HomeMy WebLinkAbout05-0760
PHELAN HALLINAN & SCHMIEG, LLP
by: Michele M. Bradford, Esquire
Atty. LD. No. 69849
One Penn Center, Suite 1400
1617 John F. Kennedy Boulevard
Philadelphia, PA 19103-1814
(11~) ~()'l,-7{){){)
Deutsche Bank National Trust Company, as Trustee for
Vendee Mortgage Trust 2003-1, without recourse,
except as provided in a Pooling and Servicing Agrement
dated February I, 2003
7105 Corporate Drive
PIano, TX 75024
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
Plaintiff
vs.
Cumberland County
Richard L. Neenan a/k/a Richard L. Neenan, III.
Claramae R Neenan
And/Or Occupants
91 Cold Springs Road
Carlisle, PAl 70 13
Term
No. 05 -1~()
C;~,CT8L~
Defendants
CIVIl. ACTlON/COMPT A INT FOR RIFCTMRNT
RASRO ON AN TNSTAT.J.MFNT CONTRACT
FOR SAI.F OF RF.AJ. FSTATF
Please be advised that this firm is a debt collector attemptiug to collect a debt. Any information
received will be used for that purpose. If you have previously received a discharge in bankruptcy and
this debt was not reaffirmed, this correspondeuce is uot and should not be construed to be an attempt
to collect a debt, but only enforcement of a lien against property.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must
take action within twenty (20) days after this complaint and notice are served, by entering a written appearance
personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be
entered against you by the court without further notice for any money claimed in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, 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 ALA WYER, 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 Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
A VISO
Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo ai partir de la fecha de la demanda y la
notificacion. Hace falta asentar una comparencia escrita 0 en persona 0 con un abogado y entre gar a la
corte en forme escrita sus defensas 0 sus objenciones alas demanandas on contra de su persona. Sea
avisado que si usted no se dafiende, suya sin previo aviso 0 notificacion. Ademas, la corta puede
decidir a favor del demandanto y requiere que usted cumpla con todas las provisiones de esta demanda.
Usted puede perdar dinero 0 sus propiedadas u 0 tros derachos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE, SI NO TIENE
ABOGADO 0 SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, V AY A
EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DlRECClON SE
ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, P A 17013
800-990-9108
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
Pursuant to the fair debt collection practices act, 15 U.S.C. 9 1692 et seq. (1977), defendant(s) may
dispute the validity of the debt or any portion thereof. If defendant(s) do so in writing within thirty (30)
days of receipt of this pleading, counsel for plaintiff will obtain and provide defendant(s) with written
verification thereof; otherwise, the debt will be assumed to be valid, likewise, if requested within thirty
(30) days of receipt of this pleading, counsel for plaintiff will send defendant(s) the name and address of
the original creditor, if different from above.
The law does not require us to wait until the end of the thirty (30) day period following first contact with
you before suing you to collect this debt. Even though the law provides that your answer to this
complaint is to be filed in this action within twenty (20) days, you may obtain an extension of that time.
Furthermore, no request will be made to the court for a judgment until the expiration of thirty (30) days
after you have received this complaint. However, if you request proof of the debt or the name and address
of the original creditor within the thirty (30) day period that begins upon your receipt of this complaint,
the law requires us to cease our efforts (through litigation or otherwise) to collect the debt until we mail
the requested information to you. You should consult an attorney for advice concerning your rights and
obligations in this suit.
PHELAN HALLINAN & SCHMIEG, LLP
by: Michele M. Bradford, Esquire
Atty. I.D. No. 69849
One Penn Center, Suite 1400
1617 John F. Kennedy Boulevard
Philadelphia, PA 19103-1814
(71 'i) 'i1i,-7000
Deutsche Bank National Trust Company, as Trustee
for Vendee Mortgage Trust 2003-1, without recourse,
except as provided in a Pooling and Servicing Agrement
dated February 1, 2003
71 05 Corporate Dri ve
Piano, TX 75024
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
Plaintiff
vs.
Cumberland County
Richard L. Neenan a/kla Richard L. Neenan, III.
Claramae B. Neenan
And/Or Occupants
91 Cold Springs Road
Carlisle, PAl 70 13
Term
No.
Defendants
CIVIl. ACTlON/rOMPI.AINT FOR F..lFCTMF.NT
RASF.O ON AN lNSTAT.T.MICNT CONTRArT
FOR SAJ.F OF RFAI. FSTATF
I. Plaintiff is
Deutsche Bank National Trust Company, as Trustee for Vendee
Mortgage Trust 2003-1, without recourse, except as provided in
a Pooling and Servicing Agrement dated February I, 2003
7105 Corporate Drive
Piano, TX 75024
who is the Seller and Owner of the property at 91 Cold Springs Road, Carlisle, P A 17013 .
