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HomeMy WebLinkAbout14-0218 Supreme Co COUi' do C6inm Pleas For Prothonotary Use Only: / CiVil'05ver3Sheet Docket No: CurtSberland'` r 1"f._ /� County 1 q, v v 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 bJ- law or rules of Commencement of Action: S El Complaint ll Writ of Summons (] Petition M Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Americhoice Federal Credit Union Terry and Tracy Harner T Dollar Amount Requested: L within arbitration limits I Are money damages requested? 0 Yes E No (check one) Doutside arbitration limits O N Is this a Class Action Suit? D Yes x' No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff /Appellant's Attorney: Christina C. Viola El Check here if ,you have no attorney (area Self- Represented JPro 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 El Intentional Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution (] Debt Collection: Credit Card Board of Assessment 0 Motor Vehicle D Debt Collection: Other 0 Board of Elections 0 Nuisance 0 Dept. of Transportation 0 Premises Liability El Statutory Appeal: Other S (] Product Liability (does not include mass tort) M, Employment Dispute: E � i Slander /Libel/ Defamation Discrimination C Ci Other: Q Employment Dispute: Other D Zoning Board Q Other: T , I + Other: O MASS TORT 0 Asbestos N f i Tobacco i Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste El Ejectment ©i Common Law /Statutory Arbitration Other: B D 0 Eminent Domain /Condemnation 0 Declaratory Judgment Ground Rent ! Mandamus 0 Landlord /Tenant Dispute 10 Non - Domestic Relations * Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Q Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental Q Partition 0 Replevin 0 Legal Quiet Title 0 Other: =1 Medical D Other: 1 Other Professional: Updated 1 /1/2011 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQU IRE (85165) Ali I LESLIE J. RASE, ESQUIRE (58365) JAN - 8 [ CHRISTINA C. VIOLA, ESQUIRE (308909) ANDREW J. MARLEY ( 312314) STERN & EISENBERG, PC PEW S Y 1581 MAIN STREET, SUITE 200 CV �'� WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (21.5) 572 - 81.11 FACSIMILE: (21.5) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union 616 Shelden Avenue, Suite 300 P.O. Box 144 Houghton, MI 49931 Civil Action Number: v. Terry L. Harper 154 Hollenbaugh Road Carlisle, PA 17015 -9717 COMPLAINT IN MORTGAGE FORECLOSURE Tracy A. Harper 240 W. North Street #2 Carlisle, PA 17013 -2323 Defendant(s) CIVIL ACTION - MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800 - 990 -9108 717- 249 -3166 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (851.65) LESLIE J. RASE, ESQUIRE (58365) CHRISTINA C. VIOLA, ESQUll2,E (308909) ANDREW J. MARLEY (312314) STERN & EISEN,BERG, PC 1581 MAIN STREET, SUITE 200 WAIZRINGTON, PENNSYLVANIA 18976 'TELEPHONE: (21.5) 572 - 81.1.1 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union 616 Shelden Avenue, Suite 300 P.O. Box 144 Houghton, MI 49931 V Civil Action Number: Terry L. Harper 154 Hollenbaugh Road Carlisle, PA 17015 -9717 COMPLAINT IN Tracy A. Harper MORTGAGE FORECLOSURE 240 W. North Street #2 Carlisle, PA 17013 -2323 Defendant(s) CIVIL ACTION - MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within expuestas en ]as paginas siguientes, usted twenty (20) days after this complaint and notice tiene veinte (20) dias de plazo al partir de la are served, by entering a written appearance fecha de la demanda y la notificacion. Hace personally or by attorney and filing in writing falta asentar una comparencia escrita o en with the court your defenses or objections to the persona o con un abogado y entregar a la claims set forth against you. You are warned that corte en forma escrita sus defensas o sus if you fail to do so the case may proceed without objeciones a las demandas en cbntra de su you and a judgment may be entered against you persona. Sea avisado que si usted no se by the court without further notice for any money defiende, ]a co.rte tomara medidas y puede claimed in the complaint or for any other claim or continuar la demanda en contra suya sin relief requested by the plaintiff. You may lose previo aviso o notification. Ademas, la money or property or other rights important to torte puede decidir a favor del demandante y you. requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede YOU SHOULD TAKE THIS PAPER TO A perder dinero o sus propiedades a otros LAWYER AT ONCE. IF YOU DO NOT HAVE derechos importantes para usted. A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET Lleva esta demanda a un abogado FORTH BELOW TO FIND OUT WHERE YOU inmediatamente. Si no tiene abogado o si CAN GET LEGAL HELP. THIS OFFICE CAN no tiene el dinero suficiente de pagar tal PROVIDE YOU WITH INFORMATION servicio, vaya en persona o flame por ABOUT HIRING A LAWYER. telefono a la oficina cuya direction se encuentra escrita abajo para averiguar IF YOU CANNOT AFFORD TO HIRE A donde se puede conseguir asistencia legal.. LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE Lawyer Referral and Information Service (Asociacion de Licenciados Servicio de Referencia e Information Legal) Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800- 990 -9108 717- 249 -3166 NOTICE PURSUANT TO FAIR DEBTOR COLLECTION PRACTICE ACT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A DISCHARGE IN BANKRUPTCY (AFTER ENTERING INTO THE RELEVANT MORTGAGE NOTE AND MORTGAGE AND HAVE NOT REAFFIRMED THE DEBT) THEN THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE MORTGAGE /LIEN AGAINST REAL PROPERTY. STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) CHRISTINA C. VIOLA, ESQUIRE (308909) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572 -8111, FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union 616 Shelden Avenue, Suite 300 P.O. Box 144 Houghton, MI 49931 V. Civil Action Number: Terry L. Harper 154 Hollenbaugh Road Carlisle, PA 1.7015 -971.7 COMPLAINT IN Tracy A. Harper MORTGAGE FORECLOSURE 240 W. North. Street #2 Carlisle, PA 17013 -2323 Defendant(s) COMPLAINT CIVIL ACTION - MORTGAGE FORECLOSURE 1. Plaintiff is Americhoice Federal Credit Union (hereinafter referred to as "Americhoice ") with offices located at 616 Sheldon Avenue, Suite 300, P.O. Box 144, Houghton, MI 49931. 2. Defendant(s) are Terry L. Harper andTracy A. Hamer, adult individuals with a last - known address of 154 Hollenbaugh Road, Carlisle, PA 17015 -9717 and 240 W. North Street #2, Carlisle, PA 17013 -2323, respectively. 3. Under date of 04/11/2012, defendants executed and delivered to Americhoice Federal Credit Union a mortgage upon the property 154 Hollenbaugh Road, Carlisle, PA (the "Property ") to secure the payment of the sum of $156,000.00. The said mortgage is recorded in the Office for the Recording of Deeds in and for Cumberland County on 04/13/2012 at Instrument # 201.21.0786 and is incorporated herein by reference as though set forth at length herein. A copy of the note, mortgage and legal description of the Property is attached hereto and made a part hereof as Exhibit "A ". 4. In accordance with Pennsylvania law, the required pre - foreclosure notice (under Act 91 /Act 6 as may be applicable), was sent to the defendants and no response was made in the appropriate period of time. A true and correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B ". 5. The said loan is in default as a result of the failure to pay the monthly installments of $1,014.80 due on July 1, 2013 and on the same day of each month thereafter. 6. The following is due on the loan: PRINCIPAL BALANCE .... ............................... ....................$153,268.50 INTEREST accrued thru 12/30/2013 of ......... ......................$3,996.55 Interest after 12/30/2013 shall accrue at the per diem rate of $18.90.) LATE CHARGES accrued thru 12/30/2013 of .....................$355.68 Late charges after 12/30/2013 shall accrue at the monthly rate of $39.52.) ESCROW ADVANCES . ............................... ...................:....$339.64 CORPORATE ADVANCES ......................... ........................$590.00 COSTS.................................................... ............................... $300.00 ATTORNEY'S FEE ............................... ............................... $7,000.00 LESS SUSPENSE (If any) .............................. ......................($217.38) TOTAL................................................... ............................... $165 Attorney fees are allowed in conformity with the mortgage documents and Pennsylvania law, and may be requested with judgment and may be collected in the event of a third party purchaser at Sheriffs Sale. If the mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually performed. - �` st ,^^ ^^!. ^...L• ^'.T.,.^S'v... -.. .�;- - - ... x { -- '.',� - -, -._, ... ' -. ... ' _' WHEREFORE, Plaintiff, Americhoice Federal Credit Union requests this Court to enter judgment, IN REM, for foreclosure of the mortgaged property for the sum of $153,268.50 plus interest thereon of $3,996.55 plus $18.90 per day from 12/30/2013 until judgment is paid in full, late charges of $355.68, plus late charges of $39.52 per inonth from 12/30/2013 until judgment is paid in full, escrow advances of $339.64, corporate advance of $590.00, costs of $300.00, attorney's fees of $7,000.00 and all other amounts set forth above, less any suspense as set forth above, together with record costs and any other amounts that accrue over the course of the instant matter and to which Plaintiff is entitled to recover. I S - E EN' - G PC BY: ❑ S VE BERG, ESQUIRE ❑ M. Y FREEDMAN, ESQUIRE • JACQUELINE F. McNALLY, ESQUIRE • LESLIE J. RASE, ESQUIRE f. • CHRISTINA C. VIOLA, ESQUIRIi • ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Date: A, A VERIFICATION 1, the undersigned, an authorized representative of '/v� -G�1 Ci 1 r- FcU- am authorized to make this verification on behalf of Plaintiff and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do not believe to be true or which I know to be false. Date: 7 / �J / Z ame: D 'S Title: �� ...:.... :. LOAN l MOOS APraL 1I, 2012 Camp Rill, PRBT±91tLVABTA ]Data] ICityl [state]. 156 HaLlonbaugh lined; Cerijale, t? ?c 170L5 [Propertp Addrese] 1. BORROWER'S PROMISETO PAY In return fora loan that i hnve mcalved, I promise tD pay U.S. $156, 000.00 (Itrls amount �s caffod "Principe-), plus interest, tottro order of the Lender. The Lender is MM11 10101CR MWRPAt. CREM WIGN, A MRRAL Casnax MOa. I will make all payment: under this Note in the form of cash, check or money order. I understand that the lender maytransfer this Note. - rho lender oranyone who takes this Note by +Yansferand vhto Is entitled to receive payments under this (dote Is called the 'Note Holder." 2. INTEREST Interest will be cherged on unpaid principal until the tuff amount of Princlpal has been paid, I will pay inle est at a yearly rate of 4.500%. The interest rate required by this Section 2 is th rate IvAltpayboth before and afterany defaultdescnbed in Sectim 8(B) of this Note._ 3. PAYMENTS (A) Time and Place of fayments i wgi pay principal and Interest by making a payment every month. I vnli make my monthly payment on the 162? day of each month beginning on dtm& 1, 2012. 1 will make these payments every month until f have paid allofthe principal and interest and any other charges dmosrbed below that I may cure under this Notes. Each monthly payment wig be applied as of its scheduled due data and vhH be applied to Interest before Principal. if, on tdA% 1, 2o42, I stilt owe amounts under this Note, I will pay those amounts in full on that date, which is caged the "Maturity Date.- i will make my monthly payments at 2175 BUNUX Bt.H SOLUM Ro MRCR"xCSSARG, Hill 17055 or at a dWerent place It required by the Note Holder. (B) Amount of IYlorrfhiy Payments My monthly payment will be in the amount of U.S. $790.43. C BORROWER'S RiGHT'rO PREPAY I have Me right to make payments of Principal stany time before they are due. A payment of Principal only Is known as a "Prepayment'When 1 make 4Prepaymant, twig teilthe Note Holder inwriting thatl am doing go. i maynotderig"Wa, a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holderw4l use my Prepayments toroduce the amount of Principal thatl owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on die Prepayment amount, bafore applying my Prepayment to reduce the Principal amount of the Note: if I make a partial Prepayment, there will be no changes In the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 6. LOAN CHARGES It a law, which applies to this loan and which sets mafdmum loan eharges, Is finally interpreted so that the intorest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then; (a) any such loan charge shall be reduced by the amount necessary to teduoe the charge to the permitted limo pnd�ptty taitlAus —) ( T MuLnSTATEFe%D RATE WES'm96FwrEfpfenn4s MasOraddle Mao UNIFORM WITIUMEITr Fcrtnslea 191 Cf 10H9,20070n8neDocvmwdc� Me Paso 1 of S FSMMT 0701 EX !BIT` song sutra^ already collected from me which eXcepdad permitted Iirnits MR be refunded to me.. The Note Dottier spaN in make this, refund by seduring the Principal I owe under this Note 'o r by making a direct payment b me, If a refund . reduces Prnedpel, the reduction will he treated as a paiiiai Prepayment. G. BORRCsYv'ER'S FA.ILURE'TO PA AS RROUIRED (A) Late Chorge tar Overdue, Paymenta ff the Note Bolder ties not reoehrsd the full amount cf any rnot.i hty payment by the end of is calendar days after the deter it is due, I tvifi pay a, late charge to the Note bolder. 'The amount of tine charge win be 5 of my overdare payment of prinolpAi end lnterest. I vrlllpay this late charge promptly butontyonce on each late payment. (U) xDafoult 111 do not pay the full amount of each rrianthty payment ore the data It Is due, i writ tae h defeaeit.. (C) Noldca of Datoutt if i am in dafmilt, Ilia Note Helder may send me a sa itten trot"' a letting me that if I do riot pay the nverdurr atncurtt by acarialn date, (he Natet-folder malt requips mgl pay I mma di 7m t e i y , the lu'll amowlt cif ptirebal which has not beer paid and ell the Interest that t owe on tPaatemourat. Thatdate Awstba atiecstsb days after tine data onwrnluh file ootk-� is mailed to me or delivered by other mean4. (D) No Waiver By Mote Holder Even f, ate rinse where I sm in default, the Note Holderdaea notrequi €erne to pay fats r diatey In lull as described above, the Note Holderwfll still halve the right to do so it t am in default at a later lima. (E) Payment of mote Folder`a Costs and Expanses "the Note Holder has required me to paginimediately in fuilas described above, the Motu Holderwill havathe right to be paid track by me for all of its costs end ext crease in aeztrv. aang this Nola to the extortl riot prohibited by applicable law. r"hose expen.es Include, for example, reasonabfe aKemeys' fees. T. GIVING OP N ®TIDES Unless apprraabfe taw requires a different mathod, any notice that murthe given tome under this Note 10 bo given by delivering it or by mailing it by first class mall tome at the Property Address Above or eta different address it I idivo the Note Holder a notice of my different - address. Any notice lhat must be given to the Nota Molder underthis Note will be given by deiivodng it orby maWriq it byf l; class mail to the Mate Holder at the address stated in Sstlian S(+) nbova or at a diftr:rent address ill am given a notice of that different address. 8. OSLIWIONS OF PERSONS UNDER THIS 140TE if more than ona person signs thts Note, each person is fruity and personally obligated to keep nit of Me promises made to this Note, Including thepromisetopaylba uifamountowed. Anypersanwholsagumntor ,suraiyorendorser afthis Note is also obligated to do these things. Any personwho takes over these obligations, Inciuding the oblgations of a guarantor, surety arendorser of this Note, is also oMgetad to keep all of tba promises made in this Nola. The NDte Holder may enforce its rights under this Nato against each person Individually or against all of us together. this means that any one of us may be regilirrd to pay all of the amounts oared under this Note. 9. WAIVERS I and any other person who has obilgations under Us Mote waive the rights of Presentment and Notice of Dishonor. 'Presentment' means the right to require the Note Holder to demand payment otarnounts due. 