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Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: Cumberland County The information collected on this fartn is used solely for courl administration purposes. This firm does not supplement or replace the, filing and service af'hleadings or other papers as required by law or rules of court. Commencement of Action: S � Complaint C Writ of Summons n Petition Transfer from Another Jurisdiction ® Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Nationstar Mortgage, LLC Michael A. Finkey and Chin Suk Finkey T Dollar Amount Requested: ®within arbitration limits I Are money damages requested? El Yes FX No (check one) noutside arbitration limits O N Is this a Class Action Suit? E] Yes El No Is this an MDJAppeal? Yes El No A Name of Plaintiff /Appellant's Attorney: Christina C. Viola El Check here if you have no attorney (tire a Self - Represented (Pro Sel Litigant} Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS M Intentional El Buyer Plaintiff Administrative Agencies rl Malicious Prosecution ® Debt Collection: Credit Card [] Board of Assessment Motor Vehicle Debt Collection: Other 17 Board of Elections Nuisance ® Dept. of Transportation F1 Premises Liability ® Statutory Appeal: Other S 0 Product Liability (does not include mass tort) r7 Employment Dispute: E Discrimination M Slander /Libel/ Defamation Employment Dispute: Other E] Zoning Board C El Other: � Other: T I l] Other: O MASS TORT M Asbestos N I Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS E] Toxic Waste [I Ejectment rl Common Law /Statutory Arbitration B f Other: l] Eminent Domain /Condemnation E] Declaratory Judgment Q Ground Rent F7 Mandamus Landlord /Tenant Dispute Q Non - Domestic Relations x © Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY rl Mortgage Foreclosure: Commercial Quo Warranto l! Dental Partition Replevin M Legal Quiet Title © Other: n Medical ll Other: i Other Professional: Updated 1/1/2011 STEVEN K. EISENBERG ESQUIRE (75736) ci p M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) J0 1 � " L CHRISTINA C. VIOLA ESQUIRE (308909) C�f�4� ANDREW J. MARLEY (312314) R l� STERN & EISENBERG, PC 106j f4SAN C© 1581 MAIN STREET, SUITE 200 ,tF j L,V 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 Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 V. Civil Action Number: ' • S l /U l Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 COMPLAINT IN Defendant(s) MORTGAGE FORECLOSURE 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 PROVIDn 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 (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 Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 V. Civil Action Number: Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 COMPLAINT IN Defendant(s) MORTGAGE FORECLOSURE 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 las 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 contra 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, la corte 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 notificacion. 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 u 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 Name 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 A 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 Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 V. Civil Action Number: Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 COMPLAINT IN Defendant(s) MORTGAGE FORECLOSURE COMPLAINT CIVIL ACTION - MORTGAGE FORECLOSURE 1. Plaintiff is Nationstar Mortgage LLC (hereinafter referred to as " Nationstar Mortgage LLC ") with offices located at 350 Highland Drive, Lewisville, TX 75067. 2. Defendant(s) are Michael A. Finkey and Chin Suk Finkey, adult individuals with a last - known address of 220 Long View Drive, Carlisle, PA 17013. 3. Under date of 03/30/2007, defendants executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Taylor, Bean and Whitaker Mortgage Corp. a mortgage upon the property 220 Long View DrNe,'Cariisle, PA (ihe "Property") to secure the payment of the sum of $280,000.00. The said mortgage is recorded in the Office for 7 T 7 the Recording of Deeds ip and for Cumberland County on 04/13/2007 at Bk. 1988 Pg. 3047 and is incorporated herein by reference as though set forth at length herein. A copy of the mortgage and legal description of the Property is attached hereto and made a part hereof as Exhibit "A ". 4. An assignment dated June 13, 2013 transferring the mortgage originally with Mortgage Electronic Registration Systems, Inc. as nominee for Taylor, Bean and Whitaker Mortgage Corp. (Originating Lender) to Nationstar Mortgage LLC, was duly recorded on 06/18/2013 at Instrument Number 201319862 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania. A true and accurate copy of the assignment is attached hereto as Exhibit `B ". 5. Said Defendant(s) are the real owners of Property 220 Long View Drive, Carlisle, PA 17013. 6. 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 "C ". 7. The said loan is in default as a result of the failure to pay the monthly installments of $1,769.79 due on March 1, 2012 and on the same day of each month thereafter. 8. The following is due on the loan: PRINCIPAL BALANCE .... ............................... ....................$262,805.19 INTEREST accrued thru 01/15/2014 of .......... .....................$33,396.40 Interest after 01/15/2014 shall accrue at the per diem rate of $46.80.) LATE CHARGES accrued thru 01/15/2014 of .....................$0.00 ESCROW ADVANCE ...... ............................... .....................$15,248.30 CORPORATE ADVANCE .................... ............................... $275.50 COSTS.................................................... ............................... $ 0.00 FORBEARANCE... _ ............................... ............................... $(370.41) TOTAL............................... ............................... ....................$311,35 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. r WHEREFORE, Plaintiff Nationstar Mortgage LLC requests this Court to enter judgment, IN REM, for foreclosure of the mortgaged property for the sum of $262,805.19 plus interest thereon of $33,396.40 plus $46.80 per day from 01/15/2014 until judgment is paid in full, late charges of $0.00, escrow advance of $15,248.30, corporate advance of $275.50, costs of $0.00, forbearance of $(370.41) 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. T EI tEERG, PC BY: ❑ K. EMENBERG, ESQUIRE • M. TROY FREEDMAN, ESQUIRE • JACQUELINE F. McNALLY, ESQUIRE • LESLIE J. RASE, ESQUIRE • CHRISTINA C. VIOLA, ESQUIRE • ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Date: January 2014 VERIFICATION I, the undersigned, an authorized representative of Nationstar Mortgage LLC ( "Nationstar Mortgage LLC "), 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: I 1 /�( 1// 5 11 ,t Name: Olivia McAdams Title: Assistant Secretary NOTE March 30, 2007 Carlisle Pennsylvania (Date] Icily] IStatel 220 Long View t)rive Carlisle, PA 17013 (Properly Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 280,000.00 (this amount is called "Principal'), plus u,terest, to the order of the Lender. The Lender is Taylor, Bean & Whitaker Mortgage Corp. I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.5000 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1st day of each month beginning on May 01, 2007 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If. on April 01, 2037 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will snake my monthly payntertts at Taylor, Bean & Whitaker Mortgage Corp., 1417 North Magnolia Ave, Ocala, FL 34475 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $1,769.79 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When Intake a Prepayment, l will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayient if I have not made a] I the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If Intake 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. MULTISTATE FIXED RATE NOTE — .Single Family Faimle Mae/Freddie Mae UNIFORM INSTRUMENT Form 3200 1101 GREATLANO ■ ITEMT1601.1 (OM 1) (Page I of pages) TeOrdenCa61.60x530- W93drme616- )97.1131 1111!l111lII !1111 Illll Illy IIIII IIIII lI� 1111 Ill! ill! II I 1111111 EXHIBIT '23O3O159fi773• 5_ LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any Sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. if a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of Fifteen calendar days after the date it is due. I will pay a late charge to the Note Holder. The amount of the charge will be 5.00000 of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If 1 do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling rile that if I do not pay the overdue amount by a certain date, the Note Holder may require ine to pay immediately the full amount of Principal which has not beelt paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default. the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have die right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to the under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS TINDER THIS NOTE If more than one person signs this Note, each person is filly and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor'' means the right to require the Note Holder to give notice to other persons that amounts due have not been paid, 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instnnnent" ), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in MULTISTATE FIXED RATE NOTE— Single Family YannieMae/Freddie Mae UNIFORM INSTRUMENT Form 32001t01 GREATUWD ■ ITEM T164M-2 (0011) (Page 2 of J pages) To Odv rat: I- RDa530 -93930 F= 616 - 191-1131 this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Leader's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instniment. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days front the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security lnstntment. If Borrower fails to pay these suns prior to the expiration of this period, Lender may invoice any remedies pennitted by this Security Instrument without further notice or demand on Borrower. Borrower has executed and acknowledges receipt of pages 1 through 3 of this Note. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED (Sea]) (Sea!) Michae�Fin Borrower Borrower (Seal) (Seal) Borrower Borrower (Seal) (Seal) Borrower - Borrower jgign Original Oi4vj Without recome, pay to the Order of By: T0004 Bean 9 Whitaker Mortgage Corp. Ertel CerW -Shaw, E.U.P. MULTISTATE FIXED RATE NOTE Single Fancily Fannie Mae/FrMdte Mac UNIFORM INSTRUMENT Form 3200 t/Ot GHEATLAND ■ 1rEM 11646t3 (Page 3 of 3 Pages) To Cider Cal: 1 - 800.530-9393(3 Ft<616 -791 -1131 iN BERT P.'ZIE%G ER RECrRDER OF DEEDS P-'OSERLAND COUNTY- 2007 APR 13 P() 1 30 [Space Above This Line For Recording Damn MORTGAGE MIN: 100029500015967734 DEFINITIONS Words ttsed in nuultiplc sections of this document are defined below and other words are defined in Sections 3, 11, 13, 18, 20 and 21. Certain ntics regarding the usage of words used in this document are also providd in Section 16. (A) "Security Instrument" mcans this document, which is dated March 30, 2007 , together with all Riders to this docunteni. (B) "Borrower" is Michael Finkey and Chin Suk Finkey Borrower is the mortgagor tinder this Security Instnunent. (C) "MERS" is Mortgage Electronic Registration Systems, Inc. MERS is a separate corporation that is acting solely as a nominee for Lender and Lender's successors and assigns. MERS Is the mortgagee under this Security Instrument_ MERS is organized and existing under the laws of Delaware, and has an address and telephone utunber of P.O. Box 2026, Flint, MI 48501 -2026, ten. (888) 679 -MERS. (D) "Lender" is Taylor, Bean & Whitaker Mortgage Corp. Lender is a organized and existing under the laws of FL Lender's address is 1417 North Magnolia Ave, Ocilla, FL 34475 (E) - Note" means the promissory note signed by Borrower and dated March 30, 2007 The Note states that Borrower owes Lender Two Hundred Eighty Thousand and no /100 Dollars (U.S. $ 260,000.00 ) phis interest. Borrower has prontised to pay this debt in regular Periodic Payments and to pay the debt in full not later than April 01, 2037 (F) "Property" mcans the property that is described below under the heading "Transfer of Rights in the Property." (C) "Load' mcans the debt evidenced by the Note, plats interest, any prepayment charges and late charges duc under the Note, and all sums duc under this Security Instrument, plus interest. PENNSYLVANIA - Single Ninily— Fanale Madi midie Mac UNIFORM INSTRUMENT Form 40391/01 GREAn AT ■ nEM T27SOL1 f001 i — MERS (Pgeel of 16 pages) To Order Cal:1- WO.531F93930 Fax: 616- 791.1131 Ilflll IIIH IIIII IIIII IIIII Illli IIIII IIIII IIIII VIII IIIII III IIIII IIII IIII •d240981596773• RK 19'8SPG3047 (H) "Riders" means all Riders to this Security Instruument that are executed by Borrower. The following Riders are to be exeancd by Borrower [check box as applicable]: El Adjustable Rate Rider ❑ Condominium Rider ❑ Second Home Rider Balloon Rider E] Planned Unit Development Rider ❑ Othcr(s) ]specify] 0 1-4 Family Rider ❑ Biweekly Payment Rider (1) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and gdaninistrative rules and orders (that have the effect of law) as well as all applicable final, non - appealable judicial opiniotu. (J) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessmcnLc and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (K) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic histrunent, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an account. Such term includes, but is not limited to, point -of -sale transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse; transfers. (L) "Escrow Items" means those items that are described in Section 3. (14t) "Miscellaneous Proceeds" means any comtlx:nsation, settlement, award of daunages, or proceeds paid by any third piny (other than insurance proceeds paid under the coverages described in Section 5) for (i) damage to, or dcstrlction of, the Property; (ii) condemnation or other taking of all or any part of the Properly; (iii) conveyance in licit of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (N) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on. the Loan. (0) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument. (P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. §2601 et seq.) acid its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from tine to tithe, or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, " RESPA" refers to all requirements and restrictions that are imposed in regard to a PENNSYLVANIA– Single Fandly— Fanute Mae/Freddle Mae UNIFORM INSTRUMENT Form 30391/01 GREATLAND ■ ITEM 7276012 (001 t }—MERE (Page 2 o f 16 guges) To Oder CA 14530.9393 t3rsx 6W791-1131 811198,8PG3048 "federally related mortgage load' even if the Loan does not qualify as a "federally related mortgage loan" under RES PA. (Q) "Successor In Interest of Borrower" nuns any party that has taken title to the Property, whether or not that party has assunied Borrower's obligations under the Note and/or this Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrument secures to Lender. (i) the repayment of the Loan, and all renewals, extensions and modifications of the Note; and (ii) the perfonnance of Borrower's covenants and agreements under this Security histrtunent and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS the following described property located in the County hype of Recording Jurisdiction] of Cumberland (Mane of Recording Jurisdiction) See Attached Exhibit A. which currently has the address of 220 Long View Deivb kAA [Street] Carlisle Pennsylvania 17013 ( "Property Address"): [City) [Zip Code] TOGETHER WITH all the improvenients now or hereafter erected on the property, and all easements, appurtenluncec, and fixtures now or hereafter a part of the properly. All replacements and additions shall also be covered by this Security ]nstru lent. All of the foregoing is referred to in this Security Instnrnlent as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instnrnent, but, if necessary to comply with law or custom, MERS (as nominee for Lender and Lender's successors and assigns) has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take arty action required d of Lender including, but not limited to, releasing and canceling this Security Instnrnlent. PENNSYLVANIA - Single Family— Funnlr \1neWreddte Mae UNIFORM INSTRUMENT Form 30391/01 GREATLAND ■ rrEM 1276013 (0011)—MFRS (Pagel of !b pages) roOrderCa9 :1-800.530-93930Far:616-791.1131 ON I 988PG30490 BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. BoMwer warianis and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use acid non - uniform covenants with limited variations by jurisdiction to constitute a unifomm security instalment covering real property- UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: I. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due die principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments duc under the Note and this Security Instrument shall be made in U.S. currency. However, if any check or other instrument received by Lcnder as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, basil: check, treasurer's check or cashier's check, provided any such check is drawn upon all institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If cach Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on uuapplied funds. Lender may hold such unapplied finds until Borrower makes payment to bring the Loans current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If tot applied earlier, such fiords will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the f huts against Lender shall relieve Borrower from making payments due tinder the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note. (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other ainottms due under this Security Instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment taut be paid in full. To the extent that any excess exists after the payment is applied to the fill payment of one or more KNNSYLVANI A —Sin* Family— Funnte pladFreddie Mac UNIFORM INSTRUMENT Form M39 1/01 GREATIJN D ■ i ITEM TZ76 X4 (0011) (Pine 4 r f 16 jwgee) To Order Call: 1- 00.530.93930 Fait: 616.791 -1131 11K] 988PG3050 Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date. or change the amount, of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note is paid in fill, a stun (the "Funds ") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property (b) leasehold payments or ground rents on the Property, if arty; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any suns payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. 'flnese items are called "Escrow Items." At origination or at any time during the tcrnn of the Loan, Lender may require thlt Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be at Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Leander waives Borrower's obligation to pay the Funds for any or all Escrow Items- Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender ruquires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to snake such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covca><ant :utd agreetne -nu" is used in Section 9. If Borrower is obligated to pay Escrow ltens directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated tinder Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amou tits, that are then required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to pennit Lender to apply the Funds at the time specifier! under RESPA, and (b) not to exceed the maximunn amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. 'nte 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 de- posits are so insured) or in aury Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Rents no later than the time specified under RESPA. Lender shall not chage Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Leader pays Borrower interest on the Fonds and Applicable Law pemtits Lender to snake such a charge. Unless an agreement is trade in writing or Applicable Law requires interest to be paid on the Funds, Lctudcr shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shalt give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA. and Borrower shall pay to PENNSYLVANIA— Single Family -- Fannie Mae/Freddle.Mae UNIFORM MSTRUMENT Form 10:391/01 GREATL ND ■ ITEM T276MS (0011) —HERS (Pare 3 of 16 pages) To OrAU Cal: 14M90-934313 Far 616 -741 -112, 8X1988PG3051 Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 mondily payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower shall pay all taxes, assessments; charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if arty, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in die manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instnument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over this Security Instmntent, Lender may give Borrower a notice identifying the lien. Within 10 days of die date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4. Lender may require Borrower to pay a one -time charge for a real estate tax verification and/or report ing service used by Lender in connection with this Loan. 5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the terns "extended coverage," and any other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the tern of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connecdon with this Loan, either: (a) a one -time charge for flood zone detemrination, certification and tracking services; or (b) a one -time charge for flood zone detemrination and certification services acrd subsequent charges each time reurappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. If Borrower fails to maintain any of the covcniges described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, tart might or might not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Iistrunient. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. PENNSYLVANIA - -Single Family — Fannie MaelFneddie Mac UNIFORM INSTRUMENT Form 30391/01 GREATLANO ■ ITEM T276015 toot 1}—MMS (Page b of 16 pages) To Order Sall: 1- BOD- SM -9393O Fax 618-741.1131 nu 9 3052 All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, turd shall name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payer;. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments is the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Leader shall not be required to pity Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sunes secured by this Security instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in Section 2. If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related natters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiatc and settle the claim. The 30 -day period will begin when the notice is given. [it either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrtument, and (h) any other of Borrower's rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument, whether or not then due. 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Security Insiruntent and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in _ connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purpose. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is PENNSYLVANIA —Single Natily— FannleMaelFreddle Mae UNIFORM INSTRUMENT Forin.V.W 1/01 we 6WM 11 ■ ITEM T2780L7 (lI0► i ►-HERS (Page T r f 16 IxrArs) io O-Oa Cst; t-0po-53F9393O Fmc Bt6 -791 -7131 8RI988PG30:53' All insurance policies required by Lender and renewals of such policies shall he subject to Lender's right to disapprove such. policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires, Borrower sliall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage not otherwise required by Lender, for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payee. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lenders satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically fusible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Stich insurance proceeds shall be applied in the order provided for in Section 2" If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30-day period will begin when tlhe notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under The Note or this Security Instrument, and (b) any other of Borrower's rights (other thin the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property. insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay announts unpaid under the Note or this Security Instrument, whether or not then due. 6. Occupancy. Borrower shall occupy, establish. and use the Property as Borrower's principal residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld. or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation. Maintenance and Protection of the Property; Insgpections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property. Borrower shall maintain the Pniperty in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section S that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in connection with damage to. or the taking of. the Property. Borrower shall be responsible for repairing or restoring the Paipert) only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as die work is i'ENNSTLVAVIA— iingic F.irml% FannIL Nine/FmAdle tat UNIFOMM IMTRUME.VT Form W 1101 ITEM T2766C7 M I )—YERS i PA; e 7, -f /4;xz� e, J T7 Order CaJ 1$00-536"9393 0 Nx 616-751-10 completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is not relieved of Borrowers obligation for the completion of such repair or restoration. Lender or its agent may make reasonable entries upon and inspections of the Property. If it his reasonable cause. Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause. 8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender with material information) in connection with the Loan. Material representations include, but are not limited to, representations concerning Borrowers occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest In the Property and Rights i'nder this Security Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a legal proceeding that might significantly affect Lender's interest in the Property and /or rights under this Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or fot{titure, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and 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 lien which has priority over this Security Instrwuent; (b) appearing in court; and (c) paying reasonable attorneys' fees to protect its interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change locks, replace or bond up doors and windows, drain water front pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender f*ay take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. Any anhoumts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note late from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. If this Security Instrtnnent is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Nfortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan, Borrower shall pay the preminns required to maintain the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurmce coverage required by Linder ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance. Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Bomw cr of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage is not ;available. Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender sill accept, ttsc and retain these payments as a non- refundable loss reserve in lieu of Nlnrtgige Insurance. Such loss reserve shall be non- refundable. PEXN*SY1.V.VN1.t SmXtc Faith Fannie \Iae/Fredrtte S1ac UNIFORM I\MUNIENT Form 3039 1101 GREATLANO a ITEM 727601.8 1001 I)—MFRS 1 Page X .,f 16 jugeV To Oder raj I- MD- 530-9393 t7 far 616.791 -1131 notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, acid Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately designated payments toward the prentiuuts for Mortgage Insurance. Borrower shall pay the premiums required to maintain Mortgage Insurance in effect, or to provide a non - refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower mid Lender providing forsuch termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the ;Dote. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may incur if Borrower does not repay the Loan is agreed. Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into agreements with other parties that share or modify their risk, or reduce losses. These agreements are on tennis and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. These agreements may require the mortgage insurer to make payments using any source of finds that the mortgage insurer may have available (which nnay include funds obtained front Mortgage insurance prennituns). As a result of these agreements, Lender, any purchaser of the Mote, another insurer, any reinsurer, any other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's payrneuts for Mortgage Insurance, in exchange for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of the insurers risk in exchange for a share of the pretuiums paid to the insurer, the arrangement is often tenned "captive reinsurmice." Farther: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund. (b) Any such agreements will not affect the rights Borrower It If any —with respect to the Mortgage Insurance under the Homeowners Protection Act of 1.998 or any other law. These rights may include the right to receive certain disclosures., to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and /or to receive a refund of any Mortgage Insurance premiums that were unearned at the time of such cancellation or termination. 11. Assignment of :Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. If die Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction. provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to he paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would be lessened. the Miscellaneous Proceeds shall be applied to the sums secured by this Security Iasinuttent. whether or not then due, with the KNNSYLVANIA— Single Fundy Fannie Ntae/Fmittie Ntac t'NIFOR.NI INSTRUMENT Form 3039 U01 tit. (W1 MERS Wj �e 4., lA GREATLIWD! STEM T276 MD j lu,;ra To0^6erh: t60a63a- 93930ra■ 6t6.741-tt31 i excess, if any, paid to Borrower. Stich Miscellaneous Proceeds shall be applied in the order provided for in Section 2. Iu the event of a total taking, destruction, or loss in value of the Properly, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if arty, paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market j value of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Security instrument immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following faction: (a) the total amount of the sums secured immediately before die partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market _ value of the Property immediately before die partial taking, destruction, or loss in value is less than the amount of the stuns secured immediately before the partial taking, destruction, or loss in value. unless Borrower and lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Panty" meatus the third party that owes Borrower Miscellaneous Proceeds or the patty against whom Borrower has a right of action in regard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's judgment, could rrsult in forfeiture of the Property or other material impaimment of Lender's interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred. reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a riling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. Tlhe proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. It Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the tittle for payment or modification of amortization of the suns secured by this Security Instrument granted by Lender to Born>wLr or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sunhs secured by this Security Instrument by reason of any dematnd made by the original Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exercising :mv right or remedy including, without limitation, Lender s acceptance of payments from third persons, entities or Successors in hmterest of Boruwer Iw in amounts less than the amount then due. shall not be a waiver of or preclude the exercise of any right or remedy. - - - PENNSYLVANIA— Siiigle Family Fannte Mae/Fredtdie Ntac UNIFORM INSTRUMENT Fount.W9 1101 GREATLAND ■ rTFM 727601.10 MI 11 --MERS Warr l0a•(Ih/u; tar To Mar Gtl 600.53D.9393OFax 616- 791-1131 13. Joint and Several Liability; Co- signets; Successors and Assigns Bound. Borrower covenants and agrees that Borrower's obligations and liability shalt be joint and several. However, any Borrower who co-sigus this Security Instrument but does not execute the Note (a "co-signer'): (a) is co- signing this Security Instrument only to mortgage, grant and convey the co-signers interest in the Property under the temps of this Security Instrument: (b) is not personally obligated to pay the sums secured by this Security Instrument: and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or snake any accommodations with regard to the temts of this Security Instrument or the Note without the co- signer's consent. Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security instrument. Borrower shall not be released front Borrower's obligations and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services perfomned in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security Instrunnent to charge a specific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees Ihat are expressly prohibited by this Security Instrument or by Applicable Law. If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted limits. then_ (a) any such loan charge shall be reduced by the antonnt necessary to reduce the charge to the pennitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this reftund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 15. Notices. All notices given by Borrower or Lender in connection with lids Security Instrument must he in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been given to Borrower when mailed by first class snail or when actually delivered to Borrower's notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designates) a substitute notice address by notice to Lender. Borrower shall limntptly notify Lender of Borrowers change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower sliall only report a change of address through that specified procedure. There may be only one designated notice address under this Security instrument at any one titue. Any notice to Lender shall be given by delivering it or by mailing it by first class snail to Lender's address stated herein unless Lender has designated anollier address by notice to Borrower. Any notice in connection with this Security Instrument shall not be deenned to bare been given to Lender until actually received by Lender. If any notice required by this Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy Cite cormsponding requirement under this Security Instrument. 16. Governing Law; Severability; Rules of Construction. This Security instrument shall be - - — governed by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations contained in this Security Instrument are subject to any requirements and limitations of PIENNSYt.V.t,.NL1— Sutgle Family Fannie StneNreddle llac UNIFORM INSTRUMENT Form J039 1101 GREATLAND ■ ITEM T2760Ui t00i t> --MERS II1 -tM jklee,I 700raer Ga 14DD- 670- 9393E3FOP 616•.974131 Applicable Law. Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a prohibition against agreement by contract. ht the event that any provision or clause of this Security h►strunent or the Mote conflicts with Applicable Law, such conflict shall not affect other provisions of this Security instrument or the Note which can be given effect without the conflicting provision. As used in this Security Instrument: (a) words of the masculine gender shall mean and include corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take any action. 17. Borrower's Copy. Borrower shall be given one copy of die Note and of this Security Instrument. 18. Transfer of the Property or a Beneficial Interest In Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lenders prior written consent. Lender may require immediate payment in fill] of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower nwst pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand oil Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security instrument discontinued at any time prior to the earliest of: (a) fiNe days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the tennination of Borrower's right to reinstate: or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrmnent, including, bill not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lenders interest in the Property and rights tinder this Security Instrument, and Borrower's obligation to pay the shuns secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses inn one or more of the following fornis. as selected by Lender: (a) cash; (b) money order, (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instnnnentalily or entity; or (d) Electronic Fronds Trannsfer. Upon reinstalement by Borrower, this &-curity Instnnneut and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer: Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more limes without prior notice to Borrower. A sale resultin a change ill the entity (known as the "Lmm Seniccr') that collects Periodic Payments doe tinder the Nute and this Security Instrument and performs other mortgage loan servicing PFrWS\'L \'AWL\ tingle F. utnh Fannie \iaeJFreddie .\lac UNIFORM 1NSTRt :\LE \"1' Form .1039 1/01 a12 (001 t n-MERS r Pact 11 . • GR�T7 ITEM T276 91- 0 f J4 pJ;r +1 To Ober Ca: t- fi0a53o-93936Fa. fi'fi -791 -1131 obligations under the Note, (Iris Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Sen•icer unrelated to a sale of the :dote. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name acid address of the new Loan Servicer. the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the ;Tote, the mortgage loan servicing obligations to Borrower will remain with the Lour Servicer or be Irartsferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of. this Security instrument, until such Borrower or Lender has notified the other parry (with such notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the otter party hereto a reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time period which nu►st elapse before certain action can be taken, that time period will be deemed to -be- reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall he deettned to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21:. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, or wastes by Environutental Law and the following substances: gasoline, kerosene, other flattnnable or toxic petroleum products, toxic pesticides acid herbicides, volatile solvents, materials containing asbestos or fonualdehyde, and radioactive materials;. (b) "Ettvironniental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (e) "Environmental Cleanup" includes any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup. Borrower shall not cause or permit the presence, use. disposal, storage, or release of any Hazardous Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Enviromnental Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences shall not apply to the presence. use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property (including, but not limited to, hazardous substances in consumer products). Borrower shall promptly give Lender written notice of (a) any investigation, claim, deunand, lawsuit or other action by any governmental or regulatory agency or private patty involving the Property and any H.•v-arduits Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition. including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance. and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. If Borrower learns. or is notified by any govennnienlal or regulatory authority. or any private party. that any renioNal or other rentediation of any Hatandous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. PEVNS!'L�'. \ \1.1 —Sm¢]r Fannl} Fannie Stae/Freddle lac tNIFORII INSTRVINIENT Form i0 S9 1f01 GRn_ATLAMD ■ ITEM T276003 1001 1} —MFRS Pj eV-1 M IaUufag 1 -M0- 530.9393OFa, 616 -:91 -1131 NON - UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert In the foreclosure proceeding the non - existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require Immediate payment In full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited lo, attorneys' fees and costs of title evidence to the extent permitted by Applicable I.aw. 23. Release. Upon payment of all stints secured by this Security Imstnu lent, this Security Instrument and the estate conveyed shall tenuinate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24, Waivers. Borrower, to the extent permitted by Applicable Law. waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption front attachment, levy and sale, and homestead exemmption. 25. Reinstatement Period. Borrower's tine to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property. this Security Instrument shall be a purchase money mortgage. 27. Interest Rate Alter Judgment. Borrower agrees that the interest gate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from tine to time tinder the Note. PEtititiFl.�'.> \[�— Siuelc Fuld} Fannie Jlae/Fml(lle .%Iae t'NIFOR-Nl INSTRt'ilE \T Form.1039 1/01 GAEATLAND ■ ITEM 72'.60.14 10011 --4ER5 'o Ordm G7 1- 809.530.93930%. 616 -'91-1131 BY SIGNING BELOW. Borrower accepts mid agrees to the tenns and covenants contained in pages through 16 of this Security Instnuneut and in any Rider executed by Borrower and reconted with it. (Seal) (Seal) Michael Finkey Borrower CHIN SUK FINKEY Borrower A. (Seal) (Seal) Bnrrower Borrower (Seal) (Seal) - BorroWer Borrower Witness: W i i nets: PENNSFLVANL\ —Smkte Fum % Fannie Vie/Fm1die \tic UNIFORM INSTRCStENT Form 33.19 tN11 GAEATLAt10 ■ ITEM T2 —MEn9 Wj to /j h5 ;xk Ta Cdu W6 1- 600-530- 9393OF3a 616-91 -1131 State of County of On this the � � day of \`L���� �1 before ine, � the undersigned officer. personally appeared known to me (or satisfactorily proved) to be the person(s) whose natlle(s) >-- subscribed to the within instrument and acknowledged that" —, executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set in hand ne►d official seal. COM&iONWEALTH OF PENNSYLVANIA NOTARIAL SEAL �L . CAROL L. TROXELL, Nc:ay Pjblic Title of Officer New Curnberlapd Boro. Cumberland Co. My Commission Expires DPC. 27. "r.9 .My commission expires: After Recording Return To: STONE, LAFAVER & SHEKLETSKI 414 BRIDGE STREET NEW CUMBERLAND , PA 17070 CERTIFICATE OF RESIDENCE f, �,� v? ►a Ste,"" t do hereby certify that the correct address of the within warned lender is 1417 North Magnolia Ave, Ocala, FL 34475 Witness any hand this day of n1 or txai<r PFNNSYLVANLI —SmKic FannI5 Fannie Staeffmictie Nlac UNIFORM INSTRUMENT Form 3639 1101 GREAILAND 11 ITEM T2760L16 00i t t. —HERS Wage 16 -/Ih ju;ri! To Order Ca71- 8Z536-9393QFu 616 "91 -1131 Lt-'UAL Ur-W -Kill' 1 W174 ALL THAT CERTAIN piece, parcel or tract of land sibaate in North M_ iddleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit BEGINNING at a point on the eastern right -of -way line of Long View (50 foot right -of -way, 32 , `fdot , cartway), said point being at the southwestern comer of Lot No. 4 on the hereinafter mentioned Plan of Lots; thence by Lot No. 4 North 78 degrees 11 minutes 47 seconds East a distance of 166.00 feet to a point at other lands of Fred A. Gettys; thence by other lands of Fred A. Gettys, South 11 degrees 48 minutes 13 seconds East a disfance of 100.00 feet to a point at Lot No. 2 in the hereinafter mentioned Plan of Lots; thence by Lot No. 2, South 78 degrees 11 minutes 47 seconds West a distance of 166.00 feet to a point at the eastern right -of -way line of Long View; thence by the eastern right -of -way line of Long View North 11 degrees 48 minutes 13 seconds West a