HomeMy WebLinkAbout13-6474 r � ?
Court of Common Pleas For Prothonotary Use Only:
Civil Cover Sheet
Docket No:
Cumberland County - li
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
® Complaint El Writ of Summons ❑ Petition
S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiffs Name: Deutsche Bank National Trust Lead Defendant's Name: Patrick T. Straka; Stephanie
C Company, as Trustee for Long Beach Mortgage Loan M. Straka
T Trust 2006 -6
I Dollar Amount Requested: within arbitration limits
O Are money damages requested ?: F1 Yes ® No (Check one) ® outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No
A Name of Plaintiff/Appellant's Attorney: Christopher A. DeNardo, Esquire
❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant)
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Statutory Appeal: Other
S ❑ Product Liability (does not ❑ Employment Dispute:
include mass tort) Discrimination
B' ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other
F] Zoning Board
C ❑Other:
. El Other:
I Other:
O MASS TORT
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/1/2011
SHAPIRO & DeNARDO, LLC f ,
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. =NO: *784t,7
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 T,-
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 ";?r _ r
AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 C• {{ , t .,,
3600 HORIZON DRIVE SUITE 150 V j
KING OF PRUSSIA, PA 19406 ` vSYj �� 'q Y
TELEPHONE: (610)278 -6800
S & D FILE NO. 13- 044173
Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS
Trustee for Long Beach Mortgage Loan Trust CIVIL DIVISION
2006 -6 CUMBERLAND COUNTY
PLAINTIFF
NO:
VS.
Patrick T. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
Stephanie M. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
DEFENDANTS ;
COMPLAINT - CIVIL ACTION
MORTGAGE FORECLOSURE
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 DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU
ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE
COMPLAINT OR FOR ANY OTHER 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 OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
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.
3 . 7 s�� ar
UA ya ql9
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717- 249 -3166
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE (20) DIAS DE PLAZO,AL PARTIR DE LA FECHA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA
ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU
PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA
MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O
NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA
PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O
OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717 -249 -3166
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278 -6800
S & D FILE NO. 13- 044173
Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS
Trustee for Long Beach Mortgage Loan Trust ; CIVIL DIVISION
2006 -6 CUMBERLAND COUNTY
PLAINTIFF
NO:
VS. ;
Patrick T. Straka
107 West Butler Street ;
Mount Holly Springs, PA 17065
Stephanie M. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
DEFENDANTS
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, Deutsche Bank National Trust Company, as Trustee for Long Beach Mortgage
Loan Trust 2006 -6, the address of which is, c/o JPMorgan Chase Bank, N.A., 7255 Baymeadows
Way, Jacksonville, Florida 32256, brings this action of mortgage foreclosure upon the following
cause of action:
1. (a) Parties to Mortgage
Mortgagee Long Beach Mortgage Company
Mortga og lW : Patrick T. Straka and Stephanie M. Straka
(b) Date of Mortgage May 31, 2006
(c) Place and Date of Record of Mortgage
Recorder of Deeds
Cumberland County Mortgage Book 1953, Page 199
Date: June 2, 2006
The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached
hereto and marked as Exhibit "A" and incorporated herein by reference.
(d) Assignments
Assignor: Long Beach Mortgage Co.
Assignee: Deutsche Bank National Trust Company, as Trustee for Long Beach
Mortgage Loan Trust 2006 -6
Date of Assignment: March 3, 2008
Recording Date: April 9, 2008
Instrument No.: 200811112
2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal
successor in interest to the original Mortgagee, or is the present holder of the mortgage by
operation of law.
3. The real property which is subject to the Mortgage is generally known as 107 West
Butler Street, Mount Holly Springs, PA 17065 and is more specifically described as
attached as part of Exhibit "A ".
4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by
the Mortgage (the "Note "). A true and correct copy of the Note is attached and marked as
Exhibit "B ".
5. The names and mailing addresses of the Defendants are: Patrick T. Straka, 107 West
Butler Street, Mount Holly Springs, PA 17065 and Stephanie M. Straka, 107 West Butler
Street, Mount Holly Springs, PA 17065.
6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both.
7. The Mortgage is in default because the monthly installments of principal and interest and
other charges stated below, all as authorized by the Mortgage, are due as of December 1,
2012 and have not been paid, and upon failure to make such payments when due, the
whole of the principal, together with charges specifically itemized below are immediately
due and payable.
8. The following amounts are due as of October 2, 2013:
Principal Balance Due $118,899.19
Interest Currently Due and Owing at a variable rate $5,449.51
From November 1, 2012 through September 30, 2013
Escrow Advances $1,572.41
Appraisal Fees $395.00
Property Inspection $28.00
Property Preservation $165.50
Suspense/Unapplied Balance ($521.85)
TOTAL $125,987.76
9. Interest accrues currently on a daily basis and is subject to further adjustment as set forth
in the underlying Mortgage and Note, and Plaintiff may incur other expenses, costs and
charges collectible under the Note and Mortgage.
10. In addition to the above amounts, reasonably incurred attorneys fees and costs as well as
proof of title in conformity with the mortgage documents and Pennsylvania law, shall be.
sought by Plaintiff and included in any request for judgment.
11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S.
§ 1680.402c, et sec ., was sent to each individual Mortgagor at their mailing address and/or
the mortgaged property address by first -class mail and certified mail. Copies of the material
part of the Notice are attached hereto as Exhibit "C" in accordance with Pa.R.C.P. 1019(i).
12. Pursuant Pa.R.C.P. 1019(d), the Notice sent to the Defendant(s) contains the information
required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. § 403 et seq., and separate
Notice of Intention to Foreclose is not required.
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in
favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in
paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and
charges collectible under the Note and Mortgage and for the foreclosure and sale of the
mortgaged premises.
SHAPIRO & DeNARDO, LLC
Date: _
BY:
Attorneys for Plaintiff
S & D File No. 13- 044173
jda
Who rncorded;m&Uto. AO DERT F. ZIEGLE:R.
LONG BEACH MORTGAGB COMPANY s "; "'''" „ � ,
2210 ENTERPRIS}s DR., WS: SCOD140
MORENC$, SC 29501
2006 JUN 2 RIB $ i9
I.= No
Patoel Nuaftr; �
pone ALore 7t�tl U�eBmr ti Dao�
MORTGAGE
THIS MORTIGA013 ('Sea nky lastctnmant') is given oa May 31 , 2006 no mnrtsapr b
PATRICK T Sf MWA and MPHANIE M STRAKA, HUSBAND AND WIFE AS JOINT TIONANTS
( "Bornnwer "). MiU 5iwjdW Instrument b given to
LONG REACH MOR.TGAUrs COMPANY
whia is ogmdzed and Wdstnag under the lawe Mike State of.dawate . and Whose
edam is 140D S, DOUM ASS RD., SUITE 100, ANAnUMM t CA 92806
C1ne llgndred Nine Mislussad Five Hu>idtpd ( ")• Bonower owes laa t am prindpel am oY
Twenty and zo /i .�•.�»
DORM (U.S. 5 109,520.00 ).
This dst is evidenced by Borrower's n tilted the saw data as this Seauity instttmeeot wbkh provides for
tnnWWy prflm K with ft It ilubt, If not paid earlier, .due and payslo on Jtmt: ] , 226
'Ibis Secmdty luxi t amt maim to Leaodet:'(s) the rrpaymM of the debt evhlmleed by the Note, wltp hr =$[, and all renewals,
m mmdans and nodif'tcalions of tics Note; (b) the payment of ae other sans, with fit. advattoW zklar pkv&aph 7 to
protect the se mtw of tble Smutty Ia uume<lt, and (a) the pat&am = of )latxbWes's overeats aW agremmm tinder No
Seemity lus ml zur and the Nate. For this pntpm, Borrower does bmby reengage, sm aad a mrney to laidw tho following
descibod pmp" heated In CUMBBEtUM town, Pamivania:
LEGAL DESCRWIION ATTACHED RMWO AND MADE A PART HEMP
WhWh tns the address of 107 W BUTLER STBEl3X' MT.HOLLY SPRINGS Oman
Paw*lva * 17065 r4p coal Chapany Addrms ").
POWYLVAN &S �� I nng� 1e � f�ty -WlW A1FHWC;
U WAMUN OWT �1
VMP MOFrtUAa� FORM$.1a0�J0717+Ri11
B( 1 9 5 3 1 G O 199
'FOrAt Ia+�7 NC W �
I
'f(O Tfi M WrrH id the IvTroY&ft au now or bm=fcer esowW an the pmpedy, ad aU mftm lt8, Mmunmm, and
ftlurass now or bereedter a part m4 prapnrty. All IVUaV=b =4 ad ttops ahe11 Also be c*vemd by this 5ecarity
k ttvmomr. All of the fotagtb is t>nbm d to h¢ this Semrity TaBttem M as the ''
BCMRC'WM COVENANTS tat h Boa war IA latvtidly a" of rho estate y conveyed aad bias the tight to ImmPge,
great and rumvey th I'mpeny and that the Pmpmy b vaatmeeted, ercepr for eaaamb[tmm of m nL Botmwer watrams
gad will drtietldqs 11J' the title to dte Proporty t ail claltas and dataottds, ttabJext � say autmnbxaocaa of record. _ _
T d+CURTIY LNSTRUMSN'[' emtaobhus ttnlfoaa noveutass for rmticad use and nsns mHom aww" with limlteel
V Ywl ptopetfy.
UNIFORM CC}VSNANTS. Beumwar and Ltmder emrtsoamt rmd aPme as ibnom
L Atymasat vt land 1p�meaat tsgd ><.Rte fvhar r. Bunowet shall prompdy pay when dae the
ptimnbpal a@ read it>tearst em debt eviet6atard by tlem to and prapaymmtt toad ltuo tdttuSgea due wader the Nola
� � 1Fbgd9 foN Truce tmd Tnn„�„n,. g pt 1p1�t1C 18w Cr to
al WtIttC11 Wdva by Lander, Hor10v41C! SW ply to
Lxitdar oa the day monody payutmrat aa duo tmdeir t e Mote, ua8l the Note is paid In foU, a sum C'Fa kl) foi; (a) yyea Y tmMs
and oat which ts1A;y AURA P ' over thts Stably htru a as a lien an tht; Property; (b) yearly k�smhald paytneam
or ground rmft cd Ampetty, If my, o) yearly lkmW or pr*#et{lr 3a mg= pankaur, (d) yen* flood insuram per,
if a w; (e) 7'amiy Le WMMMI premmma, If my, and (f) my mm psyabte by Llommm to Lmtddr, is aeaordstiee with
the provlsious of pmragraph 8, In Iteu of the paymmx of mioqage ltiguta pr taiwas. These fUMS ate eadled wRsmow Items."