'Notice of Dishonor" means the right to require the Note Holderto give notice to other persons that amounts dud have not been paid. 10. UNIFORM SECURED NOTE This Now is a uniform instnament%A(M limited variations in soma jurisdictions. in addition to the protections given to the Nota Holder under this Note, a tilortgage, Deed ofTrust, or Security Deed (the 'Security Instrument), dated the same date as this Note, protects the Nate Halderfrom posslbie iosses which mightra=ltiff eta 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 irnmedlate payment in fall of all amounts f oboe under this Note. Same of those conditions are described as follows: If all or any part of the Property many Interest In the Properly is sold or transfarred (wit Borrawor is not a natural person and a beneficial inteirestin Borrower is sold ortransfetted) without Lender's priorwritten can-sent, Lander may require Immediate, payment in full at all sums secured by this Securri y Insin:ment. However, this option shall not be exercised by tender it such exercise is prohibited by Applicable. Lam H gander exorcises this option, Lander shall give Borrower notice of amateration. The notice shall provide a period atnot less then 30 days from the date the notice is given in accordance vlilh Section 1 S within wht tmmttfe7ar __ MUIZtgTATE FIXES ritlTE MOLE -Singh Femly.Frtnnto Meat[°taddta tylae uWtF4Rbt iM5'FEtttREiJF Form S3aa Ylof W 106b -ara7 gnfinafraamraiu�. free. Page 2 of 3 F42"OT arm aaxs #c = go=T+swerM stpeyallsums hy this S- Wityi:a,t-, rfa3srr(wGrfa* expirafw. of ihis prood, Lortdermay invoke any rermr ies permMed E+ytkdS Sncaertty icistnrr +erats eu�ativr�ler natim or demand or, 1r5gTNESS'1HP HAND(S) AND OF iJE tlN006IGNEB. / t Tarp L Hvi`s3r [Sign original onsyl FSUL nSTATE FBrEA RATE NOTE_%,, FomilYFarmfo MaWmddts Mae UMFORM INS - MUMEV foe 326010 F�pp?iOT Pfo= $ 1899 ZOQT ©nf�e Bacurt+atrta, ltte Page 3 of 3 STEPntll19 PRXNCR U 5$ YZD x� Exa r Ro �c;� 1 tai n HECHASMSBURG, PA I M 717 -591 -1276 Ater Pocarding Return Tog _ aJWIRICAO 79E RAL CREDIT UNZO>t Co re SetHe ment 5erAces atTxs xx A5 3800 Malt Street 2175 tio? hr RV Camp. HiA, PA, 17011 G C _ atrx F A 1.7055 "N 12 4a- 23-05SS- 004 i (SpAC4AbOV97h9 *LIrtForrimo?dinagData) LOAN MORTGAGE DEFINIVONS Words used in multiple sectlons of this document are defined below and otter wards are defined in Sections 3, 11, 13, 18, 20 and 2i, Certain rules raasrdincg the usage of words used in this document are also provided in Section 16. (A) 'Security tnstr'ument" mearg this document, which is dated ALPRx1a 12., 2012, together with all Riders to this document, (8) "Borrower' is TERRY L RARNZIR AND TRACT A, RAM R, RUSBAAN1t AND tXFEa = Borrower is the mortgagor cruder this Security Instrument. (C) "Lander" Is AmKRzCxpZCE FEDERAL cREDiT [rHZam. Lender is a FEDERAL CM IT € NION organized and existing under the �.. laws of PRIMsyLVAniA. Lender's address Is 21.7'5 SUMBL1'g BEE HOLLOW RD, MECHA.LICSBURG, PA 17055. —� Lender Is the mortgagee under this Security Instrument, r� Ynitia3.s _ PENNSYLVAN[A -ftgla Farmly-Fannta MavjFtaddia Floe UNIFORM INSTRUMENT Formatter 4101 a IM-20070dmeDoe�C�l�11 A e I Of 14 PASSrS81f 0 PAUQEOL OM �County at GUMSMAND � � (Robert P ZfegliK RecordK da CerWtttatthetragaIrrg 4 tax tWva as appe" in C 0.410312013 It :04 AM CUMBERLAND COUNW rust.# 201210786 - Page'T Lon 0 Y m (D) "h4oW ineans the promissory note s�gned by Borrower and dated APRIL t 1 f 20 M - fneNotestates 'inatBorrowerawsLender skt,�sat** *A; ***** WrCENAfRED FIFTY SIX TrfOi SMW AnD GiO1100 ear. �rarana• a�: �s�, to-�rtk- �tttatt ,�,�;e.+�ntt�etms�t4r�•�trt� 6:3ollar� 4�,�. ����5 Q34��a�t€ � - - plus Interest, Borrower hr s promised to pay this debt in regular Periodic Payrnents end to pay the debt in Roll not later than MAY 1, 2042 (E} 'Propergr' rite -ans the property that is described below underthe heads"trg "a'ranste(of Rights in the Property.' (F) "Lean" means this debt 4nAdenced by the Note, plus interest, any prepayment :charges end late - changes dire under the mote, and all Burns due under fols Securi y Instrurneml, phis interest. — (G) "Riders means snit Alders to tiers SecUdly Itrstrtament that are executed lay Borrower, `t'he following Riders are to be executed Isy Borrower [check box as appliEcabte); =Adjustable Rate Rider LDConclominium Rider =Second Home i° der Balloon bider =Piarined Unit De eloprosnt Rider i= -IQ :her(z) sspacifrj 1-4 Fancily Rider i l B iweekly Payment Bider =V.A. Rider "i (H) "Applicable Lv.W' means all aontxollirrcg applicable federal, state and' ias;al statutes. regulations., _ ordinances and admintstrativa rules and orders (that have the offeat of law) as well as all applicable final, non -appealable judicial opinions. (1) 'Comraunity Association Dues, Fees, and Assessments" means all Blues, fees, assessments - - and oth c harges that are imposed on Borrower or the Property by Fa condominium association, homeowners association or similar organization. (d) " Eieizi - mrileFsar dsTrarrsfet"meansanytr.wsferoff ands, otherthanatransaciionotfg hated bycheck, draft, or similar paper Instrument, which is initiated through an electronic teminal, felopbonic Instrument, computer, or rmrgnalrctape so as to order, instruct, or authorise a financial irasftrtiun to debit ur credit an account Such terms Iticludes, but is not limited to, poIntof-sale transfers, automated teller machine tran sadons, transfers initiated by telephone, wire transfers, and auto€nated :iea"ir ghouse transfers, (K) " Escrow ltltma' means those items that are described in Section S.. (I-) "Miscmltaneous Preceada"meansanycompansadon, settlement, award ofda.rnagms , orproceads paid by any third party (otherthasn insurance proceeds pald under the coverages described in Section - 5) for: (i) damage to, or destniction of, the Property; pi) condemnation or other taking of all or any part Of the Property; (19) conveyance in lieu of condemnation; or (lv) misrepresentations of, or ornissions as to, the value andJor condition of the Property. (fd)"Mortgage Insurance" means insurance protecting tender againstthe nonpayrnentof, or default on, the Loam. (N) ``Porlodic Paymenr meana the regulwly scheduled am ount due for(!) principal and interest u nder the Note, plus (it) any amounts under Section a of this Security instrument (0) " RESPA" meanstheReatFatateSetdomentProceduresAct( 12U. S. C. §260ietseq.)and?�simplernendng regulation, Regulation X (240.F.R. Patt3500 ) s astheysnight be arrtendetd front tune to time, cranyedditional orsuccessor leglslationorregulation thatgovemsthesome subjectmatter. As usedinthLsSeeurity lnstrurnent, 'RESPA" refers to all requirements and restrictions that are imposed in regard to a "laderaily related -. mortgage loan° even if the Loan does not qualify as a "foderaliy related mortgage tract" under RESPA. (P) "Successor In Intareat of Borrower means any party that has takers fide to the Property, whether or not that party has assumed Borrower's obligations sander the Note andjor tb6 Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY Th is Security instrument setxtres to Lander. (tl the repayment of the Loan, and all renewals, extensions and - modifications of the Note, and (I) the performance of Borrower's covenants and agreements under this Security Instrunient and the Mote. Forthis purpose, Borrower doses hereby mortgage gr- nvey Zsritial at PENt,ISYt VAN A•-S nIa Fumlly— Footle MaetfraddlQ Mar UMFORM IPfsLRtJA�iENT Form 3039 lto �. 0 19994007 Online porumanta, Inc. Page 2 of 14 PAUDEDL o7o3 ■ 0 11;29;04 AM CUMBERLAND COUNTY Inst.# 201210788 - Page_2 , Lender tie fol wing described ro EcG.s � d I� party Ic?cata� in #tie C4LrPa" IType d Rewdtng Jurlad€cilani of Cunh arland IN amp d Fitxwd4ig J k&i7onl, SZE z GAZ. DESCRIPTZ01 MITACM TiibRE t) MO MADIZ A PART arRSOXF 4S EX51ZIT - ,r€PR r�g�.;c3Wc1fiR�Q1� which currently has the addrosm of 154 Eiclien augh Road, ca'rliole, s.. .— Pennsy 17015 [SSrseSi tDR}°i ( Address TO(GETi-fER WITH al the improvement, now or hereafter erected on the property, and all easements, appurtanarrcas, and f )du es now or hereafter a part of the property. All replacements and { additions shall also be covered by this Security instrument, All of the foregoing is referred to in Phis Security Instrument as the "Property.' BORROWER COVENANTS that Borrower is lawfully selsed of the estate hereby conveyed and has the rightto mortgage, grant and convey the Property and thatthe Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generallythe title to the Property against ail olaims and demands, subject to any encumbrances of record, THIS SECURITY IMSTRUMEW combines uniform, covenants for national use and neon - uri form covenants with limiters variations by jurisdiction to constitute a uniform secur€ityinstrument covering real property. UNIFORM COVENANTS, Sarmwer acid mender covenant and agree es follows - 1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charge,& Borrower shalt pay when hen due the principal of, and interest on, the debt evidenced by the Note_ and any w. Prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow items pursuant to Section S. Payments due underthe Rote and thus Security Instrument shall be made in U.S. currency. However, rf any check or other instrument receivers by Lender as payment under the Mote or this Security Instrument is returned to Lender unpaid, Lender may require that any or all - subsequent payments due under the Mote and this Security instrument be anode in one or more of the following forms, as selec by tender. (a) cash; (b) money order; (c) cerg check, bunk check, treasurees check or cashier's check, provided any such check is drawn upon an instigation whose deposits are Insured by a federal agency, Instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lenderwhen received at the local €on designated in the Mote or J ' at such other location as may be designated by Lender in accordance vAth the notice provisions in — Section 15. Lender may return any Payment or partial payment if the payment or partial payments are _ I to bring the Loan current, Lender may accept sny payment or partial payment insufficient --- to bring the Loan current, with% €twaiver of any rights hereu nder or prejudice to Its rights to refuse such payment or partial payments In the future, but Lender is not obligated to apply such payments at the - time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay Interest on unappiied funds. Lender may hold such unappRed funds until Borrower makes payment to Paring the Loan current, if Borrower does not do m within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not I aril Xnitial1 } PENNSYLVANIA s€ngta Farn€T r- fanvlo Nz1w1Fradd€%idea UNIFORM iNSTRUMENT Foam 3Cs t 0 iwD -2007 Onlineticsc:ernents, €rre Pale 3 of 14 FAUDEDL 0799 - _ R 0 V012013 11:29:04 AM CUMSERCAND COUNTY €nsr # 201210766 - r d such funds will be applied to f-a outstanding principal balance under the Note Immediately prior to _ foreclosure. No ofrset or claim which Borrower might hwve now or in the Axtures against Leveler shale relieve Borrower from making payments due underbho Note and this Security instrument or performing the co aei ants and agreerrlents secured by this Security Instrument. 2. Appllostion of Paymenle or ProcaGda, l xr'Apt as otherwise described in this Section 2 , ali payrnenis accepted and applied by L iderstiali be applied In the following carder of priodw, (a) interest dues under the Nato; (b) poineipai due underthe Rate, (>;) amounts due underS eciion3. Sum payrrrents _ shall be applied to each Pisfiodic Payment in he order In which, It became glue. Any remaining amounts shall be applied first to late charges, second to any other amounts dtae urAsr this Security Instrument, and them to reduce he principal balance of the Pate, If bender recelvos a payment from Borrower 1br a delinquent Periodic Rayment whirls inclatdee a sufficient amount to pay any late charge due, the payrn ant may be applied to the delinquent payment acid - the iat charge. llm ano Periodic Paymentis outtaaidirtg, Lerreler bray apply any payroor)t rear eked -. from Barron 4 er� to idle ml}a'� ent of lbe ! imio is Paymeri it, and to the extent that, each p/ayment roan be ?3' paid in full. To the extent that any excess exist aftj the payment is applied to e foil payment of one or more PeriadIcPayments, such excess may to s applied to any late chargesdue. Voluntaripmpayments shall be applied first to any prepayment charges and titers as described fit the Note. Any application of payments, insurance proceeds, or M�scrrllaneous Proceeds to principal due under the Note shall not extond or postpone the due date, or change the amr uq of the pedorfk, yments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Ps ri"t Payrnents are clue under the Mote, untilthe Mote is pairs in lull, a Guns (the'I'unds) to provide for payrnent of amounts dao for; (a) taxes and assessments and other items which can attain pdority over this Security instrument as a Hen or encumbrance on the Property; (b) leasehold payments orground rents on the Property, if any', (c) premiums for any and all Insurance required any Lender under Section 5; and (d) mortgage Insurance premiums, i* arty, or any sums payable by Borrower to Lander In lieu of the payment of Mortgage insurance premiums in accordance witty the provisions ref Section JO. `Riess items are called 'Escrow Items." At origination or at any time during title terra of the Loan, Lender may require that Community Association Flues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. BonDwrer shall promptly famish to Lender all notices of amounts to be paid under this Section. Borrover sh rill pay Lender the Pundsfor Escrow Recess unless Lsnderwalves Borrowees obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any tine. Any such _ waiver may only be in writing. in the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow {terns forw hich payment of Funds has been waived by Lender and, 9 Lender m quires, shag furnish to Lender receipts evidencing such payment within such time period as lender may require, Borrower's obligation to make such payments and to provide receipts shall for all purposes bedeemed to be a covenant and agreement contained in this Security lnstrurnent, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuanttoswalver, and Borrowerfallsto paythe amountdueforzan Escrowltern, Lender = may exercise Its rights under Section 9 and pay such amount and Borrower shall then be obligated underSection 9 to repay to Lenderanysuch amount. Inc :ndermayrevokethewaiverastoany oral Escrow items atanylirnabya noticegiven inaccordencewifh Section IS arid, upon such revocation, Borrower &hall -- pay to Lender all Funds, and In such amounts, that are then required under this Section 3. ' Lender way, at any time, collectand hold Funds in an amount (a) sufficlentto permit Gender to apply the Funds attire first® specified under RESPA, and (b) not to exceed the maximum amount a tender c require under AESPA. Lender shall e- dimats the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law, The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits a red) or _ �rcit:a.a PF.NNS'YLVAN1A- - Famdy-FArinto Mae/FreMo FA no UNIFORM INSYRUFi FEET FbrM3 39 ! 0 1999 -2007 Onilne Documanta, Ine- Page d of 14 PAUDEDL 0703 m � &0312013 1129:64 AM CUMBERLAND COUKIY MttA2012107B6 - P$g. "'. _` in any Federal Home Loan Bank. Lender shall apply the Fund-, to pay the Escrow Items no ati`er i tars the time specified under RESPA. Lendershall not charge Borrovvet of holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Eforriawer interest on the Funds and Applicable Laws permits Lender to rriake such a charge. Unless are agreoment is made in writing or Applicable Law requires Interest to be pain an the Funds, Lands. r shall not be rewired to Fay Borrower a.ny interest or earnings on the Fonds. Borrower and Lender de;r can agree in writing, however, that interest shall be paid on the. Funds. ? endershall give to Borrower, w0ifivtcharge, are annual accounting of the Funds as required by .PESPA. lftherelsasu€ plusafFuni; k, heidinescrow, asdefinedunderRF _SPA,LandershallfwmounttoBorrower _ #or ibe excess funds in amordanm R ; RESP.A. If there -i is a shortage of Funds hsId in escroiv, as dermed , under RESPA, I Bade• shall notify Soirower as required by RESPA, and harrower shall pay tr Lenderthe amount necersary to makeup the shortage in aroordznca with RESPA, butin no more than 12 monthly payments. if there is a deficiency of Fonds held 41 esclwv, as defined tinder RESPA, Lender shall notify Borrower es required by RESFIA, and Borrower small pay to Leader the amount neoessary to make up the deficiency In accordanoewiith RESPA, but in no more than i2 monthly payments. -- Upon payment k1€uli of all saris secured bythis Security Instrument Landlershall promptly refund to Borrower any Funds held by Lender. 