distance of 100.00 feet to a point at Lot No. 4 in the hereinafter mentioned Plan of Lots, the point and place of BEGINNING BEING Lot No. 3 on a Final Subdivision Plan for North Ridge Phase VII, as recorded in Cumberland County Plan Book 90, Page 95. CONTAINING 16,600.00 square feet or 0.381 acres. UNDER AND SUBJECT to certain building and use restrictions recorded in Cumberland County Miscellaneous Book 716, Page 649. North Middleton Township Authority has indicated that lots within North Ridge Phase VII, with finished floors of /or greater than elevation 520 (MSL) may experience low water pressures; which may require individual lot pressure boosting pumping system be installed by the homeowner; especially with multistoried building units. BEING the same premises which FRED A. GETTYS AND YVONNE W. GETTYS, HUSBAND AND WIFE, by Deed dated December 21, 2005, and recorded January 10, 2006, in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, in Book 272, Page 3550, granted and conveyed unto CLASSIC COMMUNITIES CORPORATION, Grantor herein. ALSO BEING TH SAM PR MI ES which Classis Communities Corporation, a Pennsylvania corporation.by their Deed dated p ,2007 and about to be recorded in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, granted and conveyed unto Michael Finkey and Chin Suk Finkey, his wife, Mortgagors herein. Schedule A - Page 2 Commitment No. 28583FINKEY This commitment is invalid unless the Information Sheet and Schedules A and 8 are attached (Pagel of 3) Inst. # 201319862 - Page 1 of 3 CERTIFIED PROPERTY IDENTIFICATION NUMBERS 29 -06- 0019 -104 - NORTH MIDDLETON CCGIS REGISTRY 06/18/2013 BY TB Prepared By / Return To: E.Lance/NTC, 2100 Alt. 19 North, Palm Harbor, FL 34683 (800)346 -9152 Tax Code/PIN/UPI #: 29 -06- 0019 -104 I IIIIII I�II� VIII IIII I'lll IIII IIl�I IIII' (IIII II�'I IIII I��I ASSIGNMENT OF MORTGAGE FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the undersigned, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP., ITS SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS PO BOX 2026, FLINT, MI, 48501, (ASSIGNOR), (MERS Address: 1901 E Voorhees Street, Suite C, Danville, IL 61834) by these presents does convey, grant, assign, transfer and set over the described Mortgage therein to q ge � ther with all interest secured thereby, all liens, and an rights due or to become due thereon to NXff6NSTAR 1Vl ORTGAGE LLC, WHOSE ADDRESS IS 350 HIGI-�'LAND DRIVE, LEWISVILLE, TX 75067 (469)549 -2000. Said Mortgage dated 03/30/2007, in the amount of $280,000.00 made by MICHAEL A. FINKEY AND CHIN SUK FINKEY to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. AS NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP. recorded on, in the Oihce of the Recorder of Deeds of CUMBERLAND County, in the State of Pennsylvania, in Book 1988, Page 3047 and/or Document #. Property is more commonly known as: 220 LONG VIEW DRIVED TWP. OF NORTH MIDDLETON, CARLISLE, PA 17013. Dated this 13th day of June in the year 2013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR TAYLOR, BEAN & WMTAKER MORTGAGE CORP., ITS SUCCESSORS AND ASSIGNS By: �^ ANIEL THOMP ASST. SECRETXkY All Authorized Signatories whose signatures appear above are employed by NTC and have reviewed this document and supporting documentation prior to signing. NSDAV 20550220 -- NSDAV N1 MIN 100029500015967734 MERS PHONE 1- 888 - 679 -6377 DOCR T1313063509 [C] EFRMPAI 1 111111 (IIII VIII VIII VIII VIII (IIII VIII IIII IIII 1 1111111 IIII VIII illll VIII (IIII (IIII VIII (IIII VIII (IIII IIII IIII *D0001718695* EXHIBIT (Page;2lot:.31. Inst. # 201319862 - Page 2 of 3 1 111111 11111 IN 1 III I STATE OF FLORIDA COUNTY OF PINELLAS The foregoing instrument was acknowledged before me on this 13th day of June in the year 2013, by Daniel Thompson as ASST. SECRETARY for MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP., ITS SUCCESSORS AND ASSIGNS, who, as such ASST. SECRETARY being authorized to do so, executed the foregoing instrument for the purposes therein contained. He /she /they is (are) personally known to me. Nicole Baldwin Notary Public State of Florida � � My Commission 0 EE 722285 NICOLE BALDWIN - NOTARY PUBLIC Expires August 5, 2016 COMM EXPIRES: 08/05/2016 Assignment of Mo kaQe from: MO RTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NONUNEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP., ITS SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS PO BOX 2026, FLINT, MI, 48501, (ASSIGNOR), (MERS Address: 1901 E Voorhees Street, Suite C, Danville, IL 61834) to: NATIONSTAR MORTGAGE LLC, WHOSE ADDRESS IS 350 HIGHLAND DRIVE, LEWISVILLE, TX 75067(469)549 -2000 Mortgagor: MICHAEL A. FINKEY AND CHIN SUK FINKEY When Recorded Return To: Nationstar Mortgage LLC C/O NTC 2100 Alt. 19 North Palm Harbor, FL 34683 All that certain lot or piece of ground situated in Mortgage Premise: 220 LONG VIEW DRIVED TWP. OF NORTH MIDDLETON CARLISLE, PA 17013 CUMBERLAND (Borough or Township, if stated), Commonwealth of Pennsylvania. Being more particularly described in said Mortgage. Certificate of Residence I, Daniel Thompson, do certify that the precise address of the within named Assignee is: NATIONSTAR MORTGAGE LLC, WHOSE ADDRESS IS 350 HIGHLAND DRIVE, LEWISVILLE, TX 75067(469)549 -2000 15 ANIEL TROMP ASST. SECRET .&Y All Authorized Signatories whose signatures appear above are employed by NTC and have reviewed this document and supporting documentation prior to signing. *20550220* NSDAV 20550220 -- NSDAV N1 MIN 100029500015967734 MERS PHONE 1- 888 - 679 -6377 DOCR T1313063509 [C] EFRMPAI 11111111111111111111111111111111111111111111111111 1 1111111 IIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIII IIII *D0001718695* (Page 3 of 3) Inst. # 201319862 - Page 3 of 3 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY, 1 COURTHOUSE SQUARE -.<:... CARLISLE, PA 17013 717 -240 -6370 Instrument Number - 201319862 Recorded On 6/18/2013 At 8:26:43 AM • Total Pages - 3 • Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 139560 User ID - SW • Mortgagor - FINKEY, MICHAEL A "Mortgagee - NATIONSTAR MORTGAGE LLC • Customer - SIMPLIFILE LC &RECORDING * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $12.00 RECORDER OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $56.00 I Certify this to be recorded in Cumberland County PA �p curge / S y 9 O . : t RECORDER OF DEEDS 1750 - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. STERN & EISENBERG, PC 410 THE PAVILION 261 OLD YORK ROAD JENKINTOWN, PA 19046 (215) 572 -8111 Date: April 5, 2013 COMBINED NOTICE UNDER ACT 6 and ACT 91 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDI IIR SU HIPOTECA. EXHIBIT G HOMEOWNER'S NAME(S): Michael A. Finkey PROPERTY ADDRESS: 220 Long View, Carlisle, PA 17013. MAILING ADDRESS: 220 Long View, Carlisle, PA 17013 -8703 LOAN ACCT. NO.: _ ORIGINAL LENDER: MFRS, Inc., as nominee for Taylor, Bean & Whitaker Mortgage Corp. CURRENT LENDER/SERVICER: Ocwen Loan Servicing, LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND X 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 (plus three (3) days for mailing) from the date of this Notice. During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT AP PLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender inu 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.) If you have tried and are unable to resolve this problem with the lender, 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. Your application MUST be filed or postmarked within thirty (30) days of your face -to -face meeting. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your° application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR 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 lender on your property located at: 220 Long View, Carlisle, PA. IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following montlis and the following amounts are now past due: Monthly payments from March 1, 2012 through and including April 5, 2013 as follows: Payments of $2,693.47 due on 03/01/2012 through and including 04/01/2013, inthe amount of ................. ............................... .....................$37,708.58 Other charges (explain/itemize): Latecharges:. ..................................... ............................... ......$1,504.33 Feesbilled ................................... ............................... ............$196.50 Other charges ( explain) . ............................... ....................:.....$0.00 Lesssuspense .................. ............................... ........................$370.41 TOTAL AMOUNT PAST DUE: .................................................... $39,039.00 B. Reserved for items other than amounts set forth in A. above. HOW TO CURE THE DEFAULT - -You may cure the default within THIRTY -THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $39,039.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made Payable and sent to: Ocwen P.O. Box 6440 Carol Stream, IL 60197 -6440 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged p ro p erty. 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 tl e delinquency bef6re - the lender legal proceedings against you; will still be -- required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYS period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other stuns due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paing total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Ocwen Loan Servicing, LLC Address: P.O. Box 6440 Carol Stream, IL 60197 -6440 Phone Number: 800 - 310 -9229 407 - 737 -6300 (fax number) Contact Person: Performing Collections Dept./Loss Mitigation Department EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION 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 costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (See Attached Page) Sincerely, STERN & EISENBERG, PC BY: je PC VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND REGULAR MAIL NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES 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. r a� — _ Gompr�ernensiue Housing at;Ir Counseling Agencies A HQ Agencias de Consejo al C lie Me pars Yivienda Cumberland County `CCCS of Western PA -York 55 Claver Hill Road Dallastavn PA 17313 888.511.2227 7 888.5112227 tiin�nvcrrsua.oro Community Action Commission - Capital Region 1514 Derry St Harrishurzi PA 17104 717232 A?5? wuntcact ri rr =u niv.oro Harrisburg Fair Housing Council 2100 N 6th St Harrishurg PA 17118 717238 ?540 Housing & RedevelopmentAidhority- Cumberland Cnty 114 N HanoverSt; S7E 104 CarfsL PA 17013 866.683.5907 7 71 ? 