Lewder :ally. at amy time, aspect and hold Funds in tm am= tuft to Wmaed die mtattino m amount it huder for a fedardly
IVI&md aaortgago loan may requtma for 8grr+owaes taamw mount under the tbdmW heal Eabb Sattl=mt Proce4tkt" Act of
1974 as at mdc4 from *m to lima, 12 U.S.C. Se ubu %D1 et seg. ('RE P'A"), , unless another law that apldies to the Funds
sets a lAaser aunt. If so, Lust mqy, at 4w flue, MUM And hold Fusels in to amount not to a meed'the Tosser arua=,
L der may 690mAte the amount of Ands due on flu basis of camas data itmd reasonable aWmuft of cgmndwm of fotam
Emw RMA or gftrwba in 4wndmme whh applitmblc law.
Th Feuds SbBU the bold ter as lastiaulem vs+bm dgosh are hrsurvd by a fedirai.tsgetnry, may, or M*y
(inclu4ing Laaderr, if Lauder is such tin rd pan or in ktchmi liana LOWBtmk.
L
anyr emtGar &W the Fttttdtt to tba
m
Em w IMM. Letader m7 rut charge Homowar for bn1dtag land Wplyhtg the pvWg. Ono Ay tW*zb* � ea=W , or
v A" E ew Itmns. unle r..��r= >?� tom- ea fly Foo is t ^r,,•,► t. I r.+M►� to �m sub
a ohazgn, Iletv Ix4dar MY Be> Own to a .timee t ec
W&Vaod xq}todbi g service
usod by' header in eoommecttioa with A& las vala�sa V alf4 pHcable hN othovtse, Umim an apectmat is made or
Applicable law requtrm inctrim to be paid, Ir endee shall soot be zc0W to psy Borrower any imorast or cmmhop as fate rumb,
Borrower stet Lam may etgax In Wtitiag. bowma, Ibtu ins slat! be paid on rho Foods. Deadest d ali Sm to Botrowar,
widwtu chk99, ltd screws! Womflas of the Funds, showinsg aredlta mast debit To the Pm& and tfsa purpose for whkh nab
Nebit to U mmms was amdo. 'the Funds are Pledged as addldadd for mm mcumd by this SfttdW ]asuma=,
tm
If the Panda held by Lder emceed tin atrtooata pert�d to� a by sppUcable law. L.cWw ana tmcA t to Bomowet
for do .weam Pu ds in ammdmm whh tbo is of appTtcabla law. If the amaant of dm Funds hard by L tcder at eqy
bate is not man cat to pay the Narrow 2e= W tap* Bon ower is Wripttg, and, insuch case Borrower
shaft pay to TAW the amotmt try to m im vp the "eieAey, ltartowar slant& maim up the dollolvW i4 uo nitre than
twelve monmy pgjrneR414 at T Jew 'a We discretba,
Upoo pa xam in W of qU 1, r am secaned try this Sez=urity h mcrtteat, I.e der :shall psmng 4 rafmtd to Borrower eery
Funds hold by I.mh t. 114 mdaparWqh2j, lowder gun mquhe qr an the. Property, Lauder. prior me* cagdaWon or sale
Of d PropattY, foul! apply any klhtda bald. by L.aotler at the flue of +esxlOddan or m a medit sgfi* the mm aearred by
ty ='L Of ftYumb. Unless igtyits,Ablo late providers othtcwise, all Payll mm te*vcd by Leader wader paragraphs
1 and 2
tihell be 8net, to any I PnPa1omm c4aqp dtta cadet the Note; sexrond. to aavamna ptgrable under paragraph 2;
third, to iaraest due; fumth, to pdnelpal duq and last. to mW tats a men due ttadar the Nowt.
4. Chm2ea; >E km Dwmwm shall PWOU fazes, asseassmatte, dl>argest, flam and Wpcdtdm attributable to Qte Pro
adflmh Wally attain priotdV over this Stxurity Iaatr=cM and ieaaeheld pgymmds or grovad ants, if amy. Banowcr a
dIAM abUguiona in the maYrtrer provided in pataZMb 2, or If not pall fa that mum, Borrower" V the m am liana dhadyy
to ft PC= owed paymrut. eo tdsall pms Vgy furaftb m La ft all nod= of aeanwe 1 to be paid uodw tf& pargr•ga.
If Horower avdoas theft Paymcau &Mdy, Amaimi oltafl pmmptly tiuniah to Ltasrler =Wpts evidettcidg the payments:
.
44-OMPAI (Bete na.zat �at"
lc>m� 953PG0200 Loan
t
Borrower shall promptly d6darge my Brea which bas Pdotfty over this SOM11W Jrtigaueturot ttdw Bozo (a) Bvw im
wridng to the payment of fhb oblipdoo troCt ad by the Bari ua a =caeracc table m Lender; (b) contests in good fedtb the ilea
by, or ddfettda against a aroec mul Of the liet ill, ptoce dMP in tho LrndarIs opbtdvn aparatd to p "wit the
elder came nt of dw lien or (a) sccv w from the !older of the liw no agm unt saddWMry W L.aWW strbordlaedng the lira to
tltie; SeeM1trity Jnsaromemt. T# I�ttder detettttbras that asd part etP rite 1.'c+apary ie sub,�aat w a iirm whficb may auato prlatfty aver . .
dtie Security Iastrtnneat, Loader tssey give Bbrmwor a ttoneo Hkt it yW me ht u. R= shaft sari* the liem or take one or
more of the acne a act forth above whbiu 10 days of the giving of aotiae.
3. ItU=rd or Pitopwiy lumffertce. Borrower dW1 kwp the hpovaate = now WdStiAR of trU afW w0Cted On the
Fropetty f=anged against logs by Ate, batrds included whbin rile tare= 'eoumded teove WO 4"d MY ORM h mrdg, inclttdle
floods or goad=s, for WWeth larder tux tares iaaurma. This iasmr ww shalt be usuhmdnW hn tie amomm and Sir the periods
that Lender ve*dres. 'lists 4wi anit>d Lamar providW ft martyr m eball be drown by Buravver =Wed to Leader approval
which," not be "V*8 wtably Wimbeld. in }ietMwet %is to mdr aia coverage tffis=WW abava, LtMW air, at Leader's
apdou, obWu oovw4b to prutwi l.eduleer'a rigW In W ft7jay la awvnl"* witty peregrnph 7.
All Imumme paUdc s sad =newels sW be table to Louder and dal] itlCUgde it at Mard mortgage abnrae, Lender
stall have the right to hold the poll m and %wwwab, If I.ondor ftwires, Borrowee slml] pzdmp►lY give m leader ail receipts of
paid prtnniemss and reneWal 0044. In this sytroat of lnsa, Barra= Shall glut prompt notice to the tuarwee cuTier rmd L mda.
Lender My MU proof of loss iP not rnpdc I ra I It y by Borrower.
Ur4eAs Lmdec rind Barinvrex a thrtwius a tea is writing, intnrnnoo proceeds almll ba implied to or ,�pglr of the
Property damaged, if the renaffidott or repair is wouOrOjeagy &table mad Yin's umnity is act leswd. If the reatun don or
repair is not eaoaomlc&W ftele or Leader's security wmad be lessened. the isu=m= procee& abwll be rtppmA to tbt gums
s=lued by tM Seawky bmtrt meat, vVt:L6w or net ism duet, with wW exaew paid to If Baraftf abaadona tiro
r
Property, or doea not unuv vAdda 30 days a merle Amax L oWe a tact the curlar eyed to ultra a cWm, that
Lender inapt CoUog the leans= proceeds. Lender may use tiro pr =ds w trtmir or t�saoty rim Ptopert9 ar tQ 1 Y ctttAa
soa=red by lute amity kWZQ M, vac or not tier dtt 7bb 90-d8y pedal y� >bagin n the nt�aa is gluon.
VJaWs Linder and Bonower od wlw Was to writing, gay 001intion of ptacach W pt�cipal dMU ttat, et UW Or
postpond the dua date of the tuorbly paynwts nArred to In paaagmpbs 1 and 2 - or CbWV the attxumt of ft payMWA If
A = p2b 21 the ftop=7 sc =quh-4 by Lam. Ecr.".rn's 1. #4 to W I === x 'ws iad pr 'row g ft--
pric acgtr Me aequWtlan stall pans to Lender to the extent of rite MW aex 4*d by this Swa ty lit
tely d, Oaci` paug Pbaex�vattlon MW ntenenee ace=d Protection of the Fvoperq; Aunw*Wle ]Wan Applicattmt;
locasedi ds. Bonowez shall atxnpy, establish. ad UM titer Ztxopettl+ as 8oaowet's priticipal xuddence wtddn sbtty days after tbt
etiQyctetioa of No Swaft and Shell c MdM to occupy du property as Bpapwet pencipal ratldoaoo for at least one
year altar th imam of axapaaay, antetss I:eatrlt>r otborvvise7 agiaas ha writing, wiriob oonrxmt sbnll not ba fl wed v1d,
air U0140 ec dttntm+taeCes crest wDdeh ttra btyc>amd ]totrovNer'a central. fiatlgwcr stall not destroy, damage or hnpair
the pmportytiro Property so deteriorate, ac commit vvasta ea the I'toporty. Bcurovver shall be in doffeplt if troy fldrfbltaw
acxton or p. v�inamer dv$ ar otslal. is beSva that {aa teau0er's good Adth juBgment could result to forfeiture of the
Property or o aostmrial�► izngtir the lttn crested by ttds Secertty 7a�rualt or Leader's smuity inmost. Borrower may
Outs welt a ad reiaAtste, e9 provided iz paragraph 28, by eatcsing dna cotton or ptoaerodI to be dambW with a roltng
tbnt, 1a Leaol faith dtoolttati. pree odes forielture of the Saaow�'s interest "in rho PrDpdsty or othat siAl
siancat ea created by this Samndty l iastcttmr m or Lender's semflty hmarm gonuwar -situ!! also be is ddu* if
Bonmvvei, daft tbo loan appUcadoa ptctaosa, Sava mate➢ Wy false or h9browdou of atsreatteata to .I *ad ar (or faded
to provide: Leader widr any ittAtCr W iv%vwW tt, It couftodou with the IagA 44dnrlCOd by the Not% belading, btu not Bunted
to. reptesaniations aonwrrdng Borrower's occupancy of the pmpaty m a prlaclpd tealdesce. N this Scoadtj kutnament h an
leasehold, lbarrower shall comply with all the pmvhdohs of the low- If Borrower aogvk= feo dtlo to the Property, tie
ieasebold'tmd *a fete title dAU OX Merge U=ltra l.0ft a�cas to ate =Seer in wrltlrrg.