4. Charges; ions. Borrower shall pay all taxes, assessment$, charges, fines, and Irnposivoils - attributable to the Property which can attssin priority raverthis Security Instrument, feasehold payments- or ground rents on the Property, If arty, and Community Association flues, Fees, and Assessments, f any, To the extent that these items are Escrow Items, Borrower shall pay them In the manner pro - sided in Section 3. Borrower shalt promptly discharge any lion whi: lh has priority over this Sac€trjty Instrument unless Borrower. (a) agrees in uniting to the payment of the obligation secured by the lien in a manner acceptable to Lender, butonly so long as Borrower is perform ing such agreert°.en% (b) contests the lien in goad faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement M the lien wtaife those iarOcGodings are pending, but only until such proceedings are concluded; or (c} secures from the holder caf the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument, If Lender determines that any partofthePropertyissubjecttoalio nwhichcanattainpriorityoverthisSecurityinstrume tt,Lendermay give Borrower a notice identifying the lien. Within 10 days of the aisle on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section R. Lender may require Borrower to pay a one -tune charge for a real estate tax verification nand /or reporting service used by Lender in connection with this Loan. 3. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected an the Propertyinsured against loss byfisre, hazards inducted within tbB term extended coverage," and any other hazards Including, but not limited to, earthquakes and floods, for vihich Lander requires insurance. This insurance shall be maintained in the amounts (including deducti levels) and for the periods that tender requires. What Lender requires pursuant to the preceding sentence: can change during the term ofthe Loan. The insurance carrier providing the insurance shall be chosen by Sorrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unroasonably. Lender may require Borrower to pay, in connection with this Loan, either. (a) a one -time charge for ttood zone determination, certification and tracking services, or (b) a orie -time charge for flood zone determination and certtficatfon services and subsequent charges each time romappings or similarchanges occurwhich reasonably might affectsuch determination or certification. Borrowershalt also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency In connection with the review of any flood zone determination resulting from an objection by Borrower. It Borrowerfails to maintain any of the coverages described above, Lender may obtain insurance coverage, atLender`s option and Borrower's expense. Lender Is under no obligati n to initial PENNSYLVANIA- Single Family- Fannia mAemreddlo Mac UNIFORM INSTRUMEW FPr(n 3W9 ! A 1M.2007 flhHna DOMM MS. tna Fags s of !k pAUDEDL 070a ]EI0312013 11;28:04 AM CUMBERLAN'O COUNTS' 201210716 -'P `„ p a; ticuiartype�o €amount.ofcovarage. tl era�fore,suc4 coverage c�veriandQ€,btatr<tilgA "ght s not protect Bormwer, Borrower's equity In the Property, or the contents of the Property, against any risk, hazard or liability arid ought provide greats -ar or lesser coverage than Was prevloUsly in sffect, Borrower acknowledges that the cost of the insurance coverage so obtair+ed rn $ght; significanti!{ - exceed the cast of insurance that Borrower csnafd have obtafned. y',rcy amounts disbursed h }FLender under this Secticart 5 shall become additional debt of Borrower secured by this Security Instrument. - These amounts shall bear interest atthe Note ratefr the date of dis bursament and shall be payable, until such interest, upon notice from tender to F.3orrower requesting payment. Ali Insurance policies required lay Lander and renevaals of such iaokies s hall bs subject to Lenders right to disapprove such policies, shall include a standard mortgage: clause, and shall nacres Lon dw as mortgagee and /or as ar, additional icss payee. Lender shall have the €itdht to hold the policies and =. renewal certifcates. If Lander requires, Borrower shall promptly give to Lender all receipts of paid pi- omiums and renewal notices, It Borrower obtains any form of insurance coverage, -tot othervaisc - required by Lender, for damage to, or destruction of, the Property, such policy shall Include €r stan;dar'el mortgage clause and shall name lender as mortgagee and /or as an additional loss payee, in the event ofloss, Sonwer shall give prompt notice to the insurance camor and tAnder. Lendermay rroake proof of loss P not made promptly by Bo;�cwer, sonless lender and Borrower otherwise agree in uniting, any insurance proceeds, whether or w7l: tkte u:tdedying insurance was required by Lander, shall be applied is testorallon or repair of the Property, if the restoration or repeir is evono€nlc,ally t`easible and _ Lender's security Is notlessenedd. Dudnq such repair and restor•atxo €x period, lewder shalt have use rightto hold such insurance proceeds until Lender has had an opportunity to Inspect such Property to ensure the - work has been completed to lenders aaisfaetion, provided that such inspection shall be undertaken promptly. Lender may disburse prods for the repairs and restoration in a single paymentorin a series of progress payments as the work is. completed. Unless an agreement is made in writing or Applicable Law requires interestto be paid on such insurance proceeds, Leander shall not be required to pay Borrower any interest or eamingson such proceeds. Pees forpublic adirrsters, orotherthlyd parties, ratin d say Borrower• shall rot be paid outofthe insurance proceeds end shall be the soleobliigallon of Borrower. If tits r'astoraton ` or repairis not economicaltyteasible or Lender's securityvrould be lessened, the insurance proceeds shall be applied to the sums secumd bythis Security Instrurnent,whether ornotthen due,with the excess, ifany, paid to Borrower. Such insurance proceed-- shall be applied In the Larder providers for ire Section 2� if Borrower abandons the Property, Lender may file, negotiates and settle any available Insurance clairn and related matters, tf Borrower does notrespond N tin 30 days to a noticefrom Lander thatthe insurance carrier has offered to settle a claim, then Lender may negotiate and .settle the claim. The 3"ay period will begin when the notice is given. In either event, o r if Lender acquires the Property under Section 22 or otherwise, borrower hereby assigns to Lender (a) Borrower's rights to any insurance -° proceeds in an amount notto exceed the amounts unpaid under the Mote or this Security Instrument, Y: and (b) any other of Borrower's rights (other than the right to any refund .of unearned premiums paid — by Barrows* under all Insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the - Property or to pay amounts unpaid under the Mote or this Security Instrument, whether or notthen due. - S. Qcaupanr y. Borrower shall occupy, establish, and use, the Property as Borrower's principal residence within 60 days after the execution of this Security instrument and shall continue to occupy the Property as Borrower's principal residence for at least ore year after the date of occupancy, sinless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Sorrower's control. 7. Iareaervradorr, Maintenance and Protection of the praperV, Inspecttom Bom3wer slaatl stet destroy, damage or Irnpairtte Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is reasiding intha Property, Borrowshail maintain the Froperty in orderto prevent the Property from deteriorating or decreasing In value due to its condition. Unless it is determined pursuant . to Seedon5thatrepairorrestnrationisneteconomicaliyfeasb le.BorrowershaHprompttyrOpalr Property" w wait' -�-�- PENNSYLVANIA Family- Flitiaia MaeffirWdleMst6 UNIFWIi SNS"UMENT r-atm 3tr35 0 1999.2M7 Who DaeurTs�3 me Page Ea of � 4 P D L 0709 _g]!Q�ii2013 11:29:04 AM CUMBERLAND COUNTY ins X 201210786 LOA39 � s i; damag€d o avokt #ur#1er dets i at€ot? or damage. If Insurance or condemnation proceeds are paid ire connection with damage to, or the taking ref, the property, Borrower sheen be responsible for repairing or restoring the Property only if !,.ender has released proceeds for such purposes. Lender may disburse proceed sfor the repairs and restoration in asingle payrnentor in a series of progress payments w Me wmrl� `= is comnlsted. lithe Insurance orcondemnation proceeds amnotsuff nttorepairorrestoretheProper4;, Borrower 6-, not relievDd of Borrowees obligation for the completion of such mpaiir or restoration. Lender or its agent may make reasonable entries capon and inspections of the Property, it it has reasonable caeuga, Lendermay inspect the interior of the; improvernents gn the PropeAy. Under.shali --- give borrower notice at the time of or prior to such. an interior inspection specifying such reasonable cause. S. Borromfees loan Applicntton, Sot-rower shag be in default it, during the Loan, application - process, Borrower or any persons or entifi+as acting at the director of Sorrowar or Milk Borrower' knowledge or consent gave materially false, mislead €ng, or inaccurate Information or statements to �.. Lender (or failed to provide Lender with material Information) in c3nnwti€er with the Loa Material rep resent-ations Include, but are notifraked to, representations. concen; ingBorrower Property as Borrowers principal residence. 9. Protoctlon of Lender's Interest in the Property and Rights Undarthis Security Instrurreent If (,a) Bvrrowerfaiis topedorm thecovenartO ar4dagreements:c:nt wined in this Security Insttiatnent,(b) there is a legal proceeding 'Mat might significantly affect Landees interest in the Property and /or rights - under this Security instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a fiery which may attain priorRy ovaar this Security Instrument or to enforce laws or regulations), or (c1 Borrower has € bandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Propettty.and rights under this Security Instrument, including protecting and/or assessing the value of the Property, and securing and /or repairing the Property. Lender's actions can include, but are not limited to: (a) paying any sums - secured by a Iten which has priority over this Security ItTshumont; (b) appearing in court, and (e) paying reasonable attorneys' fees to protect its interest in the Property and /or rights under this Security Instrum Including its secured position in a bankruptcy proceeding. Securing the Property includes, = butis notlimited to, entering the Ptopertyto malee repairs change locks, replaceorboard up doors and f windows, drain wator front pipes, eliminate building or other code teaolafior2s or dangerous conditions, and have utilities turned on or off. At Lender may take action under this Section 9, Lender drams not have to do so and is not under any duty or obligation to do so. It is agreed that tender incurs no liability for not taking any or alt actions authorized tinder this Section 9. Any amounts disbursed by Lender render this Section 9 shall become additional debt of Borrower LZ secured by this Security Instrument These amounts shall bear interest at the Note ratan from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment, N this Security instrument is on a leasehold, Borrower shall comply With all the provisions of the lease. Borrower shall not surrender the leasehold estate and interests herein conveyed or terminate or cancel_ the ground lease. Borrower shall not, without the express vaitten consent of Lender, after or amend the ground lease. It Borrower zcqu+ras tae title to the Prapart'f, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Mortgage Insurance. If Lender required Mortgage insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain the Mortgage insuranceirtefiect If,lora�ty reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage Insurer that previously provided such insurance and Borrower was required to snake separately designated payments toward the premiums for Mortgage insurance, Borrower shall pay tile premiums - required to obtain coverage substantially equivalent to the mortgage Insurance priwfously In effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by lender. If substantially equivalent fVfortgacte Irisuranc _• Znita PENiNsYLVANIA— :+Ingle Famry— F'atvalo Mao/FroMle Mite UNIFORM INST UMEW Form awe +t 01MP2o07 Online Dacaamenta,IM Page 7 of 14 PA EDL 0709 t s, 01/0312013 11:29:04 AM CUMBERLAND COUNTY inst.# 201210786 - F14 a - t LOAN 4y. coverage is not avallabte, Borrower shall ron*rue to flay to Lender the amount of the separately designated payments that were due when the insurance coveraga ceased to tie in effect, Lander twill . accept, use and retain these payment -, as a rion- refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non -r fundable, notwithstanding the fact thaMe gran i, ultimately paid In full, and Lender shall not be required to pay Borrower any interest or earnings on such loss resents. ` - Lender ,:�an no longer require toss reserve payments if Mc tgage Insura coverage (fn thaamount anrf w for the period that Lender requires) provided byan Insurer selected by Lenderagain her ornesavaliabte, _. is obtained, and Lander requires separately designated Payments, ttfward true premiums for Mortgage lnsurancao ff Landerrequired Mortgage Insurance as aaondit on of making the Loan and Sorrowerwas required to make separately designated payrrsent-- toward ihp premium.; for Mortgage insurance3, Borrower shall fray the premiums required to maintain Mortgage Insurance In affect, cu to provide 2, non - refundable lass reserve, until Lender's requirement for Mortgage Insurance ends In accordance with any written agreement betcuw Borrower and Lender providing fee, such ter Inawn or until termination is required by Appllcable Law.40hing in thiis Section 10 affects Borrower's obligwttrin to pray Interest at the rate provided In the Mote, Mortgage Insurance reirnburses Lender (ter any entity thatpurchazes the Note) forcerta n losses itrnay incur if Borrower sides not repay the hues as agreed, Borrower is not a, party to tl ,je Mortgage InsctrancP Mort insurers evaluate theirtotal re`s& on all such insurance in force from tune to time, and may enter into agreements vrith other parties that share or modify their risk, or reduce losses, These -- agreements aria on terns and conditions thatare satWactory to the mortgage insurer and the otherparty (or parties) to these agreements. These agreements may require the mortgage insurer to make payments using any source offunds that the mortgage insurer may have available (which may Include funds obtained from Mortgage Insurance premiums). As a result of these agreements, Lender, any purchaserof the Note, another Insurer, any reinsurer, any other entity, orany affiliate of any of the foregoing, may se :elve (direetty or indirectly) amounts that derive from (or aright be characterized as) a portion of Borrower's payments for Mortgage Insurance, . In exchange for sharing or modifying the mortgage insurer's risk, or reduclr:g losses. If such agreement provides that an of illato of Lender takes a share of the insurer's risk in exchange for a share of the premlurrs paid to the insurer, the arrangement is often termed 'captive s atnsuran ,' Further: (a) Any such agreements wilt not affect the amounts that Borrower has agreed to pay for Mortgage insurance, orany other tesms. of the Loan. Such agreements will riot lacrease ttre amount -- Borrower wilt owe for Mortgage Insurance, and they will not entitle Borrower to any refund, (4) Any such agreements w ill not affect the rights B orrower has - If any - with respect to the Mor€gtagca Insurance underthe Homsownars Protection Act of 1636 or any otherlaw. These rights may Include the right to receive cartalrr disclosures, to request and obtain cancellation of the Mortgage insuranco, to have the Mortgage Insurance terminated automatically, acrdfortoreceive a refundofanyMortgage Inasraneeprerrdumathatwere unerarnedatthetime cf such cancellation or tannination, 11. Assignmerd of Miscellaneous Procoedw, f=orfeiture. All Miscellaneous Proceeds are hereby assigned to and shell be paid to Lender, It the Property Is damaged, such Miscefianeous Proceeds shall be applied to restoration or repair of the Properly, If the restoration or repeiris economicaltyferasibla and Lender's securityls riotfessenede During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to eiisure the work has beers completedto Lender's satisfaction, provided thatsuch inspection shalt be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursarnent or in a series of progress payments as the worts Is completed, unless an agreement is tirade in writing or Applicable taw requires Interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not econoui callyfeasibfe or Lender's securitywould belessened, the Miscellaneous Proceeds shallbe applied su secure initials ,_ P& FrHSYLVx�itR- 5[ rrgtsFstnNy- �ar�P�e& t��rndd[ et�tecttNIF47RhtIPtaTt3uttiirnl� 'C �arm34z3e �t 0199o- 20orOntinovmursrerris,tnf-- Page a of 14 rntwEDL Bros 01/0312013 51:29:04 AM OWBERLANO COUNTY tnstX 201210786 .. LO AM a —" by this Security instrument, whether or not then due,. with the excess, it any, paid to Borrow rOu, - . Miscellaneous Proceeds shark be applied in the carder provided for in Section 2, in the event ofatotaltaking, destruction, ur ioss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secrsred by this Security instrument, whether or not then due, with the excess, R any, paid to Borrower. — , in the event of a partial taking, destruction or loss Irs value of the Property In which ti're fair mu, ket value of the Property Immediately before the partial taking, destruction, or loss in valve is equal to or greater than the amount of the sums secu red by ti`sls Security Instrument irarrtedlately before the partial taking, destruction, or lass in value, unless Borrower and Lender utherwtse agree in writing, the sums secured by this Security Instrument shall he reduced by the amount of the Miscabneous Proceeds multiplied by the following fmcdon: (a) the total amount of the surfs secured il Imedistc �y befor"O the partial taking, destruction, orlossirr valise divided by (b) thefairma.rkotvalue of the Property inrrriedlutai�r before the partial ticking, destructiun, or loss In vaiue, Any balance shall be paid. to Bcarcwer. In the event of a partial [aiding, destruction, or loss in value of the Property In which the fair market value of the Property immediately before the partial taking, destruction, or foss in vague is less than the amount ofIto Burns ;secured immardiately before the partial taking, destruction, orloss in value, unless Borrower and Lender otherwise agree in wrltinq, the Miscellaneous Proceeds shall be applied to the sufs secured by this Security Instrument whether or not the sums are theta due. lfthe Properlyls abandoned 1 my Drawer, or if, aifernotica day Lenderio SormwerthattheOpposinri Party (as definer) in the next sentence) otters to make an award to settie aclaim fordanmages, Borrower -. falls to respond to Lender witktin 30 days after the date the notice is given, Lender Is authadzed to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the su= secured by this Security Instrument, whether or trot t ten due. " OPPOsingr PaW means the third party that owes Borrower Miscellaneous Proceeds or the party against whore Borrower has a: right of action f _ In regard to Miscellaneous Proceeds. F . Borrower shall be in default iI any action or proceeding, whether civil or criminal, is begun that, in _. Lender's judgment could result in forfelture of the Property or otter materded iimpairment of Lendet s p Interest in the Property or rights tinder this Security lnstrumeriL Borrower can cure such a default acrd if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding — to be dismissed with a ruling that, In Lender's [udgrment, precludes forfeiture of the Properly or other material Impairment of Lender's interest In the Property or rights under We Security Instrument The - proceeds of atvyawat'a or claim for damages that are attributable to the impairment of t ander's interest IF in the Property are hereby assigned and shall be paid to reader. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied In the order provided for in Section 2. 11 Borrower Not »oiaased; Forbearance By Fender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower cr any Successor in interest of Borrower shall not eperata to release the liability of Borrower or any Successors In interest of Borrower. Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to refuse to extend nine for payment or otherwise modityarnortlzation of the sums secured by this Security Instrumentby reason of anydemand made by the original Borroweror any Successors in interest of borrower. Any forbearance by Lander in exercising any right or remedy including, without limitation, Lender's acceptance of payrnentsfrorn v third persons, ei or Successors in interest of Borrower or in amounts less than the amount them due, shall not be a waiver of or preclude the exercise of any right or remedy. 13. Joint andSeveralLiablllty;Co- signers, Successorsand Assigns Bound. Borrowercovenants and agrees that Borrower's obligations and liability shall be jointand several, However, any Boroowe. who co -signs this Security Instrument but does not execute the Mote (a " co- stgner 3: (s) is co -s €fining this Security Instrument only to mortgage, grant and convey the co- slgnees interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay tit - orris se ured by A ° s PENNSYLVARA- Stngro Fam*- Fnruda MamlFreddle Mae UttlF4RM INSTRUMENT Form 30" 1(4 0 Page 9 Of 14 PAUVEt?L oaf f a s k W03/2013 t1:29:04 AM CUMBERLAND COUNTY inst.92012%7864-, this security Instrument', and (c) agrees that lender and any other Borrower can agree i ear ena, _- m rti odify, forbear or make any accommodatlons vAth regerd to the ters of this Security Instrument or ��. the Note without the co sigriers e4nsent. Subject to the provisions of Section 18, any Successor in interest of Borrow who assumes B orrower' sobligadonsunderthlsB ecurlyl nstrumentinw€ iiing, andis approved byiender , shall obtain - all of Borrvx -ar's rights aril benetrts under this Security Instrument Bmrower shall not be reteased from Borrower's obligations and liability under this Security instrument unless. Lender agrees to such reiease in writing. The calmnAnts and agreemenF^ 41 this Security Instrument shall !rind (except as provided lrrt Section 20) and benefit the successor, and assigns of !Render. 14, Loop. Charge% tender may charge Borrawarfee` for servlcas performed in connection v&h Borrower's default, for the purpose of protecting Lender's interest In tie Property and rights under this Se cunt; Instrument ,butnotlinlitedto, attorneys' fees, property inspection and valuation fees, In regard to any other fees, the absence of express lautlloe'tyr in this Security Instrument to charge a specific fee to Borrower shall not he construed asapro bitiononthecharginrgiftuchfee ,t.endermayR not charge fees that are expressly probibited by this Security Instrument or by App icable Law. lithe Loan is subject to a law which sets maximurn loan charges, and that law is finally Interpreted so that the interestorotherloan charges collected orto be collected in connection with the Loan exceed - the permitted llm its., then; (a) any such loan charge shatl be reduced bythe amount necessraryto reduce the charge to the permitted limit; and (b) any Burns already oallec fed Tom Borrower which e=-eded permitted limits will be refunded to Borrower. lender Ynay choose to make this refund by reducing the principal caved u rider the bate or by making a direct payment to Borrower. ti a refund reduces principal, the reduction vvill be treated as a partial prepayment without any prepayment charge ,,Arhether or not a prepayment charge Is provided for under the Note). Borrower's accl�ptariee of any such refund made; by directpaymeritto Borrowervitil constitute awaiverof any rightof action Borrower wAght have arising out of such overcharge. t . 15. Notices. All notices given by Borrower or Lender in ccnnecton with this Security Instrument �- must be in vAiting. Any notice to Sor a wer in connection with this Security Instrument shall be deemed to have been given to SofTower Aen madeu by first class mail qor when actuafkp delivered to BorTowe 's notice address itsentbyothermeans. Noticato arty oneldorrowershall constitutenoticetoall Borrowers unless Applicable hew expressly requires otherwise:. The notice address %!hail be the Property Address unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify tender. of Borrower's change ofaddress. Pf Lender specifies a procedure for reporting Borrower's change- of address, then Borrower shalt only report a change of address through that specified procedure. There may be only one designated notice address cinder this Security insuument at any one tirne. Any notice to Lender shad be given by delivering it or by mailing it by first class mail to Lender's addressstated herein unless Lender has designated another address by noilceto Borrower. Any notice in connection with this Security Instrument shall not be deemed to have-been given to Lender un oil actuallyreceived by under. If any notice required bythis Security Inestrumentis also required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security Instrument IS- Govaening Law, Severablifty; Rules of Consirlrctlan. This Security instrument shall be governed by federal law and the Caw Qf the jurisdiction in which the Property is located. All ricghis and - obligations contained In this Security Instrument are subject to any requirements and limitations of - Applicable law. Applicable Law might expftckiy or implicitly allow the parties to agrea by contract or it m ig hr be silent, but such silence shall net be construed as a prohibition against agreement by contract. I n the eventthat any provision or clause of this Security Instrurmentorthe Note conflicts with Applicable Law, such conflict shall not affect other provisions of this Security Instrum ent or the Mote which can be given effect without the conflicting provision. � -� As used in this Security Instrument (a) words of the masculine gender shall mean and include corresponding neuter words orwords of the feminine gender; (b) words In the sin sh an and Yraitia ular . r P ENNSYLYANFA- Sirtgla Famh-- Fk%nnIt+MAWrodcna Mic UNIFORM INSTRUA41=tW Faent 3038 A "— 0 te99- 2W7 Online Dowmwts� ire Page $0 of 14 PAUDEDL o7og p pV03l2013 1129;04 AM CUMBERLAND COUNTY insil2012107BS - Page-1 . include the plural and vice versa; and (c) the word'rnay' gives sole discretion wri pout Any obligation LOAN to take any action. e :. ' '17. Sorrower's Copy. Borrower shall be given one copy of the Note and ofthis Security instrumea 16. Transfer of the Property or a Seneflclail interest in Gorrowror4 As used in this Section 1z1 r °interest in the Property' means Any legal or foane35eiat interest In the Property, including, brat not fin cited to, those beneficial Interests transferrod in a bond for deed, contraot for need,, Instalfrnent sales contract or escrow agreement the intentofwhtch ist3` a transteroftitle by 3or 531 er at a future date tC a purC I` aser, l all or any part of ttte Property or any Interest fn tie Pro hefty is sold ear° transfwTed (or ti Burrower is not a natural person and a berrelcial interest In Sorravver is sold or transferrer without Uendea'a prforw fterx mnsw#- Lender may recraire immediate payment in full of all sums securer; by this Security Instrument, Hcswever, this opftn shall riot be emciaed by Lender if such exwcize is prohib ted try App €;cable- Law If Lender exercises this option, Lender shall hive Borrower notice of acceleration. The nolfce shall provide a period of not leas than 30 days fre<m the date the notice is git erj kr a rdepoe with sectlop 15 within which Barrr-vver'rvrust pay all sums seerolred by this Security Instrument, If Sorro werfails to pay these sums prior to the erxpiraaon of this period, Lender may invoke any rernaclies Pei mitt€ad by W's Secrlrlty instrument Without further notice or demand on Borrower. -- 19. Borrower's Right to Reinstate After .Accateratfon, If Borrower meats certain conditions, Borrower shall have the right to have enforcement of this Security Instnamentdiscordinued at any time prior to the earfiest of: (a) live days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b). such other perked as Applicable Lava might specify for the termination — of Borrower's right to relrestate; or (e) entry of a Judgment enforcing this Security Instrument. Those _ �Y conditions are that Borrower: (a) pays Lender all sums which than would be due under this S urity .— Instrument and the tote as ifnoacceleration had occurred; (b) cures any defarattof any othercomenants or agreements; (c) pays all expenses incurred in enforcing .this Security Instrument, including, but not limited to, reasonable attorneys' fries, property inspection and valuation fires, and other fees incurred for the purpose ofprotecting Lender's intemtin the Property and rights undarthis Security Instrument, _.. and (d) takes such action as Leader may reasonably require to assure that Lender's Interest in the r Property and rights under this Security Instrument, and borrower's obligation to pay the sums secur by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses in one or more Of the following forms, as sefectedbyLender (a) cash; - (b) money order; (o) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by afederai agency, instsimentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fullyetfective as if no acceleration had occurred, However, this right to reinstate shall not apply in the case of acceleration under Section 18, Zit. Satre of Nate; Change of Loan Servlcer, Notice of Grievance. The Note or a partial interest in the Note (togetherwith this Security Instrument) can be sold one or more times without prior notice to Borrower. A safe might result in a change in the entity (;mown as the "Loan SerAcer ") that collects Periodic Payments due underthe Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a .sale of the Note. If there is a change of the Loan Servicer, Sorrowerwillbegiven written notice oft he change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any *4her Infe"natfon RESPA requires in connection with a notice of transfer of servicing. If the Mote is sold and thereafter the - Loan is serviced by a Loan Servicer other than the purchaser of the Note, " mortgage loan servicing obligations to l3orrowerwiSl remain with the Loan Servicer or be transferred to a succ Loan 5arvicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. r" Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a cla6s) that arises from the other party's actions pursuant to this Security Instrument orthat alleges that the other party has breached arty provision of, era u awed 2ztit is we - PENNSYr_YANtR Stngl� Faretriy Fsruala rS4aoJFroddta Mac ttNtFOE3M INSTRUMENT Form 3029 filAt - a 1909- 2007' ontne pcs maters, ins. Page 11 of 14 PAUt3EDL uM 01/0312013 11:24:04 AM CUMBERLAND COUNTY InsL# 201210786 - Page ; WAN . §rAW by reason of, this Security Instrutent, until such Bonower or Lender has r offied the otter party (with such notice given In comPlIance With the requirements Of Section tk) of such allied breach and afforded the other party hereto a reasonable paticd After the giving of sas h notice tO take correctfva action. If Applicable L aW prv,4des e time period v Erich mustelapse before rartain actjs h can be taken, that time period will be deemed to be reasonable far purposes of this pamgraphr 7bQ nok$ of accele ration and OPPOftriltY to cure nitres( 10 8017ower pursuant to Section 22 arid, the notice of acceleration given to Bon ewer pcarsusnt to Section tS shall be deemed to safsfy the notice and opportunity to take correctmi action provisions of", Scaction M 21. Hazardous Substances. As used in th4 Ssctinra 21. (a) 'Hazardous SubsLances are ihos~, s _rbstances defined as topic or hazwdous substance —, paNutarte, arvv asles byEnvironmental Uwaana tfle fallowing substances, gasoline, rierosene, other tlamrrable or toxic petroleum produce, kok Resticides - and herbicid volatitesolvents, materialsoarttairting krestusorfsarma ehyde,attdt losctivaotlats�riafs; (b) `F. Vironmental law" means federal laws. and of the kud seiiicgon ,here the Propeltj is late+that relate to health, safety cis• environmelital Wotectior, (c) "Environmental Cleanup" includes any response action, remedial action, or removal action, ou defined in Environmental ; and (d) an `F- hvlmnrnental onedtri ' ore "means a coridition that can ca�aae, contributeto, orothem ise triggeral i Environmenta6 Cleanup. Soreovier shall not cause car peank the presence, use, disposal, storage, or release of any Hazardous Substances, cr threaten to release any Hazardous Substance., on or in the Property, grower shau not do, nor allow anyone else to do, ariything affecling the Roperty (a) that N in violation of any Environrr!ental i.aw, (b) which creates an Environmental Condition, or (d) which, due to the presence, use, or release or — a Hazardous Substance, creates a condition irate edsety c tize value oaf the Property.7ha fareceding two sentences shall not apply to the presence, use, or storage an the Property