249.0789 w" CChra:Cam Pathstone Corporation Pennsylvarlia 1625 Narth Second St Harrishurg PA 17102 ?1 ?234.6616 - Awny ri, n li- o w1ph_theLne .f 11 Pennsylvania Interfaith Community Programs, Inc, 40 E High St Gettysburg PA 17325 ?1 ?.334.1518 Wmwadamscha.an l NOTE Many of the agencies offer workshops at various location sites; call to find a location near you Report last updated: 4730/2012 9:{)3:04 AM Page 1 of 1 STERN & EISENBERG, PC 410 THE PAVILION 261 OLD YORK ROAD JENKINTOWN, PA 19046 (215) 572 -8111 Date: April 5, 2013 COMBINED NOTICE UNDER ACT 6 and ACT 91 TAKE ACTION TO SAVE YOUR DOME FROM FORECLOSURE This is an official notice that the mortgage on your home . is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Chin Suk Finkey PROPERTY ADDRESS: 220 Long View, Carlisle, PA 17013. MAILING ADDRESS: 220 Long View, Carlisle, PA 17013 -8703 LOAN ACCT. NO.:-� ORIGINAL LENDER: MERS, Inc., as nominee for Taylor, Bean & Whitaker Mortgage Corp. CURRENT LENDERISERVICER: Ocwen Loan Servicing, LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, x 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 (plus three (3) days for mailing) from the date of this Notice. During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) if you have tried and are unable to resolve this problem with the lender, 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. Your application MUST be filed or postmarked within thirty (30) days of your face -to -face meeting. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. A GENCYACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR 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 lender on your property located at: 220 Long View, Carlisle, PA. IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments from March 1, 2012 through and including April 5, 2013 as follows: Payments of $2,693.47 due on 03/01/2012 through and including 04/01/2013, inthe amount of ................. ............................... .....................$37,708.58 Other charges (explain/itemize): Late charges: .......................................................................... $1,504.33 Feesbilled .......................... ............................... .....................$196.50 Other charges ( explain) . ............................... ..........................$0.00 Lesssuspense .................. ............................... ........................$370.41 TOTAL AMOUNT PAST DUE: .................................................... $39,039.00 B. Reserved for items other than amounts set forth in A. above. HOW TO CURE THE DEFAULT - -You may cure the default within THIRTY -THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $39,039.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check certified check or money order made payable and sent to: Ocwen P.O. Box 6440 Carol Stream, IL 60197 -6440 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rilzhts to accelerate the mortgalZe 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 p roperty. IF THE MORTGAGE IS FORECLOSED UPON --The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYS period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs comnected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing aliy other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST 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 four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Ocwen Loan Servicing, LLC Address: P.O. Box 6440 Carol Stream, IL 60197 -6440 Phone Number: 800 - 310 -9229 407- 737 -6300 (fax number) Contact Person: Performing Collections Dept./Loss Mitigation Department EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION 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 costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (See Attached Page) Sincerely, STERN & EISENBERG, PC BY: tern & Eisenberg, PC VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND REGULAR MAIL NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES 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 LETTERINOTICE 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. Pt i �. Comprehensive Housing �f 4i _{ : : .,¢ ur.LI r ,L Counseling Agencies Agencias de Consajo at Clients para Vivienda Cumberland County "CCCS &Wlestem PA -York 55 Claver Hill Road Dallastown PA 17313 888.511.222 71 888.5112227 tSrsN•J.�'tJ.:S 0a.4fQ Cam rrl un ity Action Commission -Capital Regio n 1514 Derry St Harrisburg PA 1 ?104 717232.9757 x�nnrca.:tricxu n tv.4ro Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing & RedevtFapmentAirthorify- Cumberland Cray 114 N HanoverSt; STE 104 CarlisL PA 17013 866.683.590 71717.249.0 ?89 wxavicehr .e4m Pafhstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 ?'17234.6616 ant's r+ rat' TM ny+rnath<tma pa htm Pennsyhrania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 1?325 717.334.1518 itMA?.aGan!P�ha.6(a NOTE Many arthe agencies offer war rshops at various Iocafion sites; call to find a location near you. Report last updated: 4130!2012 9:03:04 AIA Page 1 of 1 P V, ' 1 +1k U.S. POSTAGE >J PITNEY BOWES Name and STERN & EISENBERG Address 04 261 Old York Road -The Pavilion -Ste 410 y` ZIP 1904 $001-26 0 of Sender Jenkintown, PA 19046 t� 02 M t 0001371685 APR 05 2013 Line Article Postage Fee Number 1 * * ** Michael A. Finkey 220 Long View Po stal Carlisle, PA 17013 CERTIFIED MAIL. RECEIP 2 * * * * Chin Suk Finkey ' • Only, No Insurance Coverage P rovided) 220 Long View - For delimery visit our website at www.usps.comb Carlisle, PA 17013 `° =l 3 L uY Postage $ u'1 4 * * * * Certified Fee IL C3 Return Ret Fee Postmark Re 5 * * * * C3 (Endorsement Here C3 Restricted Delivery. Fee 6 * * * * PHFA C3 (Endorsement Required) PO BOX 8029 C3 Total Postage & Fees $ r-R HARRISBURG, PA 17105 -8029 7 to Sent To ,a C3 S . Chin Suk Finkey ------------------------ Street, - 8 * * * * or PO Box No. 220 Long View Ciry State, zrP +a - -" Carlisle, PA 17013 --------------------_- 9 * * ** PS Form 3800, August 2o66 See Reverse for Instructions tl Po stal CE 11 * * ** RTIFIE RECEI ( 12 c(3 For delivery in our website at vmw.usips.com 3 C E A ELM U * * * * Ln Postage $ 14 * * ** Lr a ni Certified Fee 73 .ff Postmark C3 Return Receipt Fee r (ere 15 RE: Finkey ACT NOTICE O (Endorsement Required) Restricted Delivery Fee `• Total Number of Total Number of Pieces Postm er, Pe o R g C3 (Endorsement Req [red) Pieces Listed b S d Received at Post Office Em 1� L] Total Postage & u Fees $ rR ru Sent To a Michael A. Finkey ---------------------- O Street, Apt. No.; 220 LO View or PO Box No. L 'City State, ziP +a Carlisle, PA 17013 PS,Fonn 3800, August 2006 See Reverse for Instructions i Nationstar Mortgage LLC Plaintiff IN THE COURT OF COMMON V. PLEAS OF CUMBERLAND Michael A. Finkey and Chin Suk Finkey COUNTY PENNSYLVANIA Defendant(s)' w` COMPLAINT IN f�T► ". MORTGAGE FORECLOSURES N P co 1 U J ( civil 7 � � -� NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of th is foreclosure action, you may be able to participate in a coup- 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 MidPerin Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative. you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. if you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and File a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. if you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However. you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto. you] 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. Resp to y bmi ed: Date: / ).' //V [Sig e o set or Plaintiff] Nationstar Mortgage LLC Plaintiff IN THE COURT OF COMMON V. PLEAS OF CUMBERLAND Michael A. Finkey and Chin Suk Finkey COUNTY, PENNSYLVANIA Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Adrnin.istrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage .Foreclosure Diversion. Program" and has taken. all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties 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: Gip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Gip: 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: Lnan Number- , 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 Mortgage Food 2 Mort a e Utilities Car Payment(s) Condo/Neigh, Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment i Install. Loan Payment Cable'F Child Su ort/Alim, Spending Mone Day/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 ❑ No [] If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for HomeoNvriers 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 F No (� If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan sere "icing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/Vl'e, , authorize the above named to use/refer this information to my lenderiservicer for the sole purpose of evaluating my financial situation for possible mortgage options, We understand that Ilwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements V Proof of any expected income for the last 45 days Copy of a current utility bill V 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 _ : 1?J� Sheriff `Y THE t'i O i HOHO Ir ".` ti3 '4�r ,)1 I i,.BTlid i`d{PY k 0 Jody S Smith '. J Chief Deputy 2014 FEB I I [II .s I Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Nationstar Mortgage LLC vs. Case Number Michael A Finkey(et al.) 2014-549 SHERIFF'S RETURN OF SERVICE 02/06/2014 09:31 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Chin Suk Finkey, Wife, who accepted as"Adult Person in Charge"for Michael A Finkey at 220 Long View Drive, North Middl-ton Carlisle, PA 17013. •ZIdt.100r,! GUTS-ALL, DEPUTY 02/06/2014 09:31 AM - Deputy Shawn Gutshall, 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: Chin Suk Finkey at 220 Long View Drive, North Middleton, Carlisle, PA 17013. Ira// GUTSHALL, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, February 07, 2014 RONNY R ANDERSON, SHERIFF 1 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 Civil Action Number: 14-549 OFF1 1 THE 1110ND FA 20111 MAR 19 A.1110: 3 CUMBERLAND COUNTY PENNSYLVANIA Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Michael A. Finkey and Chin Suk Finkey, for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE $262,805.19 INTEREST accrued thru 01/15/2014 of $33,396.40 Interest after 01/15/2014 shall accrue at the per diem rate of $46.80.) ESCROWADVANCES......... ..... ..... . ............. ............ .................... ............. $15,248.30 CORPORATE ADVANCES $275.50 FORBEARANCE ($370.41) Sub-Total Through Date of Complaint $311,354.98 ACCRUED INTEREST after 01/15/2014 shall accrue at the per diem rate of $46.80 to March 18, 2014 $2,901.60 TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT $314,256.58 BY: El S ERG, ESQUIRE El M. TROY FREEDMAN, ESQUIRE El JACQUELINE F. McNALLY, ESQUIRE o ,LESLIE J. RASE, ESQUIRE Q' CHRISTINA C. VIOLA, ESQUIRE El ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff 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 Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14 -549 MORTGAGE FORECLOSURE AFFIDAVIT OF NON- MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS SS I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants': Last -known address is: 220 Long View Drive, Carlisle, PA 17013 2. Is over the age of twenty-one. 3. Michael A. Finkey is not 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. A search could not be performed for Chin Suk Finkey, as not enough identifiable information is available to yield accurate results. RG, PC Swo t is Nota Q a d subscribed before me vay of 1 ❑ K. NBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE • CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Public Department of Defense Manpower Data Center Results as of : Mar-18-2014 06:36:04 AM SCRA 3.0 Status Report Pursuant to Servieemembers Civil, Relief Act Last Name: FINKEY First Name: MICHAEL Middle Name: Active Duty Status As Of: Mar-18-2014 On Active Duty On Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA NA . No NA This response reflects the Individuals active duty status beed 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 NA No NA This response reflects ere the Individual left active duly status within 367 days preceding the Active Duty Status Date The Member or His Mer Unit Wes Notified of a Future Call-Up to Active Duty on Active Duty Status Data 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 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 & EISEENBERG, 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 Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14 -549 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: ❑ S . EI ENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff STERN & EISENBERG PC THE SHOPS AT VALLEY SQUARE 1581 MAIN STREET, SUITE 200 WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nationstar Mortgage LLC (Plaintiff) v. Michael A. Finkey and Chin Suk Finkey (Defendant(s) TO: Michael A. Finkey 220 Long View Drive Carlisle, PA 17013 Docket #: 14 -549 TEN DAY NOTICE NOTICE PURSUANT TO Pa.R.C.P. 237.1 Date of Notice: Friday, February 28, 2014 Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 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 :Warn yntl0 Day,Noticcs \Cumberland County\Nationstar.Finkey.2.28.14:docz ST E' : -ISEN:: RG r Attorney for Plaintiff 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 Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14 -549 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: ST RG, PC ❑ STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff 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 Nationstar Mortgage LLC V. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14-549 MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 (Plaintiff) Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 (Defendant(s)) BY: ERG, PC O S K. EISENBERG, ESQUIRE O M. TROY FREEDMAN, ESQUIRE O JACQUELINE F. McNALLY, ESQUIRE O LESLIE J. RASE, ESQUIRE }2(CHRISTINA C. VIOLA, ESQUIRE 0 ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ,•- PRAECIPE FOR WRIT OF EXECUTION Nationstar Mortgage LLC Plaintiff VS. Michael A. Finkey and Chin Suk Finkey Defendant Address: 220 Long View Drive Carlisle, PA 17013 ❑ Confessed Judgment ❑ Other File No. 14 -549 Amount Due 314,256.58 Interest 3/19/14- 9/3/14 Atty's Comm @ $46.80 per diem = $7,862.40 Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original 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) 220 Long View Drive, Carlisle, PA 17013 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 defendant(s)described in the attached exhibit. Date 3/18/14 Signature: GoikAl 6 (22. 5bc1 £ thi ,su C t avto. 1 Print Name: Address: Attorney for: Telephone: Supreme Court ID No: 308909 pe de t in a' estate of the Christina C. Viola, Esq. 1.581 Main St., Ste 200 Warrington, PA 18976 PIaintiff 215 - 572 -8111 1A-1/1 616 1P- CD �.�f c ALL THAT CERTAIN piece, parce or tract of land situate inliorth tv.licidleton Township, Cumberland County, Pennsylvania, bounded and described as foflows, to wit BEGINNING at a point on the eastem fine of Long View (50 foot 32-foot cartway), said point being at the southwestern comer of Lot No, 4 on the hereinafter mentioned Plan of Lots; thence by Lot No. 4 North 78 degrees 11 minutes 47 seconds East a distance of 166.00 feet to a point at o(her lands of Fred A. Gettys; thence by other tarids of Fred A. Gettys, South 11 degrees 48 minutes 13 seconds East aciislancmof1D8.80 feet bno point mt Lot No. 2in the the hereinafter mentoned Plan of Lots; thence by Lot No. 2, South 78 degrees 11 minutes 47 seconds West a distance of 166.00 feet to a point at the eastern right-of-way line of Long View; thence by the eastern right-of-way line of Long View North 11 degrees 48 minutes 13 seconds West a distance of 100'00 feet to a point at Lot No. 4 in the hereinafter mentioned Plan of Lots, the point and place of BEGINNING BEING Lot No. 3 on a Final Subdivision Plan for North Ridge Phase VII, as recorded in Cumberland County Plan Book 90, Page 95. CONTAINING 1G.GOD.0O square feet nrO.381acres. UNDER AND SUBJECT to certain building and use restrictions recorded in Cumberland County Miscellaneous Book 716, Page 649. North Middleton Township Authority has indicated that lots within North Ridge Phase VII, with finished floors of/or greater than elevation 520 (MSL) may experience low water pressures; which may require individual lot pressure boosting pumping system be installed by the homeowner, especially with multistoried buliding units. BEING Parcel No. 29-06-0019-104 BEING known as 220 Long View Drive, Carlisle, PA 170I3 ALSO BEING TRE,SAMEIPREVIISES which Classis Communities Corooration. a Pennsylvania coro.oration.bv and 'conveyd unto Michael A. Finkey and Chin Suk Finkey Schedule a' Page c Commitment No. u135u3F/mxsr This commitment a invalid unless the |nfotmzmm Sheet and Schedules A and 13 are attached 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) PCIT/1.01}it) 20/4 /4111R 19 4H10; 33 vtisERcAlito couiv PEViS LVANIA IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action 14-549 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 220 Long View Drive, Carlisle, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s): Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Michael A. Finkey and Chin Suk Finkey 220 Long View Drive 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: N/A 4. Name and address of the last recorded holder of every mortgage of record: 21st Mortgage Corp. P.O. Box 477 Knoxville, TN 37901 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: North Ridge II Homeowners Assoc.. Carlisle, PA 17013 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) 220 Long View Drive Carlisle, PA, 17013 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: �\Lk BERG, PC ENS NA °f,F P�aNQ�bo�! � v o,; • bet -s' ' 5G: 0�4*N�•,r��0" My c Swo t subscribed before me this 0 Day ofl\Th. 4 filotary Public E EN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE .(CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff 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) . } II ITAR /9 41'9 /0: 33 C 'UEFA A PEN, S YL VA NIUr �; y, IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14 -549 MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 Your real estate at 220 Long View Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 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 $314,256.58 obtained by Nationstar Mortgage LLC 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 STEVEN K. EI'SENBERG, ESQUIRE (75736) M. TIwY 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 Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14 -549 MORTGAGE FORECLOSURE RE: PREMISES: 220 Long View Drive, Carlisle, PA 17013 Dear Sir or Madam: Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, September 3, 2014 at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice). The sale is being conducted pursuant to the judgment in the amount of $314,256.58 together with interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above -named Defendant(s) who is /are also the real owner of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff' s Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. BY: S BERG, PC ❑ -N K. 'ISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE • JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ,Et CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE LLC Plaintiff (s) From MICHAEL A. FINKEY AND CHIN SUK FINKEY (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: NO. 14 -549 Civil CIVIL ACTION — LAW and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he /she has been added as a garnishee and is enjoined as above stated. Amount Due: $314,256.58 L.L.: 5.50 Interest 3/19/2014- 9/3/2014 Atty's Comm: @$46.80 PER DIEM - $7,862.40 Due Prothy: $2.25 Atty Paid: $206.31 Other Costs: Plaintiff Paid: Date: 3/19/2014 (Seal) REQUESTING PARTY: Name: CHRISTINA C. VIOLA, ESQUIRE Address: STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PA 18976 Attorney for: PLAINTIFF Telephone: 215- 572 -8111 Supreme Court ID No. 308909 David D. B ,-11, Prothonotary Deputy Ronny R Sanderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r ` � a?" 'sn7 i lit JUN 20 Ali 9: 52 CUMBERLAND COUNTY PENNSYLVANIA Nationstar Mortgage LLC vs. Michael A Finkey (et al.) Case Number 2014-549 SHERIFF'S RETURN OF SERVICE 06/10/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $110.41 SO ANSWERS, June 10, 2014 c) Gounh6u: e j:`ler,ff. teIeOSoft, knc. RONNR ANDERSON, SHERIFF 07, G26" iod a_41 9‘f ,-307 536, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVA ,vo C2.553 Cr) CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Nationstar Mortgage LLC . ❑ Confessed Judgment Plaintiff ❑ Other VS. . File No. 14-549 Michael A. Finkey and Chin Suk Finkey : Amount Due $314,256.58 Defendant Interest 3/19/14-12/3/14 Address: Atty's Comm @ $46.80 per diem until Judgment is 220 Long View Drive Costs Carlisle, PA 17013 TO THE PROTHONOTARY OF THE SAID COURT: paid in full The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original 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 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) 220 Long View Drive, Carlisle, PA 17013 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 a: ainst r- - ate •. the defendant(s) described in the attached exhibit. Date 07/23/2014 Signature: Print Name: az a F so; d a Address: 5 -?.562 Warrington, PA 18976 k0 . `'{ 1 t t c' Attorney for: Stern & Eisenberg, PC U S. -, S "k Telephone: (215) 572-8111 Andrew J . y.: rle , Es • 1581 Main Street, Suite 200 sc ttcy? e3 -6.P-- Pei � Su reme Court ID No: Alf NaCo g-41---"Iqoas 312314 bUtitl OF 2 mea All that certain pieces, parcel or tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Long View (50 foot right-of-way, 32 foot cartway), said point being the southwestern corner of Lot No. 4 on the hereinafter mentioned Plan of Lots; thence by Lot No. 4 North 78 degrees 11 minutes 47 seconds East, a distance of 166.00 feet to a point at other lands of Fred A. Gettys; thence by other lands of Fred A. Gettys, South 11 degrees 48 minutes 13 seconds East, a distance of 100.00 feet to a point at Lot No. 2 in the hereinafter mentioned Plan of Lots; thence by Lot No. 2 South 78 degrees 11 minutes 47 seconds West, a distance of 166.00 feet to a point at the eastern right-of-way line of Long View; thence by the eastern right-of-way of Long View North 11 degrees 48 minutes 13 seconds West, a distance of 100.00 feet to a point at Lot No. 4 in the hereinafter mentioned Plan of Lots, the point and place of beginning. Being Lot No. 3 on a Final Subdivision Plan for North Ridge Phase VII, as recorded in Cumberland County Plan Book 90, Page 95. Containing 16,000.00 square feet or 0.367 acres. Being known as 220 Long View Drive, Carlisle, PA 17013 Being Cumberland County Parcel No. 29-06-0019-104 Under and subject to certain building and use restrictions recorded in Cumberland County Miscellaneous Book 716, Page 649. North Middleton Township Authority has indicated that lots within North Ridge Phase VII, with finished floors of/or greater then elevation 520 (MSL) may experience low water pressures; which may require individual lot pressure boosting pumping system be installed by the homeowner; especially with multistoried building units. Fee Simple Title Vested in Michael A. Finkey and Chin Suk Finkey, husband and wife by deed from Classic Communities Corporation, dated March 28, 2007, recorded April 13, 2007, in the Cumberland County Clerk's Office in Deed Book 279, Page 2910. 