MORTGAGE UP TO DATE. C0NSU1WR 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 5 Page 3 of 9 i (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 AIORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth s later in this Notice (see following pages for specific information about the nature of your default). You have f 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 APPLICATION AS SOON AS POSSIBLE IF YOU HAYE 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 AfEETING THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS I EXPLAINED ABOYE, IN THE SECTION CALLED -TEMPORARY STAY OF FORECLOSURE." you HAVE THE RIGHT TO FILE A HENLIP APPLICATION EYEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREYENT THE LENDER FROAf 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 fiends for emergency mortgage assistance are very limited They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. x CITIPAACT91 7196 9 006 9296_ 3865 Paga4of9 i 1 I 1 NOTE.-,TFYOUARECU,RREIYTLYP,ROTECTED BY THE FILING OFA PETITION 1NRANMZUPTC7, THE I FOLLOW17VG PART OF THIS NOTICE IS FOR INFORMATIONPURPOSES ONLYAND SHOULD NOT ,8.E CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT: i (If you leave filed bankruptcy, you can still apply jar Emergency Mortgage Assistance.} - HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it rap to date). NATURE OF TILE DEFA ULT - The MORTGAGE debt held by the above lender on your property located at: 205 W MAIN ST INEWBURG, PA 17240 j IS SERIOUSLYINDEFAULT because: 1 YOU HAYS NOT AU DE MONIIILY MORTGAGE PAYMENTS for the following months and the following amounts are nowpast due, ( i 02/01/13 through 04 /01/13 3 @ $1035.12 /month 2 @ $20.80/late charge /month i 53146.96 i Previous Late Charge(s): $p.00 Delinquency Expense(s): $13.50 Unapplied Funds: TOTAL AMOUNT PAST DUE: $3,160.46 HOW TO CURE THE DEFAULT - You may care the default within TMRTY (3 0) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WIHCHIS 13,160.4 6, PLUS ANYMORTGAGE PAYMENTS AND LATE CHARGES MCHBECOME DUE 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 12218 Tucson, AZ 85732 -2218 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (3 0) 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 f dl payment of the total amount past due is not made within 2WRTY (30) DAYS, the lender also intends to instruct its attorneys to star/ 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 off the mortgage debt. If the lender refers your care to its attorney's, 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 $5a 00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually inewred 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 (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 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 zip to one hour before the Sheriffs Sale. You may do so by paying the total amount then CITIPAACT91 Page 5 of 9 ! i ! post 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 under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. ' EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 mouths 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. ' t HOW TO CONTACT THELE'NDER: i r i Name of Lender: CitiMortgage, Inc. Address: P.O. Box 12218. i Tucson, AZ 85732 -2218 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 i Puerto Rico. Fax Number: 1- 866 -940 -8147 Contact Person: MarkAnthony Hartland E -Mail Address: markanthony.b.hartland @citi.com EFFECT OF SHERIFFS SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property atler the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUAIPTION 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. FOUMAI` ALSO RAVE THE RIGHT. * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES N 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. CITIPAACT91 Page 6 of 9 t � L CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST Tn 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, Citublortgage, Inc. P.O. Box 12218 Tucson, AZ 85732 -2218 CITIPAACT91 Page 7 of 9 :T 9BE16 9296 6 3969 HEMAIP Consumer Credit Counseling Agencies FRANKLIN County Report last updated: 03i 121201311:09 AM Advantage Credit Counseling 5ervice/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 -511 -2227 Community Action Commission of Capital Region Housing Alliance of York/Y Rousing Resources 1514 Derry Street 290 West Market Street Harrisburg, PA 17204 York, PA 17401 717 - 232-9757 717. 