of small quantities of -- Hazardous Substances that are generally recognized to ta appropriate to normal residential uses arnt! to maintenance of the Property (including, but not limited to, 7 an tdous sibstanc6s in consumer products), Borrowershali promptly give under written notice of (a) any investigation, claim, demand, Isswsuit ' - w other action by any governmental or regulatory agency ar private party involving the Property and _ any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition. including but not limited to, any spilling, leaking, discharo release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or releaso of a Pamrdous Substance which adversity affects the value of the F roperty. If Bwower leams, or is notified by any governmental or regulatory authority, or any private party, that any removal or other remediaticn of any Hazardous Substance affecting the Property is necessary, Borrower small promptly take all necessary remedial actions in accordance %rith Environmental Law. Nothing herein shall create any obligation an Lender for an Environmental Cleanup, NDN- UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows. 22. Acceleration; Remedies, Leader shafl give notice to Sarraw ar priorto accalaratlonfollowing Borrower's breach of any covenant or agreement In this Security Instrument (but not prior to acceleration under Section IS unless Applicable Law provides. otherwise). Lender shall notify Borrower of, among otherthIngs (a) the defaull; (b the actfon required to cane tho default (c) when - thedefaultmuetbacurad; and (at) &hatfslltrro to cure the default aeppecifled rnayroWl in ecceierarilon - of the sums secured by this Secu Inetaumank foreclosure by Judicial proceedng and sate of the Proper: Lender a hall further Inform tBoarovuerolthe rtglatt�reinafafe afterarcol ®ra�ttort and tai rrigl�t �: to assert In !hG foreclosure proceeding the non-asistenee of a default or any csth" aiellonse of Borrower to acceleration acidfor losum. Ifthe default isnotcured !asapectilod,Umderat its option may require lrnmedltate ps ymenttnfuft of sit surssssecured by Ws Socurlty fnstrumentrrrilhoutfurthet demand and mayfoeectsse this Security instrcarnent by judicial proceeding. Londershiall be antMod to collect ali expenses Incurred In pursuing the ramedles provided In this Section 22, Including, but not limited too, attorrmye foso and cow of title evidence to the extent permitted by Applicable Law; -�— 23. Release. Upon payment of all sums secured by this Security Instrument, #tls ecurity Instrument and the estate conveyed shall terminate and become void. After such occu ender 8asif sa <' PENNVLVANG - •Sbgle Femur- Fsnnle UselFeeddle Mne UNIFORM INSYRUMENr i=eTt SM9 11 01098.2W7online Documents. Int. Page 12 of 14 FAUDSOL area e 0110312013 1129:04 AM CUMBERLAND COUNTY InsL9 201210786 - Page 12, LOAN - shall discharge and saftfy thisSecurity Instra ment. Borrower snail pay any recordation Cos . s er may charge 13orrowera feeforrelessing th. Security Instrument, but only ifthelas is p�ld to a(lbird party for sonlicas rendered and the charging of the fee- L permitted. under Applicable Law, 24, Walvere. Srrtra to the extent perm, iited by Applicable Law, walves and releases any efror or defects in proceedings to enforce this vectu ty Instrument, and hereby waives the benefit of any - present or titure laws prouidli•sg for stay of execution, estenstran of fto, exernptiar6,frorn at ta ch t, Ieuy and sate, and hornestead exemption. - _. 25. Reh atemarctFaet iad,Sono rer' sthrietoreinstate hour y prior to the commencement of bidding at a sharrifft s sate or rather sale pursuant to this aeccurity Instrument. 25, purchaae Money Mertgagea. if any of tits dttbt secured by this sec urity kWirument is Lent to Borrowerto acquire tiff to the ftperty, ibis Se- purity Instrument shall be apurchase money mortgage. - 27, lnterati�teAf# erJutgrtReniv isarrorxaeeagreeatttgeinteresteateprz ltablaafterajrrdgrererat - is entered on the Note-or in ata sclion of mortgageforerlosure sha(lbe the rate payablefrr m timattatime under the Note., BY SIGNING BELOW, Borrower Acpepts and agrees to the term and covenants contained In this Security Instrument and In any hider exerutecd by Borrower and retarded with is _ g rae A 3x7ra1 r PENNSYLVANIA- SIndra Femiiy- -FHnrs €e Mae/Fmddte teas UNIFFOHM INSTRUMENT Fort awe lf/M a 19W2007OnNne Dowmam, kcr Paga 13 of 14 PAUDEDL Ow ` s ZV0312013 11:29 :44 AM CUMBERLAND C4UNrf Inst,# 2012iWW - Page a�. LOAN camanontwealtFr rsf x�R`�cir.5'.z+. - County of emSERLAIrp a! I.e" _ ota this t}�e � day of _ � before sa+u, the usndersigneci af¢ics , gara�an lay —app—axed' der, L Hpmaer AND Tracy A. 1ternar known to me (or xatiaftutorily proven) to be the F«azsor WhOPa DWO (a) iZ/arO aUb&43.rilaaOd to the sr9.thin lustrmmi�rat tint ackaolsledged that: he/Sha /thatr executed the same for the.purrposeg t ba eln Containd. °A W In witness wkeaseaf Y iaa rtsuttt t sat my hand and Off i aa�� Baal f -n � a Y My oo=isaiau mxpir�esu ,eZ3 Vit."e of a Ca COMMO_ aN`!'t� O LYANIA Karen t. > ,beMndC0Wh' � My 1 ommtsston t u2s Nnx. -44-2013 Hti @i i tog, ppfltrGViY3fl H , e Certificate of Residence - } -f-4r - �. do hereby certify that the correot address of the within- named wrtgagee is 2175 UuMBLE P.EE — FC O LL0 14 R9 MXCX"XCSSUR13 PA 17055 Witness my hand this day/ of . Agetii of - EnitialS. PENNSYLVANIA - Vriola Fewl y- farmto MeafFFr*Wle Mee UNIFORM INSTAU)eurr Form am!) 1101 01ag8- 2oo7 Online Dwumanla,Ina Page 14 of 14 PAUDEDL =9 L ly ex: a _ t 9 t 1:29:04 AM CUMBERLAND COUNTY inst# 201250 786 - Page.. "GAL DYNCRIPTION ALL, that cerWm tract of l td 'rith improvemcnts thereon erected, si - Wate in the Township of Soufn _= Nlitldletou, Cumbodand County, Pemsylr/ania, bounded and described, as follows, according to a survey made by Tho7sYan, A- NeM "., on 71 *tee 6., '1967, :is follows: BEC-1 , 4 - 12 , 4 at a spike in the centerline. of! ovr hip Rparl'No. i 72, the corner oflaad zsow (,r FOAMeaiy of Rvsse l R.. Elickex� et im; theuse rdong said centerline, Sotuh 45) degrees 15 minutes West`, 250 feet to another spice in said ceutexlzue; thence a] ong .lands now or formerly oft y HoUcnbaueli and Pail North 10 defies 19 mattes Vest, 447.13 fee, to an icon pips: at corner of said land 121?`Vtr or formerly of Russell. K Elicker, et ux; thenm Edong� said land iio - w €1r fk)m aly :rf Rtassell ft. dicker, et ux , South 44 - deg=s 45 minutes East, 364.63 fmt, and through an iron pipe , to the spike in the centerline of Township _ Road 572, the Place of BEGIN -KING. HA VING THEREON 1;R- .ECTED a fie ranch cl°.veilir g with attached one- gange known and numbered as 154 Hollenbaugh Road, Carlisle, Pennsylvania 17103. Parcel #: 40 -23 -0585 -004 1/03/2013 11:29:04 AM CUMBERLAND COUNTY InstA 201210786 - Page: -' - 4 ROBERT P, ZIEGLER RECORi~ 1►ER. OE REEDS CUMBERLAND COUNT I COURTHOTJSESQUARE Y - CARLISLE, FA 17013 _ _ a w 717•_140 -+6370 - Instrument Ydumber n 201210786 Recorded On 41,13/2012 At 11:47:43 A- *To tat Pages -1.6 — a Instrument Type - MORTGAGE 1II5'1rs ce t t&talber a 106041 User ID - SW " Mortgagor - HALER, TERRY L * mortgagee -� A�A=i RICHO10E ]FEDERAL CREDIT 1 J�? 10 N k C'ustower - CORE SETTLEmuNT SER'vICJES FEES STATE WRIT TAX $0.50 certification page STATE JCS/ACCESS TO $23.50 JUS TICE NOT DETACH RECORDIRG FEES $33.50 pXCORDER OF DEEDS `I'hi5 pane is now part eAPCEL CERTIVICATION $10.0o of this legal doedment: FEES - AFFQFD"x E HOUSING $1:1.50 COUNTY AR C H IVES E .$2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $84.00 I Certify this to be recorded ill Cumberland County. PA e Z t� ID Zos * - Information denoted by nn asterisk may change during the verifiestion pracess and may not be rediected on ibis page. 002M59 '/0312013 11:29'04 AM CUMBERLAND COUNTY Ins(. #20121078fi qq .7012 3460 0003 4494 9228 Midwest Loan Services 616 Shelden Ave Suite 300' Houghton, MI 49931 -0144 7012 3460 0003 4494 9228 TRACY A HARMER 154 HOLLENBAUGH RD CARLISLE, PA 17015 i i t EXHIBIT a 7012 3460 0003 4494 9228 LY3JMWTES A '/ L � ' � . 7 ./ gA.'�.'T)�S+�yE7y.�7�.p�Y IC�E, 7 S �Q.� 616 S ELDE 1 / �4��L (p Y S,`i�1 y EJE, SUITE' n300 HOUGHTON, P Lj�7O�,X 144 g�-g �y 1S'. I 47731 - 01.44 October 16, 2013 154 HOLLENBAUGH RTC CARLISLE PA 17015 RE: Loan NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE Under Section 403 of Pennsylvania Act No. 6 of 1974 The Mortgage held by AMERICHOICE CREDIT UNION, on your property located at 154 HOLLENBAUGH RD, CARLISLE PA 17015 IS IN SERIOUS DEFAULT because you have not made the monthly payment of $1,014.80 from July 2013 through October 2013. Late charges have also accrued to this date and the total amount now required to cure this default, _or in other words get caught up in your payments, as of the date of this letter is $4,118.46. Total Principal, Interest and Escrow $4,059.20 Total Current Late Charges $ 276.64 Total Deferred Late Charges $ .00 Total Current NSF Charges $ .00 Total Deferred NSF Charges $ .00 Other Fees $ .00 Less Money in Suspense $ 217.38 Total Due $4,118.46 You may cure this default with thirty (30) days of the date of this letter, by paying to us the above amount of $4,118.46, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by caste, cashier's check, certified check or money order and made, at the office of Midwest Loan Services, Inc., 616 Shelden Ave, Suite 300, PO Box 188, Houghton, MI 49931. If you do not cure the default with THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not wade within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose your mortgaged '7012 3460 0003 4494 9228 property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but your cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fee even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure, the default within the thirty-day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the right to care the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the rnot tgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately three (3) months from the above date. A notice of the date of the Sheriff sale will be sent to you before the sale.. Of course, the arnount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. 800-262-6574 x0. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST.) YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as it no default had occurred, However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, Loan Counselor Mailed Certified on October 16, 2013 Certified Receipt No.: 7012 3460 0003 4494 9228 Return Receipt Requested 7012 3460 0003 4494 9229 BIPORTANT: PLEASE READ In addition, except for FHA- insured loans, you will receive another notice from us under Act 91 of 1983. That notice is called "Notice of Homeowroers' Emergency Mortgage Assistance Act of 1983 ". That notice will explain certain other rights that you might have under Act 91 of 1983. You MUST read both notices since they both explain rights that you now have under - Pennsylvania law. The time limits for Lender's Action as explained in this .Act 5 Notice might be substantially changed if you choose to apply for Mortgage Assistance ender Act 91 of 1983. If you choose to exercise your rights described in Act 91 of 1983 Notice, we cannot foreclose upon your home during that time.. Also, if upon application for Mortgage Assistance, and if mortgage assistance is granted from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving the assistance. By Loan Counselor IF YOUR PERSONAL LIABILITY FOR THE MORTGAGE NOTE HAS BEEN DISCHARGED IN BANKRUPTCY, YOU WILL NOT BE HELD PERSONALLY RESPONSIBLE FOR NON- PAYMENT OF THE DEBT, HOWE ER FORECLOSURE OF YOUR H OME WILL STILL OCCUR UNDER THE TERMS OF THE MORTGAGE CONTRACT IF YOUR ACCOUNT IS NOT BROUGHT CURRENT. 7012 3460 0003 4494 9228 October 16,20 T I NOTICE: TAKE ACTION TO SAVE YOUR HOM FROM FORECLOSURE T his is an official notice that the morteaze 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 pees. The HOMEOWNER'S EMERGENCY MOR'T'GAGE ASSISTANCE PROGRAM (HEMAn may be able to help to save your hoarse. This Notice explains how the program works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER_ CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit CounseliinR Agencies servisng your County are listed at the end of this Notice. If you have any guestions..ou may call the Pennsylvania Housing Finance Agency toll free at 1- 800- 342 -2397. (Persons with unpaired 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 IlNMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIEA. PUEDES SET€ ELEGIJBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERIDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: 154 HOLLENBAUGH RD jCA PA 17015 LOAN ACCOUNT NO.: 7012 3460 0003 4494 9 37.2£ ORIGINAL LENDER: AMERICHOICE CREDIT UNION CURRENT LENDERISER ICER: Midwest Loan Services, inc. servicing agent for A1bIERICHOICE CREDIT UNION HOMEOViT NER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE VdIHCff CAN SAVE YOUR HOME FROM FORECLO AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH 'T'I'LE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. g 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 ESTABLISH—ED 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 MEE'T'ING MUST OCCUR WITHIN THIRTY -THREE (333) 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", EXTLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES — If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. 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. 777777 " 77 F -7 77-777 7012 3460 0003 4494 9228 YOU SHOULD FILE A HEMAT APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSEI.,RIC AGENCY WDITHN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREV -ELATED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE LIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPUICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A S-fl SALE, THE FORECLOSUR -. WTJ-L BE STOPPED. AGENCY ACTION l'ION - 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 tune, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bank you can still apply for Emergency Mortgage Assistance.) HOB' TO CURE YOUR MORTGAGE DEFAULT (Brine it cap to date. NATURE OF THE DEFAULT The MORTGAGE debt held by the.above lender on your property located at: The Mortgage held by AMERICHOICE CREDIT UNION, on your property located at 154 HOLLENBAUGH RD, CARLISLE PA 17015 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS of $1,014.80 from fuly 2013 through October 2013. Late charges have also accrued to this date and the total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $4,118.46. Total )Princi al, Interest and Escrow $4,059.20 Total Current Late Charges $ 276.64 Total Deferred Late Charges $ .00 Total Current NSF Charges $ .00 Total Deferred NSF Charges $ .00 Total Miscellaneous Fees $ .00 Less Money in Suspense $ 217.38 Total Due $4,118.46 7012 3460 0003 4494 9228 HOW TO CURE THE DEFAULT —You may cure the default within TH1RTY (30) DAYS of the date of this notice BY PAYING TAE 'TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,118.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WITICH BECOME DUE DURING THE TI11R1Y (30) DAY PERIOD. Payments roust be made either by cash, cashier's check, certified check or money order made payable and sent to: Midwest Loan Services Inc. 616 Shelden Ave., Suite 300 PO Box 188 Houghton, MI 49931 IF Y DO NOT CURE THE DEFAIJL,T --If you do not cure the default within T14-IRTY (30) DAYS of the date of this Notice, the leader intends to exercise its rights to accelerate the mort2ne 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 Iender, which may also include other reasonable costs. If you cure the default within the TIURTY (01 DAY period. you will not be re€tuire€i 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 SILERH'F'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, oy u 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 pMinQ 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 Caring your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 10 months from the date of this Notice. A notice of the actual data of the Sheriffs Sale will be sent to you before the sale_ Of course, the amount needed to cure the default will increase the longer you 7012 3460 0003 44-94 9228 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. Midwest Loan Services, Inc. Address, 516 Shelden Ave., Suite 300 PO Box IS& Houghton., MI 49931 Phone Number: 800-262-6574 x0 Fax Number 906 - 457 -5 869 Contact Ask for your assigned loan counselor EFFECT OF SHERIFF'S SALE ,9 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other_ belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-- You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and casts 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.) e 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 ATTACHED Error? Not a valid filename. 