7. Protecdan of Lentdees in the Praptxty. ]FBatrowtu fills to parf'onm uta eaves aud ftm=MM amadmd in
tb39 Se arn'ty Inst rumea, or aura is it legal proceed that mmy algalfkandy agpot I.cadies's rights to (such as A
pmmlitig in bantaoptay, protbauo, fegc mWemetlbn or foifeWm of to corona IM at iWilatiow). rhea Leander MY da turd
ply for *bum Is Mceswy to pe t the W1W of the Props* nod 4p4dec'a nights in tray hopsrty. Landers acdow may
bwJuft ptsybag any sums aec urod by a lien which bah pdarhy aver this Swarky Irruottnteot, nppw in court, PrAdp,
tsaw=Ma -aftornaya' fees and etuertng an the Y?mpetty to wake iepa b. Althot>gh Laura =say talm cued ud9et this Pte,
7. Lauder don nor have to do sex
I ' �6HIPA Y n t'q� Zf 017 !�lt�90
to 9 5 3 PG 0 Z V 1 xonn IVs
Any amotmts 4bbursed by Leodae under this pategttrph 7 shall bcomc additiOpal debt of Borrower Mu red by dfis
S=RiW kftV9ftt UAW Bommer and Lamer Mae to other tams of pant, those ammum sball bear into ct foam the
data of M*4=M at flue Note rate and *A be paydble, with lam. upon. a4 ae from I to Bmower nque dng
v ?4*rt
hewer tn= N the Und m� mortgage i�ae as a amAldon of aWbg the lam seau rd by ttds Scmrhy
Iastr o iaaurance pay pmt dump rtsgndmd to nuintaiu Om morpge kmaaaca in eff If, for may mm n, tho
non
Mort, aa Mverap �� by eA CUM to be In otters, Botww=r shell per the prmnhtoas r4ttlred to
verage su bautard 4 cgWvabsat to the n*tWp kutrance pre*aaly in vffwt. at a cost mftmud lay egaiva ew to Ste
treat to'sorrawer of the aaso nno inamance ptreviousiy► in effect, fea=t an =homers mortgage imor Approved by Lender. if
eubataptially equiva}eAt mortgage irtmrtarbG+p coverage la nor avtdtab�. 6att+avref salsa pojyr tb Lu3sdmr rmrh mnrrth a tram etptai to
ano -twelfth of the yet* lgp fte hwumcce prey bong pidd by Buirvw wbpr ft bmmme oavorago lapsed or and to
be in affect. Leader 'wall accept, use 40 term= th=en it l ose reserve In lira • of mortgage iASlut�ps, I� reWVC
fr
payments m g longer be ic4u rcd, at the gWcft a rbr, owmage (in ft amount and for fain pries
that I -A- segairsi+s) provided by as iaanra>' Approval by Leader $a& beoontee avdMu and is obtained. gorx+ott+er nosh pay
the PrmzftW required to muhUm r meatgage in u mme in dt at„ or W provide a toss ,reserve, umM the uqubcmaxt for maatgage
hHurmac cads in. wUh any wrlttm mpta a�t between Harnnwet mad Linder or applitnble law.
9. gnspecNoz . ipr its met ropey u5b rwonablo amiss upon and inspection of the Pmperry. I abet! give
Bomnrar notice at the time of or prior to an hopeudan specliyiog teronable muss for Sus i lan.
1% Coadeumdou. The proeeeda of any award or clabn for dmiges„ dlreot or coasegrtamiat, in, cmndeaton with wW
oundemnation or othvt tag of miry part of the Property, or for coaveyagce to Nett of condemnation, am bmtby ass*a And
gall bo'pdd to Lender,
In the avesu of a tonal taking of the Property, the proceeds abed be applied to do smu Mhtd by this Semrdry lasCntamt,
wlmsbet'. or not - &m duo, whh any pl fm ptdd to Bow wet. In the evant of a pattlet taking of tba PMp" in W" the Wr
market ;value of the ply hmwxliately before ft tearing is cVK o0 or r than the mwmt of a minas secprod by this
Sca=nty hw nun='kmb=duWy Ware the taklug, unless born wee mad Leader ad eraise ogees is u4 amg. the amps timttr A by
ft SWW* Instrument shall W rednoed by the am%# of tha pn000eft multiplied by the fol mb* f ectlomi' (a) fate total
amotrdt. e>t= �o ate t�!� ; hafine'the tam =i='ld�i t,9 tr; t'�: fear a ' � � t3ss �
botbre the takng. MY b ftm WM bz Void to Renewer. Ih the cvcM of a pttrtiml ttiklag of the Pcoptmy in W& the fair
>aAcet yalue of the Prnpaty fwAW a* babre the ta]cing io less than the amount of duo am wowed urmnodludy befotm do
taking.. Wes Sorromwer aid Loader otbkWm agree In writing or unless s"Rgable law adtarwise provides, the ptocceds sW
be qVIIcd to the sums around, by'%W Swmdty In9ftw %tether ar aot the sea=s are Ova due,.
fin Property In 9baa4oaed by Bonvwt:r, or if, attar Matte by LoWer to Borrower plat Me eondtamror offers to m 1m an
award dr senile a edalm for datta>iges. Borrower fails to x I a d to Lander whWo s O days 4(* Om dab the notice b gtvan.
LeAder.ic — 34cAad to cauu t sod PWy the pxeooa bh at itu 9pftc4 eiom W s.asto"AGO or ropalr of 66 P"*"ty or to tam Mm"
tt Wred by this Sacariry fit whedw or trot Ou duo.
Unless UzWer and Bmxow r othorwise agree in w4 ft, taty appHoulon of proceeds W P aball not exh4d or
posipoeP the doe date of rho monthly paypasmts ref? nW to In U.1 S&4 x or idimp the ematmt of such pgycoouts.
11. iBars WW Not 1t;Nta Wl F Ddmgrmm By Lander ��akv+er. Usttenalon of the th=e for p*paerrt at wDMtmdan
of sMoniizifto of ties suns =earned by thte Smadsy shmum puned by Leader to tray► aowmr in interest of Boanwe r Stall
not Mum to release the liability of the orl&4 Borrower or Bomwmtt" A r3gComms In ferment. Larder Intel not be impI ed to
cow ptoceec8trgs against way kwwssar In interest or of m to errand dm for payu►eut or oawwiso wailIfy neon
Of the ssrms ads vW by tots Security ftn moeat by mason of any dt ntaud made by dx migival Borrower or Botrours
avecMOM in Intausttt. Any fwboarmw by Lander th etteedsipg any right or remedy shall not' be it waiver of or pre** dtt
oxaralm'of spy 4& or remedy.
14 Sttasmsora " Asaigsa low* 34M dad Sevot+al LmWtsy-, Cwolmrs► The cevemaam and ap umemta of d&
Sect dWA shall bIvA and baefit the atzCCessors od eadStr of Ltstsder end bomwet, Subject to the provbkm of
paregmplt 17, liozrowar's cavtmants, and agrMneWs quail by Ieiut and several. Any 9oaowar who "ps this Semuity
IMMORM but daps Mt awcute the Nora: (a) is ooh this &saudty Inatxita d only to asortgtrgo. great w coAM do
8onrovpgr•8 iater0st 14 ate Ptvperty tender the ttw 0 Of this Security I*4mpm (b) Is smt ptmtonany ebtiigued m easy the same
seafood by delis St Tasuumtnu and (c) agrees tbat Lender and atq other Bomnwar mtty 4g= to wAaad, modlt)r, fotbau or
make any accommMahans with tegerd to the tea7ea of this Stow # Inatttu m or do Nate wfthout that BozzattWx saaawn,
tl�.p�PA
POW "
PAD. Hof 7 t
MPM, UK 19 5 3 PG 0.2 0 � I.omt °
23. Loma Chalm. Nsba loan s=m d by this Sectuitp Ipare molt Is wMeet tD a law Stith seta mmdm= ba
and that law is liaadly ea that they interet err. other lom dhorget collected or to be wRocted in connection *bh tit
loan exceed the permitted Uvol tb mL (a) any auat loam 6up 9M be redowd by the amoteat namosmV to A dme the charge
to the permitterd llt is and (b) m W sums already 00mood from Barmwer which m corded pcm itW Unnta will be refanded to
Not,awer. Lapdar may chdase 'ter melee eras reftmd by ,edociag dto pdoolpsl *wW vatler the Nat* or by making m direct
pr m at;ta Banuwar. If a roimd codum principal, the rtdoctioa will be tmamd as a pmtial Prepsymau witleut any
prepayenpat charge tower the Note.