2. The names and last known address of Defendants are
Richard L. Neenan a/kla Richard L. Neenan, III.
Claramae B. Neenan
And/Or Occupants
91 Cold Springs Road
Carlisle, P A 17013
who are the Buyers or Occupants of the property at 91 Cold Springs Road, Carlisle, P A 17013 .
3. On or about October 23, 2002, the Administrator of Veterans Affairs, Plaintiffs Assignor,
and Defendants entered into an Installment Contract for Sale of Real Estate for the property at 91 Cold
Springs Road, Carlisle, P A 17013 . A true and correct copy of said contract is attached hereto, incorporated
herein by reference, and marked as Exhibit "A".
4. By Deed dated February 27,2003 , the Administrator of Veterans Affairs conveyed
its ownership rights and all interests to the subject premises to Plaintiff. A true and correct copy of said
deed is attached hereto, incorporated herein by reference, and marked as Exhibit "B".
5. Defendants are in default under the Installment Contract because monthly
payments under the contract due July 1, 2004 and each month thereafter are due and unpaid, and by the
terms of said contract, upon failure of Defendant Buyers to make such payments after a date specified by
written notice sent to the Buyers, the entire principal balance and all interest due thereon are collectible
forthwith. A true and correct copy of said notice is attached hereto, incorporated herein by reference, and
marked as Exhibit "C".
6. Notice of Intention to Terminate Installment Contract has been sent to the
Defendants by certified mail as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the
date set forth in the true and correct copy of such notice attached hereto as Exhibit "C".
7. The Temporary Stay as provided by the Homeowners Emergency Mortgage
Assistance Program, Act 91 of 1983, has terminated because Defendants have failed to meet with
Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written notice to the
Defendants. A true and correct copy of said notice is attached hereto, incorporated herein by reference,
and marked as Exhibit "C".
WHEREFORE, Plaintiff seeks to recover possession of said premises.
PHELAN HALLINAN & SCHMIEG, LLP
Date:
~~/05
By:
/;Y}~ ry0~
Michele M. Bradford, Esquire
Attorney for Plaintiff
"
'to' vA fORM 26"6336. (cg)
.., Reviled SBPT 1998
t
.
10-10-6-0540863
10-10-7.0018240
INSTALLMENT CONTRACT FOR SALE OF REAL ESTATE - PENNSYLVANIA
THIS LOAN MAY NOT BE ASSUMED WITHOUT THE PRIOR
APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS
OR ITS AUTHORIZED AGENT, SUCCESSORS OR ASSIGNS.
1. 'tHIS AGRBBMENT, madlllho 2Jrd day of October , 2002 ,\ly and between lbo Secratary of Veterllll$ Affair>,
an officer of the United States of America, whose llddreu is Department of Veterans Affairs, WasbingtoR. D C 20420t (f.1f the
Bnt part) hereinafter tslled "SeUer". and bidher successors in such office. as such, and
IUCIfARD 1. NEENAN, m and CLARAMAB B. NEENAN
berein.1fter caned "Buyer".
(party of the seoond part)
2. WrTNBSSBTH. That it is mutually agreed B!f follow:l:
The SeUer hereby agn:ea to sell to !be Buyer, and the Buyer hereby BgfCfS to pur:cbas.e from. the Seller. aU that [eat
propmy sit-umed in Dickinson Township county of
CUmberland and Commonweahh of Pennsylv-soia. bc[oin refencd to as "tlJe property.
and mora IiJlly doscrlbed as follows:
TAX PARCEL 8-32~2326-22
91 Cold Springs Road
Carlisle, PA 17013
3. This Agreement is JIDtdo subject to:
(1) Existin& lcue$. and to right" if any. of peuons. in pouessiou, if any.
(2) The senerul taxes and SPecial assessments which the Buyer hereinafte:t' covenaDts to pay.
(3) Building line and buildfng and liquor restrictions of record.
(4) Zonmg and building laws otonlioanccs.
(5) party wall rights or agrccment8.
(6) Roads and highwaY'.
(7) CaveI13Dts. conditIons. ex~tion&, resorve.tiow. restrictions, or easements of record.
(8) Rlghl.s of.1I pat1l.. claiming by, through, 01" under lb. Buyer.
(9) All)' state of (aets which an accuriLto su~c.y would ~bow.
((0