7012 3460 0003 4494 9235 i Midwest Loan Services j 616 Shelden Ave Suite 300 1 l F Houghton, MI 49931 -0144 7012 3460 0003 4494 9235 TERRy HARPER TRACY A HARNER 154 I'If1L.L,ENBAUUH RIB CARLISLE, PA. 17015 7412 3460 0003 4494 9235 MIDWEST LOIN SERVICES, INC. 616 SHELDEN A` ENUE, SUITE E 300 P0 BOX 144 HOUGHTON, lid 49931 -0144 October 16, 2013 . TERRY HARNE 154 I-IOLLENBAUGH RD CARLISLE PA 17015 RE: Loan #*0= NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN VALANCE . Under Section 403 of Pennsylvania Act :too. 6 of 1 0 ,74 The Mortgage held by AMERICHOWE CREDIT UNION, on your property located at 154 . HOLLENBAUGH RD, CARLISLE PA 17015 IS IN SERIOUS DEFAULT because you have not made the monthly payment of $1,014.80 from July 2013 through October 2013. Late charges have also accrued to this date and the total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $4,118.46. Total Princi al, Interest and Escrow $4,459.20 Total Currennt Late Charges $ 276.64 Total Deferred Late Charges $ .00 Total Current NSF Charges $ . 00 Total Deferred NSF Charges $ ..00 Other Fees $ .00 Less Money in Suspense $ 217.38 Total Due $4,118.46 You may cure this default with thirty (30) days of the date of this letter, by paying to us the above amount of $4,118.46, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order and made at the office of Midwest Loan Services, Inc., 616 Shelden Ave, Suite 300, PO Box 188, Houghton, MI 49931. If you do not cure ,the default with THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments_ This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose your mortgaged 7012 3460 0003 4494 9235 property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but your cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fee even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you care the default within the thirty -day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you Dave not cured the default within the thirty -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 foreclosure sale. You may do so by paying. the total arnount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately three (3) months from the above date. A notice of the date of the Sheriff 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 tirne exactly what the required payment will be by calling us at the following number: 800 - 262 -6574 W0 This payment must be in cash, cashier's check, certified check- or money order and made payable to us at the address stated above. You should realize that a Sheriff's. sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST.) YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF_ If you cure the default, the mortgage will be restored to the same position as it no default had occurred, However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, Loan Counselor Mailed Certified on October 16, 2013 Certified Receipt No.: 7012 3460 0003 4494 9235 Return Receipt Requested 7777777. P z 777 7012 3460 4003 4494 9235 pi'o'IPORTANT: P LEASE READ In addition, except for FHA- iitsured loans, you will receive another notice from us under Act 91 of 1983. That notice is cared "Notice of Homeowners' Emergency Mortgage AssistaDce.Act of 1983 That notice will explain certain other rights that you might have under Act ga. of 1983. You MUST read both notices since they both explain rights that you now have under Pennsylvania law. The time limits for Lender's Action as explained in this Act 6 Notice -might be substantially changed if you choose to apply for Mortgage Assistance under Act 91 of 1983, If you choose to exercise your rights described in Act 91 of 1983 Notice, we cannot foreclose upon your home during that time. Also, if upon application for Mortgage Assistance, and if mortgage assistance is granted from the Pennsylvania Housing Finance Agency, your borne cannot be foreclosed upon while you are receiving,the assistance. By Loan Counselor IF YOUR PERSONAL LIABILITY FOR THE MORTGAGE NOTE HAS BEEN DISCHARGED IN BANKRUPTCY YOU WILL NOT BE HELD PERSONALLY RESPONSIBLE FOR NON- PAYMENT OF THE DEBT. HOWEVER FORECLOSURE OF YOUR HOME WILL STILE, OCCUR UNDER THE TERMS OF THE MORTGAGE CONTRACT IF YOUR ACCOUNT IS NOT BROUGHT CURRENT. 7012 3460 0003 4494 9235 October 16, 2013 .ACT 91 NOTICE. T I SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mor age on your laoine is in default and the lender int ends to foreclose. Specific information about the Mature of the default is provided i 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 HE MAP can Delp, you must IYtEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. 'fake 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 Iisted at the end of this Notice. If you have any you may call the Pennsylvania Housing Finance Agency toll free at 1- 800342 -2397. (Persons with impaired hearing can call (717) 78Q1- 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 helix you find a lawyer. LA NOTMCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ES`I'A NOTIRCACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER EL EGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO °'HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDII)A DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): TERRY HARNER PROPERTY ADDRESS: 154 HOLLENBAUGH RD CARLISLE PA 17015 LOAN ACCOUNT NO_: 7012 3460 0003 44994 9235 ORIGINAL LENDER: AMERICHOICE CREDIT UNION CURRENT LENDERISERVICER: Midwest loan Services hic. servicing agent for AMERICHOICE CREDIT UNION HOMEOWNER'S EMERGENCY MORTGAGE ASSIS'T'ANCE PROGRANI YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HO FROM FORECLOSURE AND HELP YOU MADE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAYBE 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 OCCIJ)<2 WITHIN THIRTY-THREE (33) DAYS OF'I ICE 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 credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in.which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions_ 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 Rousing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHF'A and received within thirty (30) days of your face -to -face meeting with the counseling agency. 7012 3460 0003 4494 9235 YOU SHOULD FILE A HEM-AP APPLICATION AS SOON AS POSSIBLE, IF YOU HAVE A MEETING WI A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS_ A LA T 9 APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL Y APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE Viq LL BE STOMPED, 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. NO'T'E: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, TIME FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have 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 leader on your property located at: The Mortgage held by AMERICHOICE CREDIT UNION, on your property located at 154 HOLLENBAUGH RD, CARLISLE MA 17015 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS of $1,414.80 from July 2013 through October 2013. Late charges have also accrued to this date and the total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $4,118.46. Total Principal, Interest and Escrow $4,053.20 Total Current Late Charges $ 276.64 Total Deferred Late Charges $ .00 Total Current NSF Charges $ .00 Total Deferred NSF Char es $ .00 Total Miscellaneous Fees $ .00 Less .Money in Suspense $ 217.38 Total Due $4,118.46 77T 7 70 12 3460 0003 4494 4235 HOW TO CURE THE DEFAULT ._ - -You may cure the default within THEIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICF1 IS $4 9 11$,46, PLUS ANY MORTGAGE PAYMENT'S AND LATE CHARGES W141CH BECOME DUE DURING THE iHdRTY (30) DAY PERIOD. Pay ments roust be made either by cash, cashier's check, certified check or money order made payable and sent to: Midwest Loam Services, Inc. 616 Shelden Ave., Suite 300 PO Box 188 Houghton, MI 49931 IF YOU DO NOT CURE THE DEFAULT -If you do not cure the default witl - dn THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights t o accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you -nay 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 mae—rty- 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 TIIIItTY X30) I?AY period, you will not lze required to tray attorne '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 hav the right to cure the default and preygnt the sate at any time up to one hour before the Sheriffs Sale You may do so by ping the total amount then past due alus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SIDUfl F "S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 14 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you 7 77777 77 7777 7012 3460 0003 4494 923 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 LEN - DER: Nance of Lender: Midwest Loan Services, Inc. Address: 616 Shelden Ave., Suite 300 PO Box 188 Houghton, VII 49931 Phone Number: 800 - 262 -6574 x0 Fax Number: 906 - 487 -5869 Contact: Ask for your assigned loan counselor EFFECT OF SH ERIFFS SALE -m You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the tender at any time. ASSUMPTION OF MORTGA -- You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE TBE RIGHT: d 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, f TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. B TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ATTACHED Error? Not a valid filename. F1LIE,3 -OF FIC r ,.r Midwest Loan Service�OWJA _ 8 PM 1 : 4 6 Plaintif IN THE COURT OF COMMON V. CUMBERLAND COUNTY PLEAS OF CUMBERLAND Terry L. Harner PENNSYLVANIA COUNTY, PENNSYLVANIA Tracy A. Harner Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE IV i - t�'l 7 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. hive in the residential property which is the subject of th is 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 (7 17) 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 conci liation 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 TIDS NOTICE. TIDS PROGRAM IS FREE. Re, tfuII kumit d: D ate: [ ' Tnat 1 1 0D i intift] Midwest Loan Services, Inc. Plaintiff IN THE COURT OF COMMON V. PLEAS OF CUMBERLAND Terry L. Harrier COUNTY, PENNSYLVANIA Tracy A. Harrier Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Adrn.inistrative Order dated 2012 . governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: I . 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; �. 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 ofI 8 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 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: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: State: _ Zip: Is the property for sale? Yes ❑ N'o [j Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes[] No R Mailing Address (if different): City: State: Zip: Phone Numbers Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: T.nan N7mhr�r 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 41: 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 Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mart a e Food 2 Mort a e Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered)_ Auto fuel /re airs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care/I'uit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes R 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 Q No F If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. UWe understand that l/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 tender'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 1' Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Fit ED-OFFICiE Sheriff 4 'RQOW tAn'� ` �a ,11111f etif`Jr� `� Jody S Smith 2014 JAN 24 S. 53 Chief Deputy N�') , Richard W Stewart Solicitor CUMSERLAND CGUNTY �;�r���,. r ..������� PENNSYLVANIA Americhoice Federal Credit Union Case Number vs. Terry Harner(et al.) 2014-218 SHERIFF'S RETURN OF SERVICE 01/10/2014 08:21 PM- Deputy Jason Kinsler, 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: Tracy A Harner at 240 W. North Street#2, Carlisle Borough, Carlisle, PA 17013. JASON/KINS R, PUTY 01/17/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Terry Harper, 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 154 Hollenbaugh Road, South Middleton, Carlisle, PA 17015. Residence is vacant and winterized. The Carlisle Postmaster confirms that mail is delivered to the address provided. SHERIFF COST: $62.56 SO ANSWERS, January 17, 2014 RONNf R ANDERSON, SHERIFF ('t , T r lire/y,n ,ry. rr JAN 30 "E NNS),11/ COitiAN k q�'�1 CHRISTINA C. VIOLA,ESQUIRE#308909 '( STERN&EISENBERG,PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON,PA 18974 TELEPHONE: (215)572-8111 FACSIMILE: (215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR th c\c n ,COUNTY Americhoice Federal Credit Union V Civil No: 14-218 Civil Terry L. Hamer and Tracy A. Harper MORTGAGE FORECLOSURE Defendants PRAECIPE TO REINSTATE CIVIL ACTION Kindly reinstate the civil action in the above captioned matter. ST ' l : IRG, PC BY: ImakW A C. VIOLA Attorney for Plaintiff 1/29/2014 110 al0 111:xiai ak .gs.,.? p-g so/093 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY U 1 klJi {,. ?J.114 APP -7 PM CUMBERLAND COUNTY PENNSYLVANIA Americhoice Federal Credit Union vs. Terry Harner (et al.) Case Number 2014 -218 SHERIFF'S RETURN OF SERVICE 01/31/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Terry Harner, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Berks, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 02/25/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Berks County, the within named Defendant Terry Harner, not found. Eric J. Weaknecht, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $28.00 SO ANSWERS, 1 March 31, 2014 RONNY R ANDERSON, SHERIFF ci CrwtySui:e ;hen '.mss *cav COUNTY OF BERKS, PENNSYLVANIA SHERIFF'S OFFICE Courthouse- 3rd Floor 633 Court Street Reading, PA 19601 Phone: 610.478.6240 Fax: 610.478.6222 Eric J. Weaknecht, Sheriff John Stanton, Chief Deputy AFFIDAVIT OF SERVICE DOCKET NO. 14 -CUMB -218 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BERKS Personally appeared before me, Jason Wolfe, Deputy for Eric J. Weaknecht, Sheriff of Berks County, 633 Court Street, .Reading, Pennsylania, who being duly sworn according to law, deposes and says that after diligent search having been made by him, he was unable to find TERRY HARNER, within named defendant, within this bailiwick. 10'414 IFF j DE UTY SHERIFF BERKS COUNTY., PA Jason Wolfe Notes: 2/24/14 @1:15 PM NO ANSWER, LEFT CARD. 2/25/14 @10:50 AM RESIDENT STATED DEFENDANT LIVES IN CARLISLE. POSTAL SENT: NOT KNOWN AT ADDRESS. worn and subscribed i 14 day of 1�:.,r, 21 NOTA Y PUBLIC, before me NOTA' IAL SEAL 'I /10110C, OXENRE.IDER o ry Public AM ! MNie !44 2016 Sheriffs Costs in Above Proceedings $ 100.00 DEPOSIT $ 35.68 ACTUAL COST OF CASE $ 64.32 AMOUNT OF REFUND 1 "NOT FOUND" as to the above named defendant So Answers, SHERIF OF BERKS COUNTY, PA Eric J. Weaknecht All Sheriffs Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all unpaid sheriffs fees on the same before he shall be obligated by law to make return thereof. Sec. 2, Act of June 20, 1911, P.L/ 1072 Dedicated to public service with integrity, virtue & excellence www.countyofberks.com/sheriff STEVEN K. EISENBERG, ESQUIRE M. TROY FREEDMAN, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ANDREW J. MARLEY, ESQUIRE STERN & EISENBERG PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) E, ,'j isr..i,J Trf 2214 1`,r„ 1 I AM 10. 29 FE 'NSYLVANI N1 a` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION — LAW Americhoice Federal Credit Union v. Terry. L. Harper and Tracy A. Harner (Defendant(s)) Civil Action Number: 14 -218 MOTION FOR SPECIAL ORDER DIRECTING SERVICE BY POSTING AND CERTIFIED MAIL PURSUANT TO PA. R.C.P. 430(a) TO DEFENDANT(S), TERRY L. HARNER 1. Plaintiff is Americhoice Federal Credit Union which, through an assignment of mortgage became the holder of a Note and Mortgage executed by Terry L. Harner and Tracy A. Harper, secured by a mortgage on real estate located at 154 Hollenbaugh Road, Carlisle, PA 17015. As a result of Defendant's default on said mortgage, Plaintiff filed a Civil Action - Mortgage Foreclosure on January 8, 2014. 2. The identity and whereabouts of Defendant(s) is /are unknown and accordingly, all attempts to serve said Defendant(s), TERRY L. HARNER, pursuant to the usual process prescribed by Pa. R.C.P. 400 -405 have been futile. 