14.' Netlex�. nay riottco w Bartaaer provided ibz in tfria qty iestrua t dmO be given by delivering It or by mailing
it bs class meal tmleama avpGL`al�lc law zr>duit%s use elf onorh+u method. The wilco shall be directed to tht Pmperty Add=
or nay t>t r atidtepe BorroWee desigrttmes by notit m L.enderr. ! ranee to .Lmu' SWU fro SWm by Arit dmm n,dt w
L eader'e adtiraas sTAted hetelnt or may atlser adducers Lender de>sigtuRes by nado to Boamwet. Any notice provided for in 1Lis
9cewciryry Insutrertem elrall ba eicemed m have boon given ro BorroWet or 1 1 w>ta glvaa•as pmDvldod in ffis p�t�gt�pdt.
tS•' Law; S+t!vdwbllity. 'llrisi Soauclrs► Int tnroent shall be governed by fodatat law cad TO IaWL of the
�t>usdicon is the Ptttpetty is Iaeated. tlrt: esvtant tbai cup InooVision or ttltuaee Of this Seoerrity 1t pie the New
tsarrfdiCOi with trpplicable Iaw, turobt t`onlllet shall not at ct attar provitiara this Secuucity Iastn>toertt or I& Note wbieh can be
given e;tteCt whlrom the e,onhicting provision. �'a this ettd the pxOVrsiaas of brie Swunity Inctrvmecd and tsar Note am declared
ld be 9everabla.
16. Narrommes Copy. Bormwer Ball be given one confommd awpd' of the Note and of this Security bstninzai.
11. T raadt r or the Property or it BeoeQelml. Ynwmd in Borrower. if all or mV peril of the FtoperW or my knorest in it
Is. sold ear hand coed. (or it a bedxb8del s>net W its Dump err rS sold or trooftrved and Borrower is not B-Dahnai persaa) whim
Lraader'a prior wdskn couma. Leader may, at Im opti* toquide immedlo ptEyVAM in full of all muns mmuml by this
Security lase meat. Howwa, this option tba11 trot be eneewcieod by Deader ff erawrim is prolribitad by f4slvtal law to of the doo .
Of OAS Secodty hmftmenL
IIf Y. order amuism this edition, Leader Shall give lsoaoawer notice of ameletat m, MIA natioe dO Asavida a puled of not
less thud 90 days from the date the notice is delivered or mailed wkbk which eaoxawer must pay all P=s secured by this
Seamity tastrmmnat. if Bomwer Mils to pay these sums prior to dte aspiration of tide period, I=dar toam,y invoke a[tfr remedies
neanitted by t6Ta ;3ecxu#ty Iasav�rt Without itrtthcr tior3ee or eieneaoid em Saezower. • .
IL • somwees mot to I dosterte, if Boaawer meaeta cettdo candhioos. d9anrower shalt have the right: m have
etnwrommot of this Seenrlty (n9rre n=t msoomtha% at WW tmo to tits earlier oft (A) 5 days'(or mach ether period as
ay
Volieable caw m veoVy liar rebutummeat) befam vela of them le to my power of a coumbed in this
Security IWAn eek or (b) entry of a � this Stawrr'ty b ear.'lUM Conditions nee that Borrower. (a) pot
Landet an mtmrs wblcll then would be dma m dm'*b Security ImUument and fie Note as If no aemletstioa had otaomexii (b)
tuns arty doodt of ZW atlm eoteaantsor eareemer s; (a) pop all expenses locurrad is enf*mhig tlitm Security Tint.
W root , ot lim m i
ited
, rmsommin morneye' feea: Wd (d) tares much acdan ere Lender mqt► reasonably require to asp
that the lion of this SoeariW bsft nm4 Learner's riots In the ProperW sod Borrower's obligation so pry the ramps swu vd by
tbim Security ko mum = shall ogr6aua unchanged. U rmtnapatemeat by Bomwor. this Sean* IrAbdYmm curt the
obligatiooa secured hereby d Wf remaI Noy e8'e edve as if r at el taft bad. oecareed. Howow. this right m reinstMe +t 11
dot apply In due once of acceleration under paragraph 17.
19." $rile of Noted Cb mw of Loan doer. The Nom- or a parlkl 'intc= in tha Now (together V tlu rids Samu ry
Taetmmnc+n* mry toe cold ana or war& tiam wltreem prlar, latter To Rnmr won A meta my n mlt in a ehaat{eIn the e9 ft fttva
as the "Loan %Nicer') that eaiitatxs tnoatbdy payments dun unft the Nate and this Seeaoaity InaYumant. T7mm also =V be one
or mram 4mges of the Load Serviaermelated tp a sale of the Nate. If time is a chop of the Loam Service,, Burrower vdh be
Om w ttm notice of the dMuse in eamdac* With paragraph 14 dbove no appl calla law. The nodae will state Om aamts and
addM of the u*W Lana SerAw and the address to vvWch payrmeats d ouX be mWr. 7ha nadcm will mien contain, any other
iaforawom required try appilcable law.
20. Haaetrdaus Sub4ta m. Baxterwar shall twat amm or permit the presence, rote, sdapoW, etomp, of release of ray
Ha Rdaps Substom an or In the m Itoperty Borrenvear Abell not do, nor chow anyone tabs, to do. areythbog kftg the
Property, that is is violation of any rnvlrCmm ow Law. Tin preatshog two wateoccs shall not apply to the pra mc, ttse. or
storage QU the P=P!* of =ll quaurities of bona &Awa=y that are gtmerelly recognized to be app qmU to m moral
rt sidemiel uses and to noabftmarice of tEte Propotty.
�. � 19 5 3'P&•0'2 0 3 I.mn No
BO=" etball promptly glue Linder written mofte of any i*Mftatlon, claim. dttamA lawsuit or other action by any
SOMUOMW or M3uk1O1Y WM or lie PWW invoITIng the and any Hawrdoas SAbscance or HaviroummW Yaw
of wbic h Borrower has actual Imawledga. If Ranower Icams err: is w6fied by aay pymmsead or roplatoiy 8whority, th"
nay removal or otter rem% of OPY ElMnlmra AJIMUM t!m
all necowary remedial actions In aaaordance with Eavbumneo ah g � 1S net;tttt�ty, Baaovt+er shaIl promptly talcs
- - !a MU paragraph 20, n1ftwadoua 8ctbm-ac 9 amt d woo out.ol woo dWInW tee facto or Bo wWooa a61PW44ft bW
Ebvir men tal Law and tiro follow subotanw; gaAOtina, imruscoe, Other ilrrrmable or tatric palsolmw produM, rosin
Pftttddn and babieides, valvAa salves, materdola relate{. Ain$ abeam or fdr7r wAayde, raft nflitl wtjn ma mjg% A8 %*pd in
thts pa waraph 20. `11Whaaaaentel Law' means fsdand laws acid iawa of dw ye &Mcdou where tiro 1?ropeurty Is leased that
relater to health, Way or envl aor=tal pA*gion.
NdMINMRM COVBtOWn. Borrower sad Leader f ee a avenaat and agree as follows:
21.; A0019fitiau Hem. Lrndrr ehdl glee notice to IltartWV prior to accelazdan follow[W Bm nwees breach
of mil' eotreetant or agilt omul In this Seem* IastrunwK (brat not prior to aocelerallcm t► Aw paragraph 17 anlcas
applicable Mw provides othawdse). Lutdw bhbll soft Bet "ww al ammelg other trdpgn (it) the de&Wt; '(b) trie waun
Mgtrdved to GM the ddMft (d Adler dw dda h meet be am* and (dp *At figure to cure the ddkuht w apse GM may
twit in Mdteratloa of go sums seed by M Sft ty Wtra4aeed, faredosnre by JneB W p marw ft and ate of the
P►+t wwq. Lender &an dtatttbw dtt 6to Boe•rtrwo at them rlaht to rttbrslate after atroelarttttan acrd the rWd tbo assert M the
farad na n proeeetbrrg the non- eatateaoo of n 4d wit or any ottaar Mwn of Nownmar to uoaterhttin awd floeeclosum It
the debut Is not oared w spaced, Under, at its apdoo, toq regatrc iovmeddah pWalent in 60 of dl same recurred by
this SUM11y Itnttttamtent without ftatt w dcmznd and may foreclose this Stcpe instrument by jO&W proaeeeytnS.
L"W -8ltttll be entitled to caved an etgwnsw inamtred in ptmeasittg rile tan pcovitded k .td b FUNU apb 21,
lnrlr ,but not limited ta, nttdkgal s' fees 2nd testy ai *k evl0mae to the cdcut permitted by appltasUle taw.
?Z.., Rdauae. upon payment of art soma Mauad by ttds SwMity Imtrvaoeat, this 5wAly Tnr;ertmreot apd. the estate
cum" ;sltari teY ubm and become void. Auer a* occarmwcc Lendw sdttsA discharge and this SecuYitY WtttMM
.0 rina . Danvww to Fay any iota . I.au3sr MR) Chula z : 4c tor thin 5��•
Instnm>caht, but only if the fee i9 paid to a thud party far services rendered and the Atrgi rg of the fee Is patmltted under
applicable taw.
2V Watvere. Narrower, to the extant permitted by &MUmble law, Valves and 1611 M sty amt or defe= in pmeeedlop
to eufor>re, Mis S=rlt bmumen; and Irtttroby watvas that bmM of any prteserrt or A=v Is= providing for a q of cxca mton,
Man CA of limo, exrs>'aption fee= WnWbUjeat, 107 and Sala, cad hamesteAd erttugle e,
24e. Relnademmt ItWod. Berrro m Hahn w r4now provide0 is path 18 aired azmnd to one how !d' to tbe,
eromtumrceaa w o f biddio& at a sberhTs pelts or cam tale pNtgttrtat to tbie Security l ft
7S., F=v hW b(ooey A& tgaga. If arty of the debt secured by liras Seta ft Iashult is feat to Sommer to acelWm tithe
to •ttro Property this Security Instrtonreat shall be a pmddde mpg mottje.
26.1. luttrest: Pale Altser Juftwcat. �atarovveac agtoca thhwt tiro i> rate payable after a jud�mett h entexud an the Nato
or is su =SOA of meutgage foreclosure tdhait be tbo no pgole ftft Hato to lima under the Note.
f:7'ilfikldw to this Secearlt!' YtaeRlrthdt W. Hate at nlom riders am mwntcd by Borrower' sad Teoorded raged= wM tA
Scnorlry.Pt+<r =m w, t9te emaveteaota and Wwoeate of each aft rider shall bebcarporated into aad"a»rertd and aeppl maw
the covenaatn cad ag Mnems of this Scomity mstnnmeat fps if rho ridws) were a pelt of thus Seatrity InsMamantt.