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) L' rr E L, THE PRO,H©.N,' 1TA 2914 JUL 25 A 6 I1; 23 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action 14-549 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 220 Long View Drive, Carlisle, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s): Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Michael A. Finkey and Chin Suk Finkey 220 Long View Drive 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: N/A 4. Name and address of the last recorded holder of every mortgage of record: 21st Mortgage Corp. P.O. Box 477 Knoxville, TN 37901 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: North Ridge II Homeowners Assoc. Carlisle, PA 17013 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) 220 Long View Drive Carlisle, PA, 17013 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: Sworn t subscribed before me thi ay of �;�,'.i , 2014 otary Public U STE ❑ :`` E EN K. EIS O M. TROY FRE O JACQUELIN O LESLIE J. RG, ESQUIRE AN, ESQUIRE cNALLY, ESQUIRE , ESQUIRE D -'ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff All that certain pieces, parcel or tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Long View (50 foot right-of-way, 32 foot cartway), said point being the southwestern corner of Lot No. 4 on the hereinafter mentioned Plan of Lots; thence by Lot No. 4 North 78 degrees 11 minutes 47 seconds East, a distance of 166.00 feet to a point at other lands of Fred A. Gettys; thence by other lands of Fred A. Gettys, South 11 degrees 48 minutes 13 seconds East, a distance of 100.00 feet to a point at Lot No. 2 in the hereinafter mentioned Plan of Lots; thence by Lot. No. 2 South 78 degrees 11 minutes 47 seconds West, a distance of 166.00 feet to a point at the eastern right-of-way line of Long View; thence by the eastern right-of-way of Long View North 11 degrees 48 minutes 13 seconds West, a distance of 100.00 feet to a point at Lot No. 4 in the hereinafter mentioned Plan of Lots, the point and place of beginning. Being Lot No. 3 on a Final Subdivision Plan for North Ridge Phase VII, as recorded in Cumberland County Plan Book 90, Page 95. Containing 16,000.00 square feet or 0.367 acres. Being known as 220 Long View Drive, Carlisle, PA 17013 Being Cumberland County Parcel No. 29-06-0019-104 Under and subject to certain building and use restrictions recorded in Cumberland County Miscellaneous Book 716, Page 649. North Middleton Township Authority has indicated that lots within North Ridge Phase VII, with finished floors of/or greater then elevation 520 (MSL) may experience low water pressures; which may require individual lot pressure boosting pumping system be installed by the homeowner; especially with multistoried building units. Fee Simple Title Vested in Michael A. Finkey and Chin Suk Finkey, husband and wife by deed from Classic Communities Corporation, dated March 28, 2007, recorded April 13, 2007, in the Cumberland County Clerk's Office in Deed Book 279, Page 2910. 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 Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14-549 MORTGAGE FORECLOSURE RE: PREMISES: 220 Long View Drive, Carlisle, PA 17013 Dear Sir or Madam: Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, December 3, 2014.at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice). The sale is being conducted pursuant to the judgment in the amount of $314,256.58 together with interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff' s Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. BY: ❑ EVEN EI; NBERG, ESQUIRE ❑ M. TROY . ' EDMAN, ESQUIRE ❑ JACQUEj) E F. McNALLY, ESQUIRE ❑},ESLIE 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) L./ y `- 1I L D 2014 JUL 25 111: PENNS Y1 ANIUl�T Y IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14-549 MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michael A. Finkey and Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 Your real estate at 220 Long View Drive, Carlisle, PA 17013 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 $314,256.58 obtained by Nationstar Mortgage LLC 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 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 NATIONSTAR MORTGAGE LLC Vs. NO 14-549 Civil Term CIVIL ACTION — LAW MICHAEL A. FINKEY AND CHIN SUK FINKEY 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: $314,256.58 L.L.: Interest 3/19/14-12/3/14 Atty's Comm:@ $46.80 PER DIEM UNTIL JUDGMENT IS PAID IN FULL Due Prothy: $2.25 Atty Paid: $345.22 Plaintiff Paid: Date: 7/25/14 Other Costs: David D. Buell, Prothonotary (Seal) B,L eQ� 67720?Viacj Deputy 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 2 CIVIL ACTION -LAW c.nr- -<> CT) EDWARD J. McKEE, ESQUIRE STERN AND EISENBERG, PC 1581 Main Street, Suite 200 Warrington, PA 18976 (215) 572-8111 I.D. #316721 Nationstar Mortgage LLC Plaintiff(s) v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14-549 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 the Defendant(s) by certified mail, return receipt requested and regular, first-class, postage prepaktmail on September 25, 2014. I further certify that notice of the Sheriff's 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. STERN AND E SENBERG, PC EDWARD J. McKEE Attorney for Plaintiff 9/26/14 'lame and add ress f Sender STERN & EISENBERG 1581 Main Street, Suite 200 Warrin2ton. PA Line Article Number Name of Addressee, Street, and Post Office Address 1**** Michael A. Finkey 220 Long View Drive Carlisle, PA 17013 2 **** Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 3 **** 21st Mortgage Corp. P.O. Box 477 Knoxville, TN 37901 4 **** North Ridge 11 Homeowners Assoc. Carlisle, PA 17013 5 **** PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 6 **** Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 7 **** Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 a 8c **** Tenant(s)/Occupant(s) 220 Long View Drive Carlisle, PA, 17013 c c RE:Nationstar -Finkey -NOS Lr Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Employee) ru ru m r-1 tr t.r) GERTIFIED MAILTM RECEIPT (Domestic MatliOilly; No Insurance Covera e Provl ed) Earge1176)5ZinfOlffiiitieikiiiiMoVeaildrat, Postage Certified Fee Return Receipt Fee E3 (Endorsement Required) Restricted Delivery Fee c (Endorsement Required) Uj rU Total Postage & Fees rij m r -i rj Sent To P 38O0 riijr WMA -IL REGE (pqmesliclillati.Only0fo nsuranc_e,c_overage Provided) RE6r;thilhipliltfitcTFInliticiiartiOurA e6S1t,fitWwwirsfiCcomo w rn oa co co r- r•-• CO 0 (Nt o Nao Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Here Form 3800 August2006 EDWARD J. McKEE, ESQUIRE STERN & EISENBERG, PC 1581 Main Street, Suite 200 The Shops at Valley Square Warrington, PA 18976 (215) 572-8111 I.D. #316721 Eat -UF F ICE CIF THE PRO1HONOTia-, 2014 OCT -9 PM 12: L7 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW Nationstar Mortgage LLC v. Michael A. Finkey and Chin Suk Finkey Defendant(s) Civil Action: 14-549 CERTIFICATE OF SERVICE I, EDWARD J. McKEE, attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Michael A. Finkey and Chin Suk Finey, by certified mail, return receipt requested on September 25, 2014 and received by the Defendants on October 3, 2014, as evidenced by copy of certified mail receipts and signed green card attached. 10/7/14 STERN & EISENBERG PC BY: EP ARD J. McKEE Attorney for Plaintiff ;.j SENDER: COMPLETE THIS SECTIO TE 7N/S SECTION ON DELIVERY a Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front If space permits. 0 Agent 0 Addressee 1. Article Addressed to: C,\(\i1\ Sup- C\nk aaa U \c %-.W ‘te CSV \\S\ -e, \-10V)) B. Received by (Printed Name) e of Delivery D. Is delivery address different from item If YES, enter delivery address below: Cl No pi ci4 pA (70sd Service Type Certified Mail® 0 Priority Mail Express' 0 Registered (*Return Receipt for Merchandise 0 Insured Mail 0 Collect on Delivery 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Arti 7013 2250 0000 5940 0431 (Tra,.,,,, iav,.. # .W: ov PS Form 3811, July 2013 Domestic Retum Receipt SENDER COMP E THIS. SECTION • Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 'aab Wrq COY \'e, p:; 1-10i� • `,:C oMPLErEITH,ssECTION ON•DELIVERY:. ' natur X Received by (Printed Name) Agent address D. Is delivery address triifle If YES, enter delivery address 3. Service Type Certified Mail® 0 Priority Ma 0 Registered $ Return Receipt for Merc ❑ Insured Mall 0 Collect on Delivery ndise 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article l 7013 2250 0000 5940 0424 (Transfs. ,a v„• oo+ rx.0 mum/ PS Form 381.1; July 2013 i r Domestic Return Receipt l' s and ess ider ine 1 2 3 4 5 wok Article Number STERN & EISENBERG 1581 Main Street, Suite 200 Warrington, PA 18976 Name of Addressee, Street, and Post Office Address ** * * ** * ** * * Michael A. Finkey 220 Long View Drive Carlisle, PA 17013 Chin Suk Finkey 220 Long View Drive Carlisle, PA 17013 21st Mortgage Corp. P.O. Box 477 Knoxville, TN 37901 North Ridge II Homeowners Assoc. Carlisle, PA 17013 6 7 8 * * * PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 Tenant(s)/Occupant(s) 220 Long View Drive Carlisle, PA, 17013 Total Number of Pieces Listed by Sender RE:Nationstar -Finkey -NOS Postmaster, Per (Name of Receiving Employee) Total Number of Pieces Received at Post Office rI m FT" Lri C7I Lfl ru ru m r -R ni r - CI C=I Ir Li" 1=1 U) ru ru rn r-9 r - U.S. Postal ServiceTM CERTIFIED MAILTM RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) For delivery Information visit our website.at,www.,usps.aome Postage Certified Fee Relum Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Fee Sent To V\r1 -kr) Street, Apt. No.; or PO Box No. CiLV State Z +4 1114 PS Form 3800, August 2006 U.S. Postal ServiceTM CERTIFIED MAILTM RECEIPT foomestiolfaxpniy; No Insurance Coverage provided) See Reverse for Instructio For iielivork Information vls!tbur websito.itt Acw,w.usps.ccime Postage Certified Fee Relum Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fee o.&p. Here 0) 0 0 Sent" t\X\ C\e\ ( Street, Apt. No.; or PO Box No. ..a.a State, IP Pi:Form 3800, August2006 N ltu.) r.3D See Reverse:for instructions pi tit 0 N • in Ce) op (.0 r - co 0 r -JN 0 o o t 11111111111