3. Pursuant to Pa. R.C.P. 430(a), an investigation has been made to determine the whereabouts of the Defendant(s), TERRY L. HARNER, and the reasons why service cannot be made. Attached hereto and made a part hereof, as Exhibit "A ", is an Affidavit stating the nature and extent of the investigation. 4. Pursuant to Pa. R.C.P. 430(a) and Pa. R.C.P. 410(c)(2) and (3), this Court may enter a special Order directing that service be made by posting a copy of the Compliant and all further notices required in the above - captioned matter, if any, on the most public part of the property or by certified mail to the Defendant's last -known address. 5. A copy of the Motion has been mailed to the Defendant. A copy of the Certificate of Service is attached hereto as Exhibit "B ". WHEREFORE, Plaintiff, Americhoice Federal Credit Union, moves this Honorable Court to enter a special Order directing that service of Defendant(s), TERRY L. HARNER, be made by posting a copy of the Complaint on the premises being 154 HOLLENBAUGH ROAD, CARLISLE, PA 17013, and mailing a copy of same to the Defendant(s), TERRY L. HARNER, by certified mail, return receipt requested and regular mail to the last known address of 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015 andl50 WALNUT STREET, MOHNTON, PA 19540. STERN & EISE BE t• ' , PC BY: EW J. M ' , ESQUIRE STEVEN K. EISENBERG, ESQUIRE M. TROY FREEDMAN, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ANDREW J. MARLEY, ESQUIRE STERN & EISENBERG PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION — LAW Americhoice Federal Credit Union v. Terry L. Harper and Tracy A. Harper (Defendant(s)) Civil Action Number: 14 -218 AFFIDAVIT OF INVESTIGATION I, ANDREW J. MARLEY, ESQUIRE, of Stem & Eisenberg P.C., being duly sworn according to law, depose and say that I am counsel for Plaintiff in the foregoing action and that the following efforts were made by my office to serve the Defendant(s), TERRY L. HARNER, with Plaintiff's complaint and to determine the identity and present whereabouts of said Defendant(s): 1. Service of the Plaintiff's complaint was attempted by the Sheriff of Cumberland County on Defendant(s), TERRY L. HARNER, at 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015. Property is vacant. No service was made. See Exhibit "B" which is attached hereto and made a part hereof. 2. Service of the Plaintiff's complaint was attempted by the Sheriff of Berks County on Defendant(s), TERRY L. HARNER, at 150 Walnut Street, Mohnton, PA 19540. Defendant does not reside at this address. No service was made. See Exhibit "C" which is attached hereto and made a part hereof. 3. According to the United States Postal Service, the Defendant(s), TERRY L. HARNER, is listed at 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015. "GOOD AS ADDRESSED ". See Exhibit "D" which is attached hereto and made a part hereof. EXHIBIT A 4. According to the Pennsylvania Department of Transportation, Bureau of Driver Licensing, the Defendant(s), TERRY L. HARNER, is registered at 150 Walnut Street, Mohnton, PA 19540. See Exhibit "E" which is attached hereto and made a part hereof. 5. Plaintiff conducted a judgment search with the Cumberland County Prothonotary to find the whereabouts of the Defendant(s), TERRY L. HARNER. According to the Cumberland County Docket Search, Defendant(s), TERRY L. HARNER, was served with a Civil Action Complaint at 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015. See Exhibit "F" which is attached hereto and made a part hereof. 6. In addition to the searches conducted above, Plaintiff's Counsel has also conducted an Accurint.com search in order to determine additional information as to the whereabouts of the Defendant(s). Defendant(s), TERRY L. HARNER, according to Accurint.com, is currently listed at 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015. See Exhibit "G" which is attached hereto and made a part hereof. 7. The information provided has enabled Counsel to conduct additional investigation including those contemplated pursuant to Pa. R.C.P. 430(a). Notwithstanding, those additional inquiries and calls have led to no information that would indicate that the Defendant(s) is at any other address. Based on the additional investigation, Counsel believes Defendant(s) is simply evading service. This information is true and correct to the best of my knowledge, information and belief. CU MMONWEgL.Tk OF DIANE J PENNSYLVANIA NOTARIAL SEAL s t o p Bucks Commission Pyres October 31, 014 Sworn to and subscribed before me this / (�h day of , 20 \J. Notary Public STERN & EISENBERG, P BY: ANDREW J. MARLEY QUIRE Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY vz,v1, - of L-ii r�L.7,l¢ OFFICE OF THE CHSRIFF Americhoice Federal Credit Union vs. Case Number Terry Harner (et al.) 2014 -218 SHERIFF'S RETURN OF SERVICE 01/10/2014 08:21 PM - Deputy Jason Kinsler, 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: Tracy A Harner at 240 W. North Street #2, Carlisle Borough, Carlisle, PA 17013. JASON/Kt NSR, UTY 01;17/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Terry Harner, 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..154 Hollenbaugh Road, South Middleton, Carlisle, PA 17015. Residence is vacant and winterized. The Carlisle Postmaster confirms that mail is delivered to the address provided. SHERIFF COST: $62.56 January 17, 2014 SO ANSWERS, RONNY R ANDERSON, SHERIFF COUNTY OF BERKS, PENNSYLVANIA SHERIFF'S OFFICE Courthouse- 3rd Floor 633 Court Street Reading, PA 19601 Phone: 610.478.6240 Fax: 610.478.6222 Al/ Eric J. Weaknecht, Sheriff AFFIDAVIT OF SERVICE DOCKET NO. 14-CUMB-218 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BERKS John Stanton, Chief Deputy Personally appeared before me, Jason Wolfe, Deputy for Eric J. Weaknecht, Sheriff of Berks County, 633 Court Street, Reading, Pennsylania, who being duly sworn according to law, deposes and says that after diligent search having been made by him, he was unable to find TERRY HARNER, within named defendant, within this bailiwick. cAevi L'Ad DEPUTY SHERIFF OF BERKS COUNTY., PA Jason Wolfe Notes:2/24/14 Q1:15 PM NO ANSWER, LEFT CARD. 2/25114 Q10:50 AM RESIDENT STATED DEFENDANT LIVES IN CARLISLE. POSTAL SENT: NOT KNOWN ADDRESS. worn and subscribed before me t i 14 day ofA., ,20 ti NOT 'Y A P Y PUBLIC, !IOTA AL SEAL CC OXENREIDER 0 y Public 1 , 2016 Sheriffs Costs in Above Proceedings $ 100.00 DEPOSIT 35.68 ACTUAL COST OF CASE 64.32 AMOUNT OF REFUND "NOT FOUND" as to the above named defendant So Answers, SHERIF OF BERKS COUNTY, PA Eric J. Weaknecht All,Sheriffs Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all unpaid Sheilffslees-cin the same befOre lieshali be-obligated by law to make return thereof. _Sec. 2, Act ofJune 20, 1911, P.L/ 1072 Dedicated to publi irtue & excellence www. heriff Postmaster Carlisle, PA 17015 -9717 City, State Zip Request For Change of Address or Boxholder Information Needed for Service of Legal Process Date: November 20, 2013 Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Terry L. Harper Address: 154 Hollenbaugh Road , Carlisle, PA 17015 -9717 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waiypd in accordance with 39 CFR 265.6(d)(I) and (2) and corresponding Administrative Support Manual 352.44a•and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: Midwest Loan Services, Inc. v. Terry L. Harner and Tracy A. Harner 4. The court in which the case has been or will be heard 5. The docket or other identifying number if one has been issued: CCP CUMBERLAND COUNTY 6. The capacity in which this individual is to be served (e.g., defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF DD SS 'INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (Title 18 U.S.C. Section 1001). Signature Printed Name - Viola/Christina STERN $r. EISE.NBERG, PC 1581 MAIN STREET, SUITE 200 • WARRINGTON, PA 18976 - City, State, ZIP Code No change of address order on file. Not known at address given. Moved, left no forwarding address. No such address boo 0 4---5 two are 5,7 Documcntl FOR POST OFFICE USE ONLY NEW ADDRESS or BOXHOLDER'S POSTMARK NAME and STREET ADDRESS EXHIBIT PENNSYL( 4IA DEPARTMENT OF TRANSPOFr,TION BUREAU OF DRIVER LICENSING BASIC DRIVER INFORMATION NOV 26 2013 )RIVER: TERRY LEE HARNER 150 WALNUT ST MOHNTON, PA 19540 DRIVER LICENSE (DL) :,ICENSE CLASS : C L ICENSE ISSUE DATE: JUL 11 2013 .LICENSE EXPIRES : JAN 16 2015 )RIG ISSUE DATE : MAY 22 1985 44ED RESTRICTIONS : NONE J EARNER PERMITS . J ICENSE STATUS DRIVER LICENSE NO . DATE OF BIRTH SEX RECORD TYPE PAGE 21760885 JAN 15 1969 MALE REG LICENSE COMMERCIAL DRIVER LICENSE (CDL) CDL LICENSE CLASS . CDL LICENSE ISSUED : CDL LICENSE EXPIRES: CDL ENDORSEMENTS : NONE CDL RESTRICTIONS : NONE CDL LEARNER PERMITS: CDL LICENSE STATUS : SB ENDORSEMENT • PROBATIONARY LICENSE (PL) PL LICENSE CLASS PL LICENSE ORIG ISS : PL LICENSE ISSUED . PL LICENSE EXPIRES . PL LICENSE STATUS . OCCUPATIONAL LIMITED LICENSE (OLL) OLL LICENSE CLASS . OLL LICENSE ISSUED . OLL LICENSE EXPIRES : OLL LICENSE STATUS . * ** END OF RECORD * ** EXHIBIT PA - CUMBERLAND Prothonotary Log Off 0 2013 /NFOCON CORPORATION, All Rights Rcscrvcd 3/21/2014 - 1:42 PM Functions ENTER PAGE UP PAGE DOWN DONE EXrr E-MAIL BACK Dockets Filed Case No: 2013 -05425 Case Type:CONTRACT - DEBT COLLECTION: CR Caption: AMERICAN EXPRESS BANK FSB (vs) HARNER TERRY Filed Date/Time: 09/16/2013 1:55 Position to Page: of 1 Search Date: 00 /00 /0000 n Sel Date Description Image 09/16/13 COMPLAINT- CIVIL ACTION - BY DAVID J APOTHAKER ATTY FOR PLFF COMPLAINT - CIVIL ACTION - BY DAVID J APOTHAKER ATTY FOR PLFF 10/01/13 SHERIFFS RETURN - DATED 09/18/13 - COMPLAINT & NOTICE SERVED ON DEFT AT 154 HOLLENBAUGH ROAD CARLISLE PA 17015 SHFF COST - $34.78 SHFF COST- $34.78 12/06/13 PRAECIPE FOR DEFAULT JUDGMENT AND DEFAULT JUDGMENT ENTERED IN THE AMOUNT OF $ 12,367.88 - BY DAVID J APOTHAKER ATTY FOR PLFF IN THE AMOUNT OF $ 12,367.88 - BY DAVID J APOTHAKER ATTY FOR PLFF 12/06/13 NOTICE MAILED TO DEFENDANT NOTICE MAILED TO DEFENDANT 12/06/13 CERTIFICATION PURSUANT TO RULE 237.1 - BY DAVID J APOTHAKER ESQ CERTIFICATION PURSUANT TO RULE 237.1 - BY DAVID J APOTHAKER ESQ 12/06/13 AFFIDAVIT OF NON MILITARY SERVICE - BY DAVID J APOTHAKER ESQ AFFIDAVIT OF NON MILITARY SERVICE - BY DAVID J APOTHAKER ESQ 12/06/13 IMPORTANT NOTICE FILED (DEFAULT JUDGMENT) Bottom EXHIBIT a F 11U9/13 TERRY lHARNBR 154 HOLLENBAUGH RD CARLISLE, PA 17015-9717 SSN - 161-58-xxxx Age - 44 DOB - 01/xx/1969 Dates - Feb 2004 - Nov 2013 Phones - • 717-258-6474 - EST - HARNER TERRY ( � • 111 STEVEN K. EISENBERG, ESQUIRE M. TROY FREEDMAN, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ANDREW J. MARLEY, ESQUIRE STERN & EISENBERG PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION — LAW Americhoice Federal Credit Union v. Terry L. Harper and Tracy A. Hamer (Defendant(s)) Civil Action Number: 14 -218 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR ALTERNATIVE SERVICE FACTS On April 11, 2012, TERRY L. HARNER AND TRACY A. HARNER, executed and delivered to Americhoice Federal Credit Union, a mortgage upon the property, 154 Hollenbaugh Road, Carlisle, PA 17015, to secure the payment in the sum of $156,000.00. As a result of failure to make monthly payment of $1,014.80 on July 1, 2013 and on the same day of each month thereafter, Plaintiff filed a Civil Action - Mortgage Foreclosure (hereinafter "Complaint ") on January 8, 2014. II. DISCUSSION Pursuant to Pa. R.C.P. 430(a) and Pa. R.C.P. 410(c)(2) and (3), this Court may enter a special Order directing that service be made by posting a copy of the original process and all further notices required in the above - captioned matter on the most public part of the property or by certified mail to the defendant's last -known address. III. CONCLUSION As shown by Plaintiffs Motion for Alternative Service and accompanying exhibits, Plaintiff has made numerous attempts to effectuate service of its complaint on the Defendant, without success. As a result, Plaintiffs Motion for Alternative Service should be granted. STERN & EISE► ► RG ' BY: A I REW J. MA' . , ESQUIRE STEVEN K. EISENBERG, ESQUIRE M. TROY FREEDMAN, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ANDREW J. MARLEY, ESQUIRE STERN & EISENBERG PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION — LAW Americhoice Federal Credit Union v. Terry L. Harper and Tracy A. Hamer (Defendant(s)) Civil Action Number: 14 -218 CERTIFICATE OF SERVICE I, ANDREW J. MARLEY, ESQUIRE, of Stern & Eisenberg P.C., hereby certify that a true and correct copy of Plaintiffs Motion for Alter ativ Se vice was mailed to Defendant(s) by regular, first -class postage prepaid mail on 4/ /6 /L to the following: TERRY L. HARNER 154 Hollenbaugh Road Carlisle, PA 17015 And 150 Walnut Street Mohnton, PA 19540 STERN & EIS BY: ANDREW J. JY, ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION — LAW Civil Action Number: 14-218 ORDER Americhoice Federal Credit Union v. Terry L. Harner and Tracy A. Hamer (Defendant(s)) AND NOW, this /I-Wu day of ILL: , 2014, upon consideration of Plaintiff's Motion for Special Order Directing Service of its complaint by Posting and Certified Mail Pursuant to Pa. R.C.P. 430(a), it is hereby ORDERED AND DECREED that Defendant, TERRY L. HARNER, shall be served by posting a copy of Plaintiff's complaint on the mortgage premises being 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015 and mailing a copy of same to the Defendant, TERRY L. HARNER, by certified mail, return receipt requested and regular mail to the last known address of 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015 and 150 WALNUT STREET, MOHNTON, PA 19540. BY THE COURT: ‚PC,' r- cz1 CHRISTINA C. VIOLA, ESQ. (308909) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) liv'Sco1 k 20! [PR 214 htl 10: 10 E 1NS 1 LYPIIV!A IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union V Terry L. Harner and Tracy A. Hamer Defendants 4/23/14 Civil No. 14 -218 PRAECIPE TO REINSTATE COMPLAINT PRAECIPE TO REINSTATE CIVIL ACTION Kindly reinstate the civil action in the above captioned matter. STE : AND IS NBERG BY C AC.VOLA Attorney for Plaintiff 00,4_,vii.7spdaAj 1(_-'12 37a? ° `0(-t clod (: s CPI'll 1—ri , COURT OF COMMON PLEAS OF CUMBERLAND COUNTY z# CIVIL ACTION -LAW c2;--,, c:n _; y,() CD.; ANDREW J. MARLEY, ESQUIRE STERN & EISENBERG, PC 1581 Main Street, Suite 200 The Shops at Valley Square Warrington, PA 18976 (215) 572-8111 I.D. #312314 Americhoice Federal Credit Union v. Terry L. Hamer and Tracey A. Harner Defendant(s) Civil Action Number: 14-218 CERTIFICATE OF SERVICE I, ANDREW J. MARLEY, ESQ., attorney for the within Plaintiff, hereby certify that the reinstated complaint was sent to Terry L. Harner by certified mail, return receipt requested and regular, first-class, postage prepaid mail, pursuant to court order, on April 30, 2014, as evidenced by copy of said order and certified mailing receipts attached. 04/30/2014 STERN & EISENBERG, PC BY 1.11"DREW J. MA • Y, :QUIRE Attorney for Plai IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION — LAW Americhoice Federal Credit Union v. Terry L. Hamer and Tracy A. Hamer (Defendant(s)) AND NOW, this iq Civil Action Number: 14-218 ORDER day of , 2014, upon consideration of Plaintiff s Motion for Special Order Directing Service of its complaint by Posting and Certified Mail Pursuant to Pa. R.C.P. 430(a), it is hereby ORDERED AND DECREED that Defendant, TERRY L. HARNER, shall be served by posting a copy of Plaintiff's complaint on the mortgage premises being 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015 and mailing a copy of same to the Defendant, TERRY L. HARNER, by certified mail, return receipt requested and regular mail to the last known address of 154 HOLLENBAUGH ROAD, CARLISLE, PA 17015 and 150 WALNUT STREET, MOHNTON, PA 19540. BY THE COURT: )51.6.,„)4.„3 U.S. Postal Service.), CERTIFIED MAILTM RECEIPT (Domestic Mali Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.come Lto co D D D m N m a D Postag Certified Fe Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required Total Postage & Fee SentTo A -M+, L MYVY Y ��111-1.45... Street, Apt. No.; �� \-\V ���,n tQ. or PO Box No. 11.