IChecx applleabtc box{ea)] .
jestabto theta Radar ❑ condominium Rider W Family Rhieer
QGm �Y� RhW P Unit 1XVelopment Rider B[vmMy Fa AAA Rider
Rao
VA Rider � Second Now Rider
(�PVD nt Pap. s is 7 8190
%"� U t 9 5 3 PG .0 2'0 4
310Mx6 smow. sortwm zv*m and agn�es m the teuus ea4 txwene cantaitud iri Socarity loran cat
in ahy mss) uy Boracyvuar and TaX w8h tt
P A 'CK T . •AQRAWAr
�'� � 8'!'RAY►A Nnri'nMrrx
(seal) (Sao
4`CifiiLl�Re9t
do c�gY that the voxrett address of
tfie wiChia - Mn 1400 S, DOUGLASS RD.. SUM LOD
ANAHEIM, CA 92M6
Wit=s my hand this day of
' AQeatofMo�yee
COMMONW"Mil 01F FMiN0nVAMI'A, Comj'SM
0n;d&, the -3i6T day of IAAV b e ft * m. I* andarskgaed OM M,
Pmana WM'ed ?Or T -i- SkpAa A I t S*,(P.A .•
kwwn to sae (or satdator ly proven) m be the
porson . whose M MM Aet- aubscIbed to the widit insttttm a Arid wkwwleW that
wmwAed:tW =w far the putpnses herein cotained.
IN WnWMs WREREOP. T b==w sat my nand and official ad.
My ComMiaeion ftim;
Tara ott�t6cer
•� a'
Wit*, p .
1I- t3FgPa) Wa fzl ra.r m � porm 3o5s 9190 •
h*A: PUMI 1953PG0 245 ��
i ,
SCHEDULE C
L IM& WISCRIPTtON
Commftmant Number: 8100-444 Fps Number, $1004"
ALL THAT GERTAm -lot of ground sihrate in the Borough of Mt. Wahl Strlrq;$, Cumberland COW*
Pennsylvania, bounded and described as iAUM'
ON the North by Bailer Street, on the West by lot now or formerly of Mary Boyer and frannariy of John Muaen, err
the south by a 12 fact alley, an the Test by lot now of "edy of Edward Web, lormerty of Frank 0. Paul,
CQNTA!lIINO in the front on a Idutirar Street 40 and extandIng.In depth Id4 feet; h etr� b 1* 0 A 9 In Hamran
pWn of plot aBugar $treet, and baing hnpmmW vAth a three tswry frame dwal ft
rQ L� �] (��! /� c S T E W.t�►, R T T IT L E
BK'! r��IJal•r"- GO2.0.6 GUA*&NTT COMPANY
Fl)(EDIADTUSTABLE RATE RIDER.
I�IDtyR ><admt , R:wte Caapa�
nUS FrKW/ADIUSTABlZ RATE RWER is made an this Hut . day of Mar .
2006 . and is bcmpmeted into and " be alemmad to m td and auppleimeut Sus WM Dcad of
rust or Swudty► Dead (the "Swalty ItteUtmtent') of Me game date given by the trndersipiod Me "Bono wer") to
Awl Eouvwcea FbwWAQf *0lc ll= Nate (the "Note ") w
.LANG BBACB MORT"GEE COMPANY
(dm"I,cnder ") of dm same dace ;md vavning the prop+ d=dbed in the Security J+eetaumeat and located att
107 W BUTUM
1Vl'JWLLY SPXUM, VA, 17US
9WPff4' Ad*w4
THE NOTE PROVIDES FOR A CHAfift IN THE BORROWER'S FIXW INTEREST
RATE AMP TO AN AWUSTAJLJ•6 qN UEST BATE. THE. NOTE UMrM THE
AMOUNT THE BOARO'41 KW8 ADJW TAI9I.k RATE CAN CHANGE AT ANY Ohl&
TIME AND THE MAXIMUM RA' 8 "M BOAROWER MUST PAY.
AIAUIIMOX" COVM(ANTS. In addition to the covetta is vmd a$tamtetsts made In the Swu6ty IaZ mamt,
Vorrowea vM f wngor fnr or mwr;nPW and affm zi% fh trw=t
A. ADYMABL.H. RATE AND MONTHLY PAYMENT CH04S
The Note pmvldm for ati hddal fbtad interest Tare of 6.050 ; 9G. The Now also ptavtdes For
R dtamge in the initial fixed WO to as *4Usdable inaxest rate, a9 foUowtr
L A'Q1iMASLE AN9I'X' BATE AND MONTHLY PAY1tM CHWGW
(a) Chas w Data
The hti W Sxed Wbvd ram will dmp to an adjustable breoW m an the Van day of Juice
2006 . add on the Am day of the imomb every 6th month thereafter, &ub data on which the adjustable
i immt We aauld ehagge is Galled a "Change Date."
(b) 7%C Index
Segtant M with the flat C mp hate, the hvtarest rata will be bantd an as b&Z. no "Wdeat" is tin avotW
Of the Loudon intea:baalt o5wA reuse for 4x oft doUV depos In the Lttndoat RawW baW an quotatloas at
five major buff ("LIBOR ). as set fmtit in the "Mottoy Rates" sod w of The Wall Svw jour or if Gina
Money Rws MUM cease to be published or becomes umw4atble for any ram=, then vs sat forth Jn a
comparable publicaadon selemd by the L*adar. Th& most =wt Jmlex figure 4vaiUhle as of the date 45 doya
below a& Clump Date is called the "Qzm Iadm"
Plan Olft FwwW Rana Rtdw • tenor
• Pp t 0 s
740= mmm YaEUMMC LAMM M MHL M • =W3210MB
4NO0a I & W t4"PO Low N
9 5-3 -PG 0-2'07
(c) Caladadiou or cuum
Before emtb Ct WSO Data tba Leaden will ckl WAm my new WW eat rite by addlag
Font and Nkm Rundredtbs ptsoeat p poWt( ( 4AN %) to the
Index. The Isar will Ili ft rotted tip reault of IWs airliners to the eesrest one - eighth of oue p remtege
pohtt (0.125%). subject to the Haii% stated In Saud=1(d) an On kuewing page, tWs tbuadod anoount will be the
ttew lutevest sate waa'1 the Dw Cbmage beta.
The Lander wAi then de hmnine the amunt of the monthly psymsat that would be MINICI rt to repay the
uopaid prianaipai baistoce as of tha Change Barr In llfll an the Mtt mity Data tat the new item rate is
subataadally a qwd payntes. TbB XwWt; of thin eak"M will be the new monddy M=r.
(d) him on babrrea:t }Rate Cbu %a
The inWM sate at the 2W Clmahe Date win Aot M groaner than 10.03tt % or lass that►
9 %. rMwr** lnr, thn uitjmonhtr, intrma n ft wM never be tncresaed at dwxeasod on mW
sin& Ct >baat by ai= dun Oft
pa'xornOV points ( LOW 9) ism. Me rate of Imerest applicable ehaing tie psis Whg 6 usPAftlts. 'rite
wVusmble iQamaat rate wal ur4w be greater tban 14.090 %1 Tach is called tiMt'Maxieaum 9=
or I=$ than 6.090 S which is called the "Midwma date".
(e) Etrectit" riots or Cbrurge s .
Hub anew ad,}ctaWe Awma t sate will become dradw on Bach Cbaaga DM. 7u am um of each new
snabthly vWwam wM be due and payable on the iimt maomhy payment date WWr thus Cpattge Data wd the
araoaaa of the Momhly PRY do8" 0801M
(1) Nance of Changes
-be Leader wiII deiiver or mall a twtit o of so dwqa in do adjustable 9ucotrsx rare end ft aunt of 'tut.
ftw manthly paywwt: to the Dmwwor before the etreedve date of any d"c bloat nouns wlti kWuala
infasmattott required by law to be given to do Baaowar and also rite tine and tedephoste mm tr of al psrsaa who
will =Www arty O"Wons regarding the notion..
H. x'BMWR OF THE PROrMTY Olt A MMZM L 11a1T$i13S7' IN BORROWER
1. Until Bwrowa o initial Raced intaxw rate drangas w ea adjosuft iwemeat we under the owns stated in
Section A above. UuMorm Covebum 17 of do Security kstrmnd provides as faliaws:
Transfer or the Proprxty or a BMlWCW b tetwat In Borrower. If all or wW put of the Pmpcoy or coy
iata m in it is sold or mm4armd (p if a benddA IWOM in Aarsoweur is Bald or trM69nd and Bottvwor h not
n nateral pt brr) rvirhtotu I.endasIs prior written conont, Lauder may. at to option, seelut m tmaallate p*anwt in
still of all sums scoured by tt>ia Se =ity WwnuT=L Ifa+a nw, this option gW not be deans by Lander if
exercise is prabibited by federal Iasa ss Of ft dataof this Security ftU=ML
If Lw dac exetcisas tbhs opdon, leader shall give Banowar to dw of eacaltmttkm The aodna tdudl provide a
pedod of not less than 30 dWa frosa that date the natia k dellveod or =Had wilt which 8*0*w74r must pay all
PGnmVtwdr rhuOAOju6uWs Rid* itidew - Libor
TM
4>wa�ouotr>aoota+o '
Loan
BK I 9.53PIG 0 2:0-0
am seamed by t1Uix SaWflty Insbnsrt w4 If Banmwtr fops to pay tbaet mats prior to the expiration of this
patina, X.eader may invoka any rwaafi a permitted by. ft Security IvWUW4 withmn bulbar no*e Or dmUd
On Bo UM".
z. When Borrowers kddal Bud ftttm* rags ohmges to rn n4itsmble Iatmeu rue ceder the terr= stated is
' Swdm A about, Unifomn Covattant 17 of the Secorlry Iaratoaaent contafoW in Section Ba) above dwU than
Casa to be In ate t, and Unlforat tlrsvamw 17 of the Seeutitp Instrum= shall be ammded to read as foltam:
Mr efer of the Propwq at a BatrdeW LUtered In Bon ww. If oh or arty part of the Ptnperty at my
two= In ft is sold Or ttmeemd. (or if a beaalidd Interest in Borrower is sold or tms kred and Bonntwar is not
A 9at4W person) wldtouc Lemdor's prior wd= cammrt. Lehr may, at its apdan, rggdm imwedim payment in
=Of NU odes MAW by tlsfsr Seaatity lm= m n. Hawaver. this option shall not be exerufsed by Lext 1 If
enwim In pmblbited by fade A Iaw as of ttro data of this Swarity Inst mml. Lander elm shall t:vt arerdsa this
oprhm ifs (a) Borrowar causes to be submitted to Iender Whno&m M#*ed by L•eudw to svalmn to Intended
traasferce w If a new loco weft: befog me& to die nus&teet ad (b) I e ramonoly detm* ttL Letrdar" s
tmotu'ity will WA be impabW by the loan aastr *dom and that the rbk of a breach of any onveamtt or ogrnetas td irl
this Smitity Inn uaeut ie saoaptable to Lander.