855 -2752 Maranatha PathStone Corporation 43 Philadelphia Avenue 450 Cleveland Ave Waynesboro, PA 17268 Chambersburg, PA 17201 717 - 762 -3285 717 -264 -5913 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717 -334 -1518 x'e HC Page 9of9 7196 9006 9296 6422 3865 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Rcpart last updated: 03112/201311:09 AM Advantage Credit Counseling Service /CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg, PA I7102 Harrisburg, PA 17104 888 - 511 -2227 717- 232 -9757 Housing Alliance of York/Y Housing Resources Maranatha 290 West Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717 -855 -2752 717- 762 -3285 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717- 234 -6616 717 -264 -5913 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717- 334 -1518 717- 780 -3940 800- 342 -2397 HC Page 9of9 7196 9006 1296 6422 3665 1 i CitiMortgage, Inc PRESORT PO Box 9090 Temecula, CA 92589 -9090 9090 Frst Class Mail U.S. Poslage and Fees Paid WSO 7196 9006 9296 6 3896 Send Paymentsta: CRiMortgage, Inc Pd Box 689196 Des Moines, lA 5036 8-9196 I 20130405 -168 rll �1ll��nl l�i �hfill 1 1dl i � fi � l l lil DAVID L WRIGHTSTONE 205 W MAIN ST Send Correspondence to. NEWBURG, PA 17240 -8118 CitiMortgage, Inc 5400 Las Colinas Blvd. Irving, TX 75063 TT 2 C CITIPAACT91 i r i Date: 04/05/2013 Sent Via Certified Mail 7196 9006 9296 6422 3896 DAVID L WRIGHTSTONE 205 W MAIN ST NENVBURG, PA 17240-8118 RE: Property Address: 205 W MAIN ST NEWBURG, PA 17240 CitM rtgage Loan #: 773 f ACT 91 NOTICE TAB ACTION TO SAVE YOUR HOME FROM i 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 EMERGENCY MORTGAGE ASSISTANCE .PROGRAM (RE") may be able to help save your home. This Notice explains how the program works. To see ifHE' MP can help, you must MEET WITHA CONSWIER CREDIT COUNSELING AGENCY Tff THIN 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, CITIPMCT91 Page 2 of 9 7196 90D6 4296 6422 3896 i representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTEN DO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAitiIANDO ESTA AGENCEA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA_ PUEDE SER ELEGIBLE PARA UN P1€dSTAM0 POR EL PROGRAMA L LAMAD O "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIIVUR SU HIPOTECA. i HOMEOWNER'S NAME(S): DAVID L WRIGHTSTONE EMILY A WRIGHTSTONE i PROPERTY ADDRESS: 205 W MAIN ST NEWBURG, PA 17240 LOAN ACCT. NO.: W773 ORIGINAL LENDER ABN AMRO MORTGAGE GROUP, INC. CURRENT LENDER/SERVICER CitiMortgage, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FIIVANCIAL ASSISTANCE WHICH CAN SAYE 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's, 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 ELIGIBILM REQUMEiVIENTS 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 Rith one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEET17VG MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSEL7_NG 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 7A fff Page 3 of 9 F l (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 j your intentions. r i APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth j later in this Notice (see following pages for specific 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 Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within i thirty (30) days of your face -to face meeting with the counseling agency. YOU SHOULD FILE A HF,MAP APPLICATION AS SO01V AS POSSIBLE IF YOU HA YE A AfEETING WITH j A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTAfARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE 'TEMPORARILY PREYENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSUEi:." YOU HAVE THE RIGHT TO FILE A HAVAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREYENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROYED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE RYLL 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 time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. r CiTIPAACT91 F Page 4 of 9 M NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION ILV BANKRUPTCY, TILE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONPVRPOS'ES ONLYAND SHOULD NOT.SE CONSIDERED ASANATTEMPT TO COLLECT