} � City; State, ZIP+4 Ss'Forma600, August 2006 See Re4rse for Instructions U.S.. Postai Service,. CERTIFIED MAILTM RECEIPT (Domestic Maii Only; No Insurance Coverage Provided) For delivery, information visit our website at www.usps.come Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fee See Reverse for Instructions SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny Sheriff of Gtrtrthep,/4.'d v R Anderson UF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor 2014 MAY -8 PM 2: 54 CUMBERLAND COUNTY PENNSYLVANIA Americhoice Federal Credit Union vs. Terry Harner (et al.) Case Number 2014-218 SHERIFF'S RETURN OF SERVICE 04/28/2014 07:12 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Terry Harner, pursuant to Order of Court by "Posting" the premises located at 154 Hollenbaugh Road, South Middleton, Carlisle, PA 17015 with a true and correct copy according to law. RYA BUR D SHERIFF COST: $40.78 SO ANSWERS, April 29, 2014 RONIJY R ANDERSON, SHERIFF (c) CountySu:e Sherif`, Tolcosoft, Inc. STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) J/ n `ri �l JULrt � PRO -rH o o -� 2U! `! if19::7 UpBERLAhD COUNT)/ SYLVANIA IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union v. Terry L. Hamer and Tracy A. Harner Defendant(s) Civil Action Number: 14-218 Civil MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Terry L. Harper Tracy A. Harner , for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE $153,268.50 INTEREST accrued thru 12/30/2013 of $3,996.55 Interest after 12/30/2013 shall accrue at the per diem rate of $18.90.) LATE CHARGES accrued thru 12/30/2013 of $355.68 Late charges after 12/30/2013 shall accrue at the monthly rate of $39.52.) ESCROW ADVANCES $339.64 CORPORATE ADVANCES $590.00 COSTS 300.00 ATTORNEY'S FEE $7,000.00 LESS SUSPENSE (If any) ($217.38) Sub -Total Through Date of Complaint ...$165,632.99 ACCRUED INTEREST after 12/30/2013 shall accrue at the per diem rate of $18.90 to July 10, 2014 $3628.80 ACCRUED LATE CHARGES Late charges after 12/30/2013 accruing at the monthly rate of $39.52 through July 10, 2014 $7,153.12 coal Isklg•SO akots 4i! *,20-sa- ivoke led TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT $176,414.91 BY: PC ❑ EVEN K. FSINBERG, ESQUIRE CIM. TROY FR DMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ESLIE J. RASE, ESQUIRE Er ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE* (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union v. Terry L. Harner and Tracy A. Harner Defendant(s) Civil Action: 14-218 Civil MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants': SS 1. Last -known address is 154 Hollenbaugh Road, Carlisle, PA 17015-9717, 240 West North Street #2, Carlisle Borough, Carlisle, PA 17013 and 150 Walnut Street, Mohnton, PA 19540. 2. Is over the age of twenty-one. 3. Is not now nor has been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers' Civil Relief Act of 1940, as amended. BY: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DIANE. J.rTURANO, Notary Pubic Warrington Twp., County My Commission Expires October 31, 2014 Sworn tc.tkd subscribed before me this tj " nay of Lj , 2014. Notary Public STEVEN K. EI! ERG, ESQUIRE ❑ M. TROY F'L. MAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE • SLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Department of Defense Manpower Data Center Results as of : Jul -10-2014 12:16:03 PM SCRA 3.0 Status Report Pursuant to Servicernembers Civil ReliefAct Last Name: HARNER First Name: TERRY Middle Name: L Active Duty Status As Of: Jul -10-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ~ No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA I NA _ - -. No I -- NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date { The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date - Order Notification End Date Status Service Component NA NA No - NA . This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: VBS1 FAE4SOCOXEO Department of Defense Manpower Data Center Results as of : Jul -10-2014 12:16:36 PM SCRA 3.0 Status Report Pursuant to Servioemembers Civil Relief Act Last Name: HARNER First Name: TRACY Middle Name: A Active Duty Status As Of: Jul -10-2014 Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date On Active Duty On Active Duty Status Date Active Duty Start Date NA NA No Active Duty End Date Status Service Component NA ' ' r NA- No i NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date` f Status Service Component NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA i• No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: OBY3QA6420CO2E0 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union v. Terry L. Harner and Tracy A. Harper Defendant(s) Civil Action: 14-218 Civil MORTGAGE FORECLOSURE CERTIFICATION UNDER RULE 237.1 I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. No. 237.1., a true and correct copy of which is attached hereto. BY: ❑/STEVEN K. E EI) 'ERG, ESQUIRE LrM. TROY F BDMAN, ESQUIRE 0 JACQUELINF. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff STERN & EISENBERG PC THE SHOPS AT VALLEY SQUARE 1581 MAIN STREET, SUrrE 200 WARRINGTON, PA 18976 TELEPHONE: (215) 572-81 1 1 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Americhoice Federal Credit Union (Plaintiff) v. Terry L. Harner and Tracy A. Harner (Defendant(s) TO: Terry L. Harner 154 Hollenbaugh Road Carlisle, PA 17015-9717 Tracy A. Harner 154 Hollenbaugh Road Carlisle, PA 17015-9717 Docket #: 14-218 Civil TEN DAY NOTICE NOTICE PURSUANT TO Pa.R.C.P. 237.1 Date of Notice: Monday, June 30, 2014 Terry L. Harper 150 Walnut Street Mohnton, PA 19540 Tracy A. Harner 240 W. North Street #2 Carlisle, PA 17013-2323 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 By: J:\marilyn\10 Day Notices\Cumberland CountylMidwest.Harner.6.30.I4.docx STERN & EISENBERG, PC Attorney for Plaintiff STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union v. Terry L. Harner and Tracy A. Harper Defendant(s) Civil Action: 14-218 Civil MORTGAGE FORECLOSURE CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriffs Sale scheduled in the above -captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to Defendants and no timely response was made. BY: EVEN IS BERG, ESQUIRE ❑ M. TRO FRE DMAN, ESQUIRE ❑ JACQUTE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union v. Terry L. Harner and Tracy A. Harner Defendant(s) Civil Action: 14-218 Civil MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Americhoice Federal Credit Union 616 Sheldon Ave, Suite 300 P.O Box 144 Houghton, MI 49931 (Plaintiff) Terry L. Harper 150 Walnut Street Mohnton, PA 19540 (Defendant(s)) Terry L. Harper 154 Hollenbaugh Road Carlisle, PA 17015 BY: Tracy A. Harner 240 West North Street #2 Carlisle, PA 17013-2323 S I'EVEN -EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE 0 JACQUELINE F. McNALLY, ESQUIRE ❑ SLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff ai)A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Americhoice Federal Credit Union Plaintiff VS. Terry L. Harner and Tracy A. Harner Defendant Address: 154 Hollenbaugh Road Carlisle, PA 17015 TO THE PROTHONOTARY OF THE SAID COURT ❑ Confessed Judgment ❑ Other File No. 14-218 Amount Due $176,414.91 Interest 7/11/14-12/3/14 Atty's Comm @18.90 per diem=$2,7.50 O� c_.- ;Y,i:v cc% r 2-3 (P� G• > Costs The undersigned hereby certifies that the below does not arise out of a retail installment" as' , P. ,.-- contract, or account based on a confession of judgment, but if it does, it is based on the appropriate orig dal {' proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) See full legal description attached PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) 154 Hollenbaugh Road, Carlisle, PA 17015 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ❑ (Indicate) Index this writ against the garnishee (s) as a lis pendens defendant(s) described in the attached exhibit. Date 7/10/2014 Signature: 1.0)11.0 esF 103. -)S 11 ie 1 . S I, Print Name: Address: Attorney for: Telephone: to of the ndrew J. MaAF 1581 Main S ee , Suite 200 Warringt Plaintiff PA 18976 215-572-8111 Supreme Court ID No: 312314 8.0 ea ^) 5 C,.KJ C 30-sac- eny--s-a--1-06av Lv'd& Tse All that certain tract of land with improvements thereon erected, situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described according to a survey made by Thomas A. Neff, R.S., on June 6, 1967, as follows: Beginning at a spike in the centerline of Township Road 572, the corner of land now or formerly of Russell R. Elicker, et ux.; thence along said centerline, South forty-five (45) degrees fifteen (15) minutes West, two hundred fifty (250) feet to another spike in said centerline; thence along lands now or formerly of Ray Hollenbaugh and Paul Kutz, North ten (10) degrees nineteen (19) minutes West, four hundred forty-two and ten hundredths (442.10) feet to an iron pipe at corner of said land now or formerly of Russell R. Elicker, et ux.; thence along said land now or formerly of Russell R. Elicker, et ux., South forty-four (44) degrees forty-five (45) minutes East, three hundred sixty-four and sixty-three hundredths (364.63) feet, and through an iron pipe, to the spike in the centerline of Township Road 572, the place of beginning. Having thereon erected a frame ranch dwelling with attached one -car garage known and numbered as 154 Hollenbaugh Road, Carlisle, Pennsylvania 17015 BEING the same premises which Terry L. Harner and Tracy A. Hamer, husband and wife, by Deed dated June 5, 2012, and recorded July 10, 2012, as Instrument No. 201220479, granted and conveyed unto Terry L. Hamer, married man, in fee. Parcel #: 40-23-0585-004 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) e./124J 4 IS UND COUN pEF Ali 9: rAwRL r ui IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union v. Terry L. Harner and Tracy A. Harper Defendant(s) Civil Action: 14-218 Civil MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 154 Hollenbaugh Road, Carlisle, PA 17015. 1. Name and address of Owner(s) or Reputed Owner(s): Terry L. Hamer 150 Walnut Street Mohnton, PA 19540 Terry L. Harner 154 Hollenbaugh Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: Terry L. Hamer 150 Walnut Street Mohnton, PA 19540 Terry L. Harner 154 Hollenbaugh Road Carlisle, PA 17015 Tracy A. Harner 240 West North Street #2 Carlisle, PA 17013 Tracy A. Harner 240 West North Street #2 Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: American Express Bank, FSB c/o David J. Apothaker 520 Fellowship Road #C306 Mount Laurel, NJ 08054 American Express Bank, FSB 415 S 2700 West Salt Lake City, UT 84148 Mark 1 Restoration Service, Inc. 7921 Grayson Road Harrisburg, PA 17111 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Tenant(s)/Occupant(s) 154 Hollenbaugh Road Carlisle, PA, 17015. Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: July 10, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DIANE J. TURANO, Notary Public BY: V. 3,,;ngton Twp., Bucks County P="y C,.,,1,r,,s;on Expires October 31, 2014 Sworn • . d subscribed before me thi _ P ay of 2014. STERN TEVEN ❑ M. TROY 0 JACQU BERG, ESQUIRE MAN, ESQUIRE F. McNALLY, ESQUIRE ❑ LL SLIE ` . RASE, ESQUIRE aANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Notary Public STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 - TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) Of. THE PRO /HONO TA 2014 JUL 16 Ail 9: 58 CU PEERL AND COUNTY IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Americhoice Federal Credit Union v. Terry L. Harper and Tracy A. Harper Defendant(s) Civil Action: 14-218 Civil MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Terry L. Hamer 150 Walnut Street Mohnton, PA 19540 Terry L. Hamer 154 Hollenbaugh Road Carlisle, PA 17015 Tracy A. Harner 240 West North Street #2 Carlisle, PA 17013 Your real estate at 154 Hollenbaugh Road , Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on Wednesday, December 3, 2014 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $176,414.91 obtained by Americhoice Federal Credit Union against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Stern & Eisenberg, PC the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern & Eisenberg PC, telephone (215) 572-8111. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern & Eisenberg PC, telephone (215) 572-8111. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call Stern & Eisenberg PC, telephone (215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 All that certain tract of land with improvements thereon erected, situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described according to a survey made by Thomas A. Neff, R.S., on June 6, 1967, as follows: Beginning at a spike in the centerline of Township Road 572, the corner of land now or formerly of Russell R. Elicker, et ux.; thence along said centerline, South forty-five (45) degrees fifteen (15) minutes West, two hundred fifty (250) feet to another spike in said centerline; thence along lands now or formerly of Ray Hollenbaugh and Paul Kutz, North ten (10) degrees nineteen (19) minutes West, four hundred forty-two and ten hundredths (442.10) feet to an iron pipe at corner of said land now or formerly of Russell R. Flicker, et ux.; thence along said land now or formerly of Russell R. Elicker, et ux., South forty-four (44) degrees forty-five (45) minutes East, three hundred sixty-four and sixty-three hundredths (364.63) feet, and through an iron pipe, to the spike in the centerline of Township Road 572, the place of beginning. Having thereon erected a frame ranch dwelling with attached one -car garage known and numbered as 154 Hollenbaugh Road, Carlisle, Pennsylvania 17015 BEING the same premises which Terry L. Hamer and Tracy A. Hamer, husband and wife, by Deed dated June 5, 2012, and recorded July 10, 2012, as Instrument No. 201220479, granted and conveyed unto Terry L. Harner, married man, in fee. Parcel #: 40-23-0585-004 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717)240-6195 www.ccpa.net AMERICHOICE FEDERAL CREDIT UNION Vs. NO 14-218 Civil Term CIVIL ACTION — LAW TERRY L. HARNER AND TRACY A. HARNER WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $176,414.91 L.L.: $.50 Interest 7/11/14-12/3/14 @$18.90 PER DIEM = $2,740.50 Atty's Comm: Due Prothy: $2.25 Atty. Paid: $303.59 Other Costs: Plaintiff Paid: Date: 7/16/14 (Seal) REQUESTING PARTY: Name: ANDREW J. MARLEY, ESQUIRE Address: STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PA 18976 Attorney for: PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No. 312314 David D. Buell, Prothonotary Deputy COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW EDWARD J. McKEE, ESQUIRE STERN AND EISENBERG, PC 1581 Main Street, Suite 200 Warrington, PA 18976 (215) 572-8111 LD. #316721 Americhoice Federal Credit Union Plaintiff(s) v. Terry L. Hamer and Tracy A. Hamer Defendant(s) Civil Action: 14-218 MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, EDWARD J. McKEE, attorney for the within Plaintiff, hereby certify that notice of the Sheriffs Sale was mailed to Tracy A. Harrier by certified mail, return receipt requested and regular, first-class, postage prepaid mail and to Terry L. Hamer per COURT ORDER, on September 25, 2014. I further certify that notice of the Sheriffs Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on September 25, 2014, as evidenced by copies of certificate of mailing and certified mail receipts attached. 9/26/14 STERN AND EISENBERG, PC EDWARD J. McKEE Attorney for Plaintiff Name and Add of S STERN & EISENBERG, PC 1581 Main Street, Suite 200 Line Article # Name of Addressee, Street, and Post Office Address Postage Fee l **** Terry L. Harper 150 Walnut Street Mohnton, PA 19540 2 **** Terry L. Harper 154 Hollenbaugh Road Carlisle, PA 17015 3 **** Tracy A. Hamer 240 West North Street #2 Carlisle, PA 17013 4 **** American Express Bank, FSB c/o David J. Apothaker 520 Fellowship Road #C306 r Mount Laurel, NJ 08054 1 cr 1 m 5 **** Mark 1 Restoration Service, Inc. w 7921 Grayson Road Harrisburg, PA 17111 o -U t o u, 2 6**** American Express Bank, FSB r.L 415 S 2700 West � Salt Lake City, UT 84148 o a N o N O O ,�.. . 7 **** PA Department of Revenue °fl Bureau of Compliance :',;; .:1: "- • Box 281230 e . Harrisburg, Pennsylvania 17128 ::+ ,.-''' •"=7'' 8 **** Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 ' 9 **** Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 10 **** Tenant(s)/Occupant(s) 154 Hollenbaugh Road Carlisle, PA, 17015. RE: Midwest-Harner-NOS NO. OF PIECES LISTED BY SENDER NO. OF PIECES RECEIVED AT POST OFFICE POSTMASTER, PER (NAME OF RECEIVING EMPLOYEE) Q� 4.70 `A L ru Er 0 m nJ For d_`ellv_e_ IIIR mal on sit ur�nre ite�a sps.com 0510 0000 Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To Street, Apt. No.; or PO Box No. City, State, ZIP+4 Terry L. Harmer 150 Walnut Street Mohnton, PA 19540 u�m co rq cr cr m ru sD 0 0 0 0 7014 0510 Posa -(gOATALAa% L5 �mest�cWialkeZtlia2E1114Co er BE delive oibrmation is'it ou ebsite t� .usps om Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To Terry L. Harner Street, Apt. No. 154 Hollenbaugh Road or PO Box No. City State, ZIP Carlisle, PA 17015 (Domestic Prov, ed IFo 11:151 ve nf5Wition visit ouebske at rabt ® Postage Certified Fee Retum Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To Tracy A. Harner Street, Apt, No. or PO Box No. 240 West North Street #2 City, State, ZJP Carlisle, PA 17013 See Reverse for nstructtons