To the extent permitted by appUobta Iew. L=iar may charge it reasettabto be as a comdldon to L=dces
cow= to the low - on. Isadar Ako my >bquh* the a'srthttza W sign MI asmtdon arombmt that is.
acceptable w Leader and that obligates thus Umdemte to Imv A the promim and agmmmm made in iht Nato
and, in this 8eeurifiy bUUM04t. Borrower will wathm to be obUgatad wider the Nato aid Scadty Imstrumeat
Unless Leader relaw Ran" r k writing.
If leader wwrolsaa Utin option to maim inawdiata Finam in M. Lander tdtaU give Borrower nodca of
amWeration. The =dm shall pwMda a peziod of not less am SU days Oft tho 4M the rtmdop is detltvared or
rndW within wbich Bormwerr must pay all stuas $emu% by this Set city bastty M If BMTMor fans to pay
blase mm peio M the aspiration of tide period. 140dtsr may i0ft ,aq allnadks pamnilAd by this Secudly
Insm=mt without looser ncdec or 6emmd an S*Uvw*.
BY SIMMCI BMOW. Bnrmwat emepta smd agrees to the tfltmt and covenants contained In ibis
Fixed /Airibuable Rags Rider.
PA CS'r bTLtAxi '
get {5ea1)
M �anew�r - Norroger
[SIP 0XI&W 0*1 1 Cottify ihis to b e recorded
Pam vivamb FU"A tx liar. Araw t tba In Cumba d County PA
. 414MM wamtMMvo l.titttt N
Rca mir of Doeft
` LOAN NO.
t FIXEDIADJUSTABLE RATE NOTE
(LIBOR Index - Rate Caps)
THIS NOTE PROVIDES FOR A CHANGE IN MY FIXED RATE TO AN ADJUSTABLE INTEREST
RATE. THIS NOTE LIMITS THE AMOUNT MY ADJUSTABLE RATE CAN CHANGE AT ANY ONE
TIME AND THE MAXIMUM RATE I MUST PAY.
May 31, 2006 ANAHEIM CA
[Date] [City] [State]
7 W BUTLER STREET
9 T.HOLLY SPRINGS, PA 17065
[Property Address]
1. BORROWER'S PROMISE TO PAY
In return for a loan that I have received, I promise to pay U.S. $ 109,520.00 (this amount is called
"principal "), plus interest, to the order of the Lender. The Lender is
LONG BEACH MORTGAGE COMPANY
I understand that the Leader may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled
to receive payments tinder 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 8.050 %. The interest rate I will pay may change in accordance with Section 4 of this Note.
The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any
default described in Section 7(13) of this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making payments every month.
I will make my monthly payments on the first day of each month beginning on July 1 , 2005
I will make these payments 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. My monthly payments will be applied to interest before principal. If, on
June 1 , 2036 , I still owe amounts under this Note, I will pay those amounts in full on that
date, which is called the "Maturity Date."
I will make my monthly payments at: P.O. Box 2441, Chatsworth CA 91313 -2441
or at a different place if requited by the Note Holder.
(B) Amount of My Initial Monthly Payments
Each of my initial monthly payments will be in the amount of U.S. $ 807.44 This amount may
change.
(C) Monthly Payment Changes
Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I must
pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance with
Section 4 of this Note.
4. ADJUSTABLE INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Dates
The initial fixed interest rate I will pay will change to an adjustable interest rate on the first day of
June , 2006 , and on that day every 6th month thereafter. Each date on which my
adjustable interest rate could change is called a "Change Date."
(B) The Index
Beginning with the first Change Date, my interest rate will be based on an Index. The "Index" is the average of the
London interbank offered rates for six month dollar deposits in the London market based on quotations at five major banks
( "LIBOR "), as set forth in the "Money Rates" section of ]fie Wall Street Joumal, or if the Money Rates section ruses to be
published or becomes unavailable for any reason, then as set forth in a comparable publication selected by the Lender. The most
recent Index figure available as of the date 45 days before each Change Date is called the "Current Index."
If the Index is no longer available, the Note Holder will choose a new index that is based upon comparable information.
The Note Holder will give me notice of this choice.
(C) Calculation of Changes
Before each Change Date, the Note Holder will calculate my new interest rate by adding Four and Ninety
Nine Hundredths percentage point(s) ( 4.990 %) to the Current
Index. The Note Holder will then round the result of this addition to the nearest one - eightb of one percentage point (0.125 %).
Subject to the limits stated in Section 4(D) below, this rounded amount will be my new interest rate until the next Change Date.
The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid
principal that I am expected to owe at the Change Date in full on the Maturity Date at my new interest rate in substantially equal
payments. The result of this calculation will be the new amount of my monthly payment.
(D) Limits on Interest Rate Changes
The interest rate I am required to pay at the first Change Date will not be greater than 10.050 % or less than
8.050 %. Thereafter, my adjustable interest rate will never be increased or decreased on any single Change
Date by more than One percentage points ( 1.000 %)
MULTISTATE FIXEDIADJUSTABLE RATE NOTE - LIBOR
Patio 1 of 3
4940265 (01111 VMP MORTGAGE FORMS • (6001621.7291
41402661 (01 @5702)rA
Exhl
LOAN NO.
front the rate of interest I have been paying for the preceding 6 months. My interest rate will never be greater than 14.050
which is called the "„Maximum Rate" or less than 8.050 % which is called the "Minimum Rate ".
(E) Fffective Date of Changes
My new interest rate will become effective on each Change Date. 1 will pay the amount of nrr new monthly payment
beginning on the first monthly payment date after the Change Date until the amount of my monthly payment changes again.
(F) Notice of Changes
The Note Holder will deliver or mail to me a notice of any changes in my adjustable interest rate and the amount of my
monthly payment before the effective date of any change. The notice will include information required by law to be given me
and also the title and telephone number of a person who will answer any question I may have regarding the notice.
S. BORROWER'S RIGHT TO PREPAY
I have -the right to make payments of principal before they are due. Any payment of principal, before it is due, is known
as a "prepayment." A prepayment of only part of the unpaid principal is known as a "partial prepayment." A prepayment of
the full amount of the unpaid principal is known as a "full prepayment."
If I make a full prepayment at any time during the first 2 year(s) of the loan, I may be charged a
fee as follows:
If Noteholder receives a prepayment on or before the first anniversary of the date of the Note, the prepayment fee shall be
equal to three percent ( 3.000 %) of the original loan amount. If Noteholder receives a
prepayment after the first anniversary but on or before the second anniversary of the date-of the Mote, the prepayment fee shall
be two percent ( 2.000 %) of the original loan amount. IX" XX
iCAM
XXIXCX X)01JQqXXXXX*XX*XKM after, pregayment of the
Note shall be permitted without any prepayment fee.
The prepayment fee shall be payable upon full prepayment, voluntary or involuntary; including but not limited to a
prepayment resulting from Noteholder's permitted acceleration of the balance due on the Note. Notwithstanding the foregoing,
nothing herein shall restrict my right to prepay at any time without penalty scented but unpaid interest that has been added to
principal.,
When I make a full or partial prepayment, I.wiil notify the Noteholder in writing that I am doing so. Any partial
prepayment of principal shall be applied to interest accrued on the amount prepaid and then to the principal balance of the Note
which shall not reduce the amount of monthly installments of principal and interest (until reamortized as set forth in the Note at
the next Payment Change Date) nor relieve me of the obligation to make the installments each and every month until the Note is
paid in full. Partial prepayments shall have no effect upon the due dates or the amounts of my monthly payments unless the
Noteholder agrees in writing to such changes.
6. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan changes, 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: (i) any such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (ii) any sums already collected from
me that 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.
7. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charges for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of FIFTEEN
calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be
6.000 % 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 ttie full amount of principal that 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 delivered or mailed to
me.
(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 if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has requited me to pay immediately in full as described above, the Note Holder will have the right to
be paid back by me for all 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.
S. 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 mail to me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address.
Unless the Note Holder requires a different method, any notice that must be given to the Note Holder under this Note will
be given by mailing it by first class mail 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.
MULTISTATE FlXEDlADJUSTABLE RATE NOTE - LIBOR
4140265 1011 a Pegs 2 of a
41402662 (012&= Ln
• i i
LOAN NO
9. ; OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in
this Note, including the promise to pay the full amount owed. 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 of this 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 owed under this Note.
1 0. 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.
11. 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 that might result if I do not keep the promises which I make in this
Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full
of all amounts I owe under this Note. Some of those conditions are described as follows: .
(A) Until my initial fixed rate changes to an adjustable interest rate under the terms stated in Section 4 above, Uniform
Covenant 17 of the Security Instrument provides as follows:
Transfer of the property or a Beneficial Interest in Borrower. If all or any part of the Property or any
interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not
a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in
full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if
exercise is prohibited by federal law as of the date of this Security Instrument.
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 delivered or mailed 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.