THEDF,BT. (Ifyou have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it rip to date). N4777RE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 205 W MAIN ST NEWBURG, PA 17240 IS SERIOUSLYIN DEFAULT because: YOU HAVE NOT MADE MONTHLY 11IORTGAGE PAYMENTS for the following months Laud the following amounts are nowpast due: 02/01 /13 through 04/01/13 3 @ $1035.12/month 2 @ $20.80/late charge/month $3146.96 Previous Late Charge(s): $0.00 Delinquency Expense(s): $13.50 Unapplied Funds: $0.00 TOTAL AMOUNT PAST DUE: $3,160.46 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, WBICHIS $3.160.46, PL USANYMORTGAGE PAYbi lEMSAND LATE CHARGES WMCHBECOME DUE DURMG THE THIR7Y(3Q) DAYPERIOD Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to. CitilVlortgage, Inc. P.O. Box 12218 Tucson, AZ 85732 -2218 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 fadl payment of the total amount past due is not made within THIRTY (30) DAYS, 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 off the mortgage debt. If the lender refers your case to its attorney's, 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 incuned,, tip 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 tender 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 (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 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 anytime tip to one hour before the Sheriff's Sale. You may do so by paying the total amount then CITIPAACT91 Pave 5 of 9 f i I past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage fo the same position as if you had never defaulted. EARLIEST POSSIBLE SH.+i:'R3F'F'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 Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default i will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by I contacting the lender. NOW TO CONTACT THE LENDER: Name of Lender: CitiMortgage, Inc. i Address: P.O. Box 12218 j Tucson, AZ 85732 -2218 { 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 f Puerto Rico. - ! i Fax Number. 1- 866 -940 -8147 Contact Person: MarkAnthony Hartland E- 11fail Address: markanthony.b.hartland @citi.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the 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 0FJVORTG.4GE - 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 YOU MAF 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 THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, W YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN IEREE TIMES IN ANY CALENDAR YEAR) • TO ASSERT THE NONENISTENCE 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 TIM LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CITIPAACT91 Page 6 of 9 I CONSUMER CREDIT COUNSELI'VG AGENCIES SERVING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST In accordance with the Fair Debt Collection Practices Act, Title 15, U.S.0 1692(g), 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, CitWortgage, Inc. P.O. Box 12218 Tucson, AZ 85732 -2218 CITIPAACT91 Page 7 of 9 9196 913136 92% 6422 WiL, I IEMAP Consumer Credit Counseling Agencies FRANKLIN County Report last updated: 03112M1311:09 AM 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 -511 -2227 Community Action Commission of Capital Region housing Alliance of YorklY Housing Resources 1514 Derry Street 290 West Market Street Harrisburg, PA 17104 York, PA 17401 717 -232 -9757 717 -855 -2752 Maranatha PathStone Corporation 43 Philadelphia Avenue 450 Cleveland Ave Waynesboro, PA 17268 Chambetsburg, PA 17201 717 -762 -3285 717- 264.5913 PA Interfaitb Community Programs Inc 40 B High Street Gettysburg, PA 17325 717- 334 -1518 4C Page 8of9 7196 9006 '1296 6422 38 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 031121201311:09 AM 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 York/Y housing Resources Maranatha 290 West Market Sheet 43 Philadelphia Avenue York, PA 1 Waynesboro, PA 17268 717 - 855 -2 ?52 717 -762 -3285 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland rive I 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 i i i i HC Page 9of9 7196 9006 9296 6422 3896 1 r CANIongage, Inc PRESORT PO Box 9090 First -Class Mail Temecda, CA 92589 -9090 U.S. Postage and Fees Paid WSO ! 7196 9046 9296 6422 3919 Send Payments to CNMongage, Inc PO Box 689196 Des Moines, IA 50368 -9196 1 20130405 -168 �IIl1'J�IILIrrI} half!!} InI. I }�u��)��r�u���l�ll��,lf'Illl�ll EMILY A WRIGHTSTONE PO BOX 221 Send Correspondence to. NEWBURG, PA 17240 -0221 ! CitiMortgage, Inc 6400 Las Colinas Blvd. Irving, TX 75063 i i i i i ! i CITIPAACT91 J i 1 1 Date: 04/05/2013 Sent Via Certified Mail 7196 9006 9296 6422 3919 EMILY A WRIGHTSTONE PO BOX 221 NEWBURG, PA 17240 -0221 RE: Property Address: 205 W MAIN ST NEWBURG, PA 17240 CitiMortgage Loan #: =8773 ACT 91 NOTICE 'T'A 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 HOM'EOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEAW) maybe able to help save your home. This Notice explains how the program works. To see if HEIV" can help, you must MEET WITHA CONSUMER CREDIT COUNSELING AGENCY WITHEV 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 nay 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, s CITIPAACT91 Page 2 of 9 7196 9006 9296 6422 3919 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 fnd a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAIINIENTE LLAibMNDO ESTA AGENCIA (PENNSYLVANIA ROUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLA %4,DO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM' EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAbM(S): EMILY A TMOBTSTONE DAVID L WRIGI-ITSTONE PROPERTY ADDRESS: 205 W MAIN ST NEWBURG, PA 17240 LOAN ACCT. NO.: =773 ORIGINAL LENDER ABN AMRO MORTGAGE GROUP, INC. CURRENT LENDER/SERVICER CitNortgage, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCL4L ASSISTANCE WHICH. CAN SAVE YOUR HOAM FROM FORECLOSURE AND HELP YOU A.LME 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 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 111UST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE C PART OF THIS N077CE CALLED "HOW TO URE 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 elit 90ft 9296 6422 9914 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 nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. i 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 s lender from filing a foreclosure action, your application MUST be forwarded to PRFA and received within thirty (30) days of your face -to face meeting with the counseling agency. YOU SHOULD FILE A HEILIAP APPLICATION AS SOON AS POSSIBLE. IF YOU HA YE A JVEETING WITH A COUNSELING AGENCY WITRVV 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATIO,'v WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE TEMPORARILY PREYENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS I EXPLAINED ABOYE, EV THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE. " i YOU HAYS THE RIGHT TO FILE A HEMAP APPLIC47ION EYEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREYENT THF. LENDER FROM STARTING A FORECLOSURE' ACTION, BUT IF YOUR APPLICATION IS EYENTUALLY APPROYED AT ANY TIAIE BEFORE A 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 (SO) days to male 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 M be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. 7196 9006 9296 'c Page 4 of 9 i f NOTE: IFYOUARECURRENTLYPROTECTEDBYTHEFILINGOFAPETITIONINIIANR ?tI1PTCP, THE POLL OWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS ANA TTEMPT TO COLLECT THED1sBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF TUEDEFAULT - The MORTGAGE debt held by the above lender on your property located at: 205 W MAN ST NEWBURG, PA 17240 IS SBRIOUSLYM DEFAULT because: YOU HA YE NOT AM BE MOMITTLY �V0.RTGAGE PAEVENTS for the following months and the following amounts are nowpast due: 02/01/13 through 04 /01/13 3 @ $1035.12/month 2 @ $20.30/late chargelmonth $3146.96 Previous Late Charge(s): $0.00 Delinquency Expense(s): $13.50 Unapplied Funds: $0.00 TOTAL AMOUNT PAST D UE: $3,160.46 HOW TO CURE THE DEFA ULT - You may cure the default within THIRTY (3 0) DAYS of the date of this notice BY PAYING THE TOTAL AIVIOUNT PAST D UE TO T73E LENDER, RHICHIS ,83,160.96, PLUS ANY _MORTGAGE PAYMENTS-AND LATE CHARGES WHICHBECO & DUE 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 12218 Tucson, AZ 85732 -2218 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_ Iffull payment of the total amount past due is not made within THIRTY(30) DAYS, 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 off the mortgage debt. .If the lender refers your case to its attorney's, 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. Hoxwver, if legal proceedings are started against you, you will have to pay all reasonable attorneys fees actually incurred by the lender even if they exceed 3'50.00. 