(B) When my initial fixed interest rate changes to an adjustable interest rate under the terms stated in Section 4 above, Uniform
Covenant 17 of the Security Instrument described in Section I I(A) above shall then cease to be in effect, and Uniform Covenant
17 of the Security Instrument shall instead provide as follows:
Transfer of the property or a Beneficial Interest in Borrower. If all or any part of the Property or any
interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not
a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in
full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if
exercise is prohibited by federal law, as of the date of this Security instrument. Lender also shall not exercise this
option if: (a) Borrower causes to be submitted to Lender Information required by Lender to evaluate the intended
transferee as if a new loan were being made to the transferee; and (b) Lender reasonably determines that Lender's
security will not be impaired by the loan assumption and that the risk of a breach of any covenant or agreement in
this Security Instrument is acceptable to Lender.
To the extent permitted by applicable law, Lender may charge a reasonable fee as a condition to Lender's
consent to the loan assumption. Lender may also require the transferee to sign an assumption agreement that is
acceptable to Lender and that obligates the transferee to keep all the promises and agreements made in the Note
and in this Security Instrument. Borrower will continue to be obligated under the Note and Security Instrument
unless Lender releases Borrower in writing.
If Lender exercises the option to require immediate payment in full, 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 delivered or
mailed 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.
WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED.
_ (Seal)
(Seal) (
PA RICK T STRAKA �ormwer "P A lE M STRAKA • Borrower
(Seat) (Seal)
- Borrower - Borrower
(Sign Original Only]
MULTISTATE RXED /ADJUSTABLE RATE NOTE - LIBOR
4140265 toi i it Page 3 of 3
4140M (01PM 02) rti .
Pay to the order of
Without Recourse
Long Be ch Moi a Company
a
obis S. ange, Vice resident
Chase (FL5 -7734) 'w
P.O. Box 44090 CHASE
Jacksonville, FL 32231 -4090
7190 1075 4460 2536 6790
July 17, 2013
00001775 HDLO CC 19813 -BW860
STEPHANIE M STRAKA
107 W BUTLER ST
MOUNT HOLLY SPRINGS, PA 17065 -1226
6 �— ,"
i
Chase (FL5 -7734) M.
P.O. Box 44090 CHASE i mp
Jacksonville, FL 32231 -4090
7190 1075 4460 2536 6790
July 17, 2013
CERTIFIED MAIL: Return Receipt Requested and First Class Mail
00001775 HDLO CC 19813 -BW860
STEPHANIE M STRAKA
107 W BUTLER ST
MOUNT HOLLY SPRINGS, PA 17065 -1226
Act 91 Notice
Account: e "Loan ")
Property Address: OWLEIR ST
MT HOLLY SPRINGS, PA 17065 (the "Property")
Dear STEPHANIE M STRAKA:
On the following page, you will find a notice regarding your home as required by Pennsylvania law.
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official Notice that the mortgage on your home is in default, and the lender
intends to foreclose. Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
( HEMAP) may be able to help to save your home. This Notice explains how the
program works. To see if HEMAP can help, von must MEET WITH A CONSUMER
CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE
DATE OF THIS NOTICE. Take this Notice with you when you meet with the
Counseling Agency.
The name, address, and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any questions, you
may call the Pennsylvania Housing Finance Agency toll -free at 800 - 342 -2397. (Persons
with impaired hearing can call 717- 780 - 1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact an attorney in your area. The local bar association
may be able to help you find a lawyer.
LA 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 LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR
EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): PATRICK T STRAKA
STEPHANIE M STRAKA
PROPERTY ADDRESS: 107 W BUTLER ST
T HOLL SPRINGS, PA 17065
LOAN ACCOUNT NUMBER:
ORIGINAL LENDER: LONG BEACH MORTGAGE COMPANY
CURRENT LENDER/SERVICER: JPMorgan Chase Bank, N.A.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing).
During that time, you must arrange and attend a "face -to- face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE,
THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT"
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING 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 (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.
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 APPLICA TION AS SOON AS POSSIBLE IF YOU HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN
THIRTY (3 0) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FR OM S TA R TING A FORE CL OS URE A C TION A GA INS T YOUR PROPERTY, AS
EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE."
YOUHAVE THE RIGHT TO FILE A HEMA P A PPLICA TION E PEN BE YOND THESE TIME
PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FR OM STAR TING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS E VENTUALL Y A PPR 0 VED AT ANY
TIME 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 will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it up to
date).
NATURE OF THE DEFAULT -- The mortgage debt held by the above lender on your property located at:
107 W BUTLER ST, MT HOLLY SPRINGS, PA 17065 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
12/01/2012 $801.86
01/01/2013 $801.86
02/01/2013 $801.86
03/01/2013 $801.86
04/01/2013 $801.86
05/01/2013 $801.86
06/01/2013 $801.86
07/01/2013 $801.86
Other charges:
Late Charges: $35.80
Insufficient Funds (NSF) Fees: $0.00
Other Fees: $0.00
Advances: ($474.93)
Amount Held in Suspense: $521.85
TOTAL AMOUNT PAST DUE: $5,453.90
HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$5,453.90, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) -DAY PERIOD. Payments must be made by cash, cashier's check, certified
check or money order made payable and sent to
Overnight/Regular Mail: Chase
Mail Code: OH4 -7133
3415 Vision Drive
Columbus, OH 43219 -6009
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 mortgaee debt This means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made
within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose
upon your mort2a2ed 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 attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have
to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's
fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you
cure the default within the 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 W to one hour before the Sheriff's Sale. You may do so by paying
the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs
connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in
writing by the lender, and by performing any other requirements under the mortgage Curing your default in
the manner set forth in this Notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months
from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER
Name of Lender: Chase
Address: Mail Code: OH4 -7384
3415 Vision Drive
Columbus, OH 43219
Telephone Number: 800 - 848 -9380
Fax Number: 614 - 5004605
Contact Person: Bruno Mejia
E -mail Address: state .programs.intake @jpmchase.com
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's 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 Sheriff's Sale,
a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You X may or 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 the other requirements of the mortgage
are satisfied.
YOU MAY ALSO HAVE THE RIGHT
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
• YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
Advantage Credit Counseling Service /CCCS of 888 - 511 -2227 2000 Linglestown Road Harrisburg 17102
Western PA
Community Action Commission of Capital 717 - 232 -9757 1514 Derry Street Harrisburg 17104
Region
Housing Alliance of York/Y Housing Resources 717 -855 -2752 290 West Market Street York 17401
Maranatha 717 - 762 -3285 43 Philadelphia Avenue Waynesboro 17268 +
Pennsylvania Interfaith Community Programs, 717 -334 -1518 40 E. High Street Gettysburg 17325
Inc.
PHFA 717 - 780 -3940 211 North Front Street Harrisburg 17110
800 - 342 -2397
Rev. 10/12
FM646
We are attempting to collect a debt, and any information obtained will be used for that purpose.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the
attorney's name, address, and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy
under Title 11 of the United States Code, this notice is for compliance and/or informational purposes
only and does not constitute an attempt to collect a debt or to impose personal liability for such
obligation. However, a secured party retains rights under its security instrument, including the right to
foreclose its lien.
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service, you may be eligible for benefits and protections
under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or
eviction. You may also be eligible for benefits and protections under state law. SCRA and state Military
benefits and protections also may be available if you are the dependent of an eligible Servicemember.
Eligible service may include:
Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or
Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or
Active service as a commissioned officer of the Public Health Service, or
Service with the forces of a nation with which the United States is allied in a war or Military action,
or
Service with the National Guard of a state militia under a state call of duty, or
Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause.
For more information, please call Chase Military Services at 877 - 469 -0110.
AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS
As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability
Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts
to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in
advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling
888 - 995 -HOPE; 888 - 995 -4673. We offer loan modification assistance free of charge (i.e., no modification fee
required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the
fewer options you may have.
BW860
r
Chase (FL5 -7734)
P.O. Box 44090 CHASE
Jacksonville, FL 32231 -4090
7190 1075 4460 2536 6806
July 17, 2013
00001776 HDLO CC 19813 -BW860
PATRICK T STRAKA
107 W BUTLER ST
MOUNT HOLLY SPRINGS, PA 17065 -1226
Chase (FL5 -7734) CHASE ! i
P.O. Box 44090
Jacksonville, FL 32231 -4090
7190 1075 4460 2536 6806
July 17, 2013
CERTIFIED MAIL: Return Receipt Requested and First Class Mail
00001776 HDLO CC 19813 -BW860
PATRICK T STRAKA
107 W BUTLER ST
MOUNT HOLLY SPRINGS, PA 17065 -1226
Act 91 Notice
Account: he "Loan ")
Property Address: 107 W BUTLER ST
NIT HOLLY SPRINGS, PA 17065 (the "Property")
Dear PATRICK T STRAKA:
On the following page, you will find a notice regarding your home as required by Pennsylvania law.
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official Notice that the mortgage on your home is in default, and the lender
intends to foreclose. Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
( HEMAP) may be able to help to save your home. This Notice explains how the
program works. To see if HEMAP can help, you must MEET WITH A CONSUMER
CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE
DATE OF THIS NOTICE. Take this Notice with you when you meet with the
Counseling Agency.
The name, address, and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any questions, you
may call the Pennsylvania Housing Finance Agency toll -free at 800 - 342 -2397. (Persons
with impaired hearing can call 717- 780 - 1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact an attorney in your area. The local bar association
may be able to help you find a lawyer.
LA 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 LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR
EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): PATRICK T STRAKA
STEPHANIE M STRAKA
PROPERTY ADDRESS: 107 W BUTLER ST
LY SPRINGS, PA 17065
LOAN ACCOUNT NUMBER:
ORIGINAL LENDER: LONG BEACH MORTGAGE COMPANY
CURRENT LENDER/SERVICER: JPMorgan Chase Bank, N.A.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing).
During that time, you must arrange and attend a "face -to- face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE,
THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ",
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING 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 (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.