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 (30) DAY period you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sate you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (34) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then 7196 9006 9296 64 3911 Page 5of9 r 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 Sherds Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. I 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 tha Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by s contacting the lender. HOW TO CONTACT TIIE LENDER: Name of Lender: CitiMortgage, Inc. Address: P.O. Box 12218 Tucson, AZ 85732 -2218 i 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 Niimber: 1- 866 -940 -8147 Contact Person: MarkAnthony Hartland E -Mail Address: markanthony.b.hartlaad@citi.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the 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 attorneys fees and costs are paid prior to or at the sale and that other requirements of the mortgage are satisfied. YOU JUAYALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBTOR 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 1F NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE, OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Y 7196 9006 9296 6422 Page 6 of 9 i i i 1 CONSUMER CREDIT COUNSELMG AGENCIES SERVING YOUR COUNTY C4N BE L0C,4TED ON THE _ ATTACMED LIST rn accordance with the Fair Debt Collection Practices Act, Title 15, U.S.0 1692(g), you may dispute the validity of this debt, or any portion thereat ifyou 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 12218 Tucson, AZ 85732 -2218 s i I Page 7 of 9 7196 9006 92916 6422 3919 ' i BEM-AP Consumer Credit Counseling Agencies FRANKLIN County Rcport hs1 updated. 031121201311:09 AM 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- 511 -2227 Community Action Commission of Capital Region Housing Alliance of York/Y Housing Resources 1514 Derry Street 290 West Market Street Harrisburg, PA 17104 York, PA 17401 717 - 232 -9757 717 -855 -2752 Maranatha PathStone Corporation 43 Philadelphia Avenue 450 Cleveland Ave Waynesboro, PA 17268 Chambersburg, PA 17201 717 - 762.3285 - 717- 2645913 PA Interfaith Community Programs Inc 40 B High Street Gettysburg, PA 17325 717- 3344518 i i i i 311L j 1 HC Page 8of9 7196 9006 9296 6422 3919 I S HEMAP Consumer Credit Counseling Agencies CUMBEUAND County Report last updated: 03l12IM1311:09 AM Advantage Credit Counseling Service/CCCS of Western PA CommunityAction Commission of Capital Region 2000 Liaglestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 838 -511 -2227 717 -232 -9757 Housing Alliance of York/Y Housing Resources iblaranatba 290 West Nftket 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 i Harrisburg, PA 17102 Cbambersburg, 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 i i i i HC Page9of9 7196 4006 9296 6422 3919 } i i CItlMortgage, Inc —'PRESORT PO Box 9090 First -Class Mail Temecul4 CA 92569 -9090 U.S. Postage and Fees Paid s WSO l 7196 9006 9296 6422 3933 Send Payments to Ciumortgage, Inc. PO Box 689196 Des Moines, IA 50368 -9196 } I I 20130405 -168 . tl. l• llllldin�ll" Iml= �Illullrltl "���IIIIIIF�II�I11 r EMILY A WRIGHTSTONE 205 W MAIN ST Send Correspondence to NEWBURG, PA 17240 -8118 OUNIcrigage, Irm 6400 Las Colinas Blvd. ; Irving, TX 75063 i i i i I i I I i 1 i 1 r 1 I CITIP A 3 j i Date: 04105/2013 Sent Via Certified Mail 7196 9006 9296 6422 3933 EMILY A WRIGHTSTONE 205 W MAN ST NEWBURG, PA 17240 -8118 RE: Property Address: 205 W MAIN ST NEWBURG, PA 17240 i CitNortgage Loan #: 773 j 1 ACT 91 NOTICE TA.I -E .ACTION TO SAVE YOUR BIOME 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 EIYIERGENCYMORTGAGEASSISTANCE PROGRAM (HE") may be able to help save your home. This Notice explains how the program works. To see if HEAIAP can help, you must MEET WITHA CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF TH.E 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) 342-239Z (Persons with impaired hearing can call (717) 780- 1869). This Notice contains important