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 APPLICA TION AS SOON AS POSSIBLE IF YOU HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH THE PHFA WITHIN
THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROM STARTING A FORECLOSURE ACTION AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
P E R I O D S . A L A TE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY
TIME 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 will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(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 THE DEFAULT -- The mortgage debt held by the above lender on your property located at:
107 W BUTLER ST, MT HOLLY SPRINGS, PA 17065 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
12/01/2012 $801.86
01/01/2013 $801.86
02/01/2013 $801.86
03/01/2013 $801.86
04/01/2013 $801.86
05/01/2013 $801.86
06/01/2013 $801.86
07/01/2013 $801.86
Other charges:
Late Charges: $35.80
Insufficient Funds (NSF) Fees: $0.00
Other Fees: $0.00
Advances: ($474.93)
Amount Held in Suspense: $521.85
TOTAL AMOUNT PAST DUE: $5,453.90
HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$5,453.90, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) -DAY PERIOD. Payments must be made by cash cashier's check, certified
check or money order made payable and sent to
Overnight/Regular Mail: Chase
Mail Code: OH4 -7133
3415 Vision Drive
Columbus, OH 43219 -6009
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 full payment of the total amount past due is not made
within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose
upon 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 attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have
to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's
fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you
cure the default within the 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 up to one hour before the Sheriff's Sale. You may do so by paying
the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs
connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in
writing by the lender, and by performing any other requirements under the mortgage Curing your default in
the manner set forth in this Notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months
from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER
Name of Lender: Chase
Address: Mail Code: OH4 -7384
3415 Vision Drive
Columbus, OH 43219
Telephone Number: 800 - 848 -9380
Fax Number: 614 - 5004605
Contact Person: Bruno Mejia
E -mail Address: state.programs.intake @jpmchase.com
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's 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 Sheriff's Sale,
a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You X may or 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 the other requirements of the mortgage
are satisfied.
YOU MAY ALSO HAVE THE RIGHT
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
• CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
Advantage Credit Counseling Service /CCCS of 888 - 511 -2227 2000 Linglestown Road Harrisburg 17102
Western PA
Community Action Commission of Capital 717 - 232 -9757 1514 Deny Street Harrisburg 17104
Region
Housing Alliance of York/Y Housing Resources 717 - 855 -2752 290 West Market Street York 17401
Maranatha 717 - 762 -3285 43 Philadelphia Avenue Waynesboro 17268
Pennsylvania Interfaith Community Programs, 717 -334 -1518 40 E. High Street Gettysburg 17325
Inc.
PHFA 717 - 780 -3940 211 North Front Street Harrisburg 17110
800 -342 -2397
Rev. 10/12
FM646
We are attempting to collect a debt, and any information obtained will be used for that purpose.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the
attorney's name, address, and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy
under Title 11 of the United States Code, this notice is for compliance and/or informational purposes
only and does not constitute an attempt to collect a debt or to impose personal liability for such
obligation. However, a secured party retains rights under its security instrument, including the right to
foreclose its lien.
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service, you may be eligible for benefits and protections
under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or
eviction. You may also be eligible for benefits and protections under state law. SCRA and state Military
benefits and protections also may be available if you are the dependent of an eligible Servicemember.
Eligible service may include:
Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or
Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or
Active service as a commissioned officer of the Public Health Service, or
Service with the forces of a nation with which the United States is allied in a war or Military action,
or
Service with the National Guard of a state militia under a state call of duty, or
Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause.
For more information, please call Chase Military Services at 877 - 469 -0110.
AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS
As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability
Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts
to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in
advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling
888 - 995 -HOPE; 888 - 995 -4673. We offer loan modification assistance free of charge (i.e., no modification fee
required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the
fewer options you may have.
BW860
VERIFICATION OF COMPLAINT
The undersigned, a a x �b -QPj 4 kA , does hereby certify that h e/she is
Vice President of JPMorgan Chase Bank, N.A. ( "Chase "), and that Chase has been duly nominated
and appointed by the Plaintiff as its mortgage servicing agent in regard to the mortgage Ioan which is
the subject of this action (the "Mortgage "). Plaintiff lacks sufficient information to make this
verification because Plaintiff is not the entity that maintains the business records for the Mortgage.
Chase, in its capacity as mortgage servicing agent for Plaintiff, maintains the business records for the
Mortgage, and therefore, as an employee of Chase, I have sufficient information to make this
verification in accordance with Pa.RC.P. 1024(c)(1).
I am authorized to make this Verification on Plaintiff s behalf and do hereby verify that the
facts as set forth in the foregoing Complaint are true and correct to the best of my information and belief.
I have access to and have reviewed the business records of Chase for and relating to the Mortgage, and I
make this Verification based on my review of those records, which are maintained by Chase in the
course of its regularly conducted business activities and are made at or near the time of the event, by or
from information transmitted by a person with knowledge.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904
relating to unworn falsification to authorities.
Dated: C) - ;(C� - 1 By: _
Name:��.0
Vice President, JPMorgan Chase Bank, N.A.
Loan No, XXXXXX 1744
S & D FILE NO: 13 -044173
Patrick T. Straka and Stephanie M. Straka
s.
FORM 1
: IN THE COURT OF COMMON.PLEAS OF
Deutsche Bank National Trust Company, as Trustee CUMBERLAND COUNTY,
for Long Beach Mortgage Loan Trust 2006 -6 PENNSYLVANIA
Plaintiff(s)
VS.�;
Patrick T. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
Stephanie M. Straka c ` �� {
107 West Butler Street
Mount Holly Springs, PA 17065
DEFENDANTS J
Defendant(s) Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action,
you may be able to participate in a court- supervised conciliation conference in an effort to resolve this
matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a
conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact
MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and
request appointment of a legal representative at no charge to you. Once you have been appointed a legal
representative, you must promptly meet with that legal representative within twenty (20) days of the
appointment date. During that meeting, you must provide the legal representative with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
legal representative complete a financial worksheet in the format attached hereto, the legal representative
will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the
Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your
lender in an attempt to work out reasonable arrangements with your lender before the mortgage
foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for
the appointment of a legal representative. However; you must provide your lawyer with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60)
days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to
work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND
TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
SHAPIRO & DeNARDO, LLC
Date Attorneys for Plaintiff
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household How Long?
C
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# 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:
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 Ex enses: Please only include expenses you are currently a in
EXPENSE AMOUNT EXPENSE AMOUNT
Mortage Food
2" Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other prop. Payment
Install. Loan Payment Cable TV
Child Su port/Alim. Spending Mone
Day /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTI-I
I /We, , authorize the above
named to use /refer this information to my lender /servicer for the sole
purpose of evaluating in financial situation for possible mortgage options. I /We
understand that I /We am/are under no obligation to use the services provided by the
above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting
documentation
(hardship letter)
Listing agreement (if property is currently on the market)
FORM 3
IN THE COURT OF COMMON PLEAS OF
Deutsche Bank National Trust Company, as Trustee CUMBERLAND COUNTY, PENNSYLVANIA
for Long Beach Mortgage Loan Trust 2006 -6
Plaintiff(s)
vs.
Patrick T. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
Stephanie M. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
DEFENDANTS
Defendant(s) Civil
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this
mortgage foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court- supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel /Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
FORM 4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Defendant(s) Civil
CASE MANAGEMENT ORDER
AND NOW, this day of , 20, the defendant/borrower in the
above - captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court- supervised
conciliation Conference on at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the
defendantiborrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the time
frame set forth herein or such other date as agreed upon by the parties in writing or
ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant /borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff /lender must
either attend the Conciliation Conference in person or be available by telephone during
the course of the Conciliation Conference. The representative of the plaintiff/lender
who participates in the Conciliation Conference must possess the actual authority to
reach a mutually acceptable resolution, and counsel for the plaintiff /lender must
discuss resolution proposals with the authorized representative in advance of the
Conciliation Conference. If the duly authorized representative of the plaintiff /lender is
not available by telephone during the Conciliation Conference, the Court will schedule
another Conciliation Conference and require the personal attendance of the authorized
representative of the plaintiff /lender at the rescheduled Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
IF THE PROTHoNo AR',
Jody S Smith4��tixtr catt�t�br
"'13
Chief Deputy + l t. NOV Z� iw?
Richard W Stewart
Solicitor OFFiCE OFTH Sk.'ERIFF C-UHSEPiLAND
PENNSYLVANIA
Deutsche Bank National Trust Co.
vs.
Case Number
Patrick T Straka (et al.) 2013-6474
SHERIFF'S RETURN OF SERVICE
11/12/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion
Program and Complaint in Mortgage Foreclosure as"Not Found" at 107 W. Butler Street, Mt. Holly
Borough, Mt. Holly Springs, PA 17065. Residence is vacant.
11/14/2013 12:48 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselvas W Wifthanie M. Straka, .y. ho accepted as
''Adult Person in Charge. wive, North Midd eton Township, Carlisle, PA
17013.
)4 Z�11
//— 3i
'BRIAN GRZYB. KI, D TY
11/14/2013 12:48 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit:
Stephanie M Straka at 142 Amy Drive, North Middleton Township, Mt. Ily Springs, PA 17065.
BRIAN GRZYBdSKWDW0TY
SHERIFF COST: $79.69 SO ANSWERS,
November 15, 2013 RONNY R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft,Inc.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
AMY GLASS, ESQUIRE, ATTORNEY I.D. NO;� 308367
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-044173
Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS
Trustee for Long Beach Mortgage Loan Trust CIVIL DIVISION
2006-6 CUMBERLAND COUNTY t_nc
PLAINTIFF
NO: 13-6474 �3
VS.
Patrick T. Straka and Stephanie M. Straka
DEFENDANTS C,A
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED,
without prejudice.
SHAPIRO &DeNARDO, LLC
Date: BY: e�_-
Attorneys for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, AZf TORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D.NO. 311403
AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 13-044173
Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS
Trustee for Long Beach Mortgage Loan Trust CIVIL DIVISION
2006-6 CUMBERLAND COUNTY
PLAINTIFF
NO: 13-6474
VS.
Patrick T. Straka and Stephanie M. Straka
DEFENDANTS
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the Praecipe to Settle,
Discontinue and End on ' to all parties named herein at their last known
address or upon their attorney of record as below listed by regular mail, postage prepaid:
Patrick T. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
Stephanie M. Straka
107 West Butler Street
Mount Holly Springs, PA 17065
SHAPIRO & DeNARDO, LLC
Date: � BY: ef��'
Attorneys for Plaintiff