legal information. If you have any questions, CITIPAACT91 Page 2 of 9 7196 9006 9296 6422 3933 r I i I representatives at the Consumer Credit Counseling Agency may be able to help explain j it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU ' DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAIMA.NDO ESTA AGENCEA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRASTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S t EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU 5 CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA- i HOMEOWNER'S NMVIE(S): EMILY A WRIGHTSTONE DAVID L WRIGHTSTONE PROPERTY ADDRESS: 205 W MAIN ST NEWBURG, PA 17240 LOAN ACCT. NO.: W713 ORIGNAL LE N]DEF ABN AiMR0 MORTGAGE GROUP, INC. CURRENT LENDER/SERVICER: CitiMortgage, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU AMY BE ELIGIBLE FOR FINANCIAL ASSISTANCE .WINCH CAN SAYE YOUR HOME FROM .FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PA EVENTS IF YOU COMPLY WITH THE PRO8gSIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (TEM "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. TFJ1fP0RARY 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 AI'EETING PfUST OCCUR tI'ITHIN THIRTY-THREE (33) DAYS OF THE BATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY JNORTGAGE ASSISTANCE, YOU JVVST BRING YOUR JWORTGAGE UP TO DATE. THE . PART OF THIS NOTICE CALLED "HOMY TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. COjVSUASER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit coumseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty C L; 191 7196 9006 9296 6922 3933 Page 3 of 9 1 y t (30) days after the date of this meeting The names, addresses, mil telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of j 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 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 Rrotice. 1 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 I 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. t YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU B'AYE A AJEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF IRIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINEDABOVE, EV TEE SECTION CALLED "TEWORARYSTAYOF FORECLOSURE. " YOU HAKE THE RIGHT TO FILE A HEIIAP 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 TVkM BEFORE A 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 time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You tivill be noted directly by the Pennsylvania Housing Finance Agency of its decision on your application. A? 7196 9006 9296 6422 3933 Page 4 of 9 i t i t NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IV RAN" tIPTCY, THF, FOLLOT•YING PART OF THIS NOTICE IS FOR INFORI'Y1,4TIONPURPOSES ONLYAND SHOULD NOT BE i CONSIDERED AS AN ATTEMPT TO COLLECT THE DEB T. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) i i HOW TO CARE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 205 W MAIN ST � NEWBURG, PA 17240 I t .I5 SERIOUSLYM DEFAULT because: i r YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 02/01 /13 through 04/01/13 " 3 @ $1035.12/month 2 @ $20.80/late chargelmonth I $3146.96 Previous Late Charge(s): $0.00 Delinquency Expense(s): $13.50 Unapplied Funds: ($0.00 TOTAL AMOUNT PAST D UE: $3,1.60.46 HOW TO CURE THE DEFAULT - You may cure the default within TTIIRTY (3 0) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST D UE TO THE LENDER, WHICHIS $3,160.46, PLUS ANYMORTGAGE PAYMENTSAND LATE CHARGES WHICH BEC0_(W DUE 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, Mc. P.O. Box 12218 Tucson, AZ 85732 -2218 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 imereise its rights to accelerate the mortgage dehL This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney's to start legal action to foreclose upon your mortgaged property. IF THE AdORTGAGI"s IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorney's, 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 the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LEADER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -.If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then CITIPAACT91 7196 9006 9296 6422 3933 Page 5of9 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 tender and byperforming any Other requirements under the mortgage. Caring 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 Tt?E LENDER: Name of Lender: CitiMortgage, Inc. i Address: P.O. Box 12218 Tucson, AZ 85732 -2218 Phone Number: 1- 877 - 362 -0175 Monday through Friday 8 AM - 5 PIVI 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- Nlaf[Address: markanthony.b.hartland@citi.com .EFFECT OF SMEVFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OFMORTGAGE - You may not sell or trans fer 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. YOU MAYALSO IL41✓E THE RIGHT: * TO SELL TIME PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBTOR TO 13ORROW MONEY FROM ANOTHER LENDING NSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE TIME 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 tN 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. a CITIPAACT91 Page 6 of 9 7196 9006 9246 6422 3933 i i CONSUMER CREDIT COUNSELING AGENCLUS SCRMG YOUR COUNTY CAN RE LOC4TED ON THE ATTACHED LIST In accordance with the Fair Debt Collection Practices Act, Title 15, U.S.0 1692(g), 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. rf you dispute the validity of this debt, or any portion thercot 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 12218 Tucson, AZ 85732 -2218 CITIPAACT91 7196 9006 9296 6422 3933 Page 7 of 9 i i 3 i - HEMAP Consumer Credit Counseling Agencies t FRANKLIN County Rcpod last apdated:03/12M1311:C9 AM 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 88&511 -2227 Community Action Commission of Capital Region Housing Alliance of York/Y Housing Resources 1514 Derry Street 290 West Market Street Harrisburg, PA 17104 York, PA 17401 717.232 -9757 717- 855 -2752 Maranatha PathStone Corporation 43 Philadelphia Avenue 450 Cleveland Ave Waynesboro, PA 17268 Chambersburg, PA 17201 717 -762 -3285 717- 2645913 PA Interfaith Community Programs Inc 40 E IRgh Street Gettysburg, PA 17325 717 -334 -1518 r Page8of9 7196 9006 9296 6422 3933 j i i HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 03(12/2013 1 149 AM Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region 2000 Lingiestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 888-511 -2227 717 -232 -9757 Housing Alliance of York/Y Housing Resources "Maranatha 290 West Market Street 43 Philadelphia Avenue York, PA 17401 tVaynesboro, 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 High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717 -334 -1518 717 -780 -3940 800 -342 -2397 Page9of9 7196 9006 9296 6422 3993 n n VERIFICATION Brittany Lipscomb, 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. Signature: �3Y�UV� Printed Name: Brittan ipscomb Title: Vice President - Document Control Date: I b- I I- 15 CitiMortgage, Inc. FILE #: 13 -1254 NAME: WRIGHTSTONE, DAVID L. & EMILY A. POWERS KIRN & JAVARDIAN LLC �, { 1 ^ 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 CU,'�;8 RI..AND - C DU N Sean P. Mays, Esquire Id No. 307518 P E a S Y LVA ti'.I A Daniel C. Fanaselle, Esquire Id No. 312292 Richard J. Nalbandian, III, Esquire Id No. 312653 1310 Industrial Boulevard, Suite 202 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 VS. COMPLAINT IN MORTGAGE FORECLOSURE DAVID L. WRIGHTSTONE EMILY A. WRIGHTSTONE 205 WEST MAIN STREET NEWBURG, PA 17240 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. 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. 201661 ❑ Sean P. Mays, Esquire Id. No. 307518 >Daniel 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: 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): 1. monthly amount $ 2. monthly amount $ Borrower Pay Days: Co- Borrower Pay Days MONTHLY EXPENSES (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage $ Food $ 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 n Floor, Suite 202 Southampton, PA 18966 (tel) 215- 942 -2090 (fax) 215- 942 -8661 Attention: Panjola Alikaj Panjola.alikai@pkjllc.com. t (tel) 215- 942 -2090 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1L FO Ur t ii_. .. ,,. Sheriff P '.0 v�# { Climb e..t t� Jody S Smith POV 27 All 9: Chief Deputy Richard W Stewart £° CUMBERLAND COUNT tr Solicitor ,,T:t r: . THE sHERIr= PENNSYLVANIA CITIMORTGAGE Inc S/B/M to ABN AMRO vs. Case Number David Wrightstone (et al.) 2013-6266 SHERIFF'S RETURN OF SERVICE 11/20/2013 12:00 PM - Deputy William Cline, 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 Def-ndant, to wit: David Wrightstone at 205 W. Main Street, Newburg Borough, Newburg, PA 17240. / W AM CLI ' , DEPUTY 11/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Emily Wrightstone, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 205 W. Main Street, Newburg Borough, Newburg, PA 17240. Per co-defendant David Wrightstone, the defendant moved out four years ago and may be residing in Virginia Beach. SHERIFF COST: $66.60 SO ANSWERS, November 21, 2013 RONR ANDERSON, SHERIFF ;�Ccu^tvSui:c 5!;ef.ve c:sc,i #13-1254 POWERS, KIRN&JAVARDIAN, LLC By: Daniel C.Fanaselle C..r Attorney Id#312292 1 1310 Industrial Boulevard, 2nd Floor, Suite 202 //: Southampton, PA 1896 `'1}N t'P M Telephone: 215-942-2090 � �� "i ND colily Attorneys for Plaintiff P�� S YL 4 { �Y A CitiMortgage, Inc Plaintiff COURT OF COMMON PLEAS vs. CIVIL DIVISION David L. Wrightstone and Emily A. Wrightstone n/k/a Emily A Sherman CUMBERLAND COUNTY Defendant(s) No- 13-6266 Civil PRAECIPE TO REINSTATE COMPLAINT TO THE COURT: Kindly Reinstate the Complaint in Mortgage Foreclosure for an Additional thirty(30)days. Daniel C. Fanaselle Attorney Id#312292 POWERS, KIRN&JAVARDIAN, LLC Attorneys for Plaintiff Dated: January 21, 2014 7s C #13-1254 POWERS KIRN & ASSOCIATES, LLC By: Daniel C. Fanaselle Attorney Id # 312292 Eight Neshaminy Interplex, Suite 215 Trevose, PA 19053 Telephone: 215-942-2090 Attorneys for Plaintiff CtiMortgage, Inc. Plaintiff vs. David L. Wrightstone and Emily A. Wrightstone Defendants TO THE COURT: COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 13-6266 Civil PRAECIPE TO REINSTATE COMPLAINT Kindly Reinstate the Complaint in Mortgage Foreclosure for an Additional thirty (30) days. Dated: November , 2014 Daniel C. Fanaselle Attorney Id # 312292 POWERS KIRN & ASSOCIATES, LLC Attorneys for Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY i...Ef)-Clf r iLL THE PROTHONOTAR' 2tItiDEC -1 AM a, 1-45 CUMBERLAND COUNTY PENNSYLVANIA CITIMORTGAGE Inc S/B/M to ABN AMRO vs. David Wrightstone (et al.) Case Number 2013-6266 SHERIFF'S RETURN OF SERVICE 11/20/2014 01:47 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortg.ge Foreclosure by "personally" handing a true copy to a person representing themselves to b- he D -ndant, to wit: David Wrightstone at 205 W. Main Street, Newburg Borough, Newburg, PA 17 WIL IA CLINE, DEPUTY 11/20/2014 01:48 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Emily Wrightstone, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 205 W. Main Street, Newburg Borough, Newburg, PA 17240. Deputies were advised by the defendant's ex-husband that the defendant resides in Virginia Beach. SHERIFF COST: $72.09 SO ANSWERS, November 21, 2014 u tySuite Sheriff. Teleesaft, inc. RON R ANDERSON, SHERIFF #13-1254 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 1NTERPLEX, SUITE 215 TREVOSE, PA 19053 (215) 942-2090 CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMR() MORTGAGE GROUP, INC. CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY COURT OF COMMON PLEAS David L. Wrightstone No. 13-6266 Civil Emily A. Wrightstone Defendant(s) PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above case DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs. Dated: t1 1_ - (/ A IV. Manuel -Coughlin, E . uire Id. No. 63252 ❑ •lanta 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 Attorneys for Plaintiff #13-1254 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 CITIMORTGAGE, INC., SUCCESSOR BY MERGER TO ABN AMRO MORTGAGE GROUP, INC. Plaintiff vs. David L. Wrightstone Emily A. Wrightstone COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 13-6266 Civil Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Praecipe to Discontinue Without Prejudice was sent by first class mail, postage pre -paid, upon the following on the date listed below: David L. Wrightstone 205 West Main Street Newburg, PA 17240-8118 David L. Wrightstone PO Box 221 Newburg, PA 17240-0221 David L. Wrightstone 439 State Street Enola, PA 17025 Dated: V',-21 Emily A. Wrightstone 205 West Main Street Newburg, PA 17240-8118 Emily A. Wrightstone PO Box 221 Newburg, PA 17240-0221 Emily A. Wrightstone 439 State Street Enola, PA 17025 ❑ Jil anuel-Coughlin, Es• ' ire Id. No. 63252 ❑ •lanta 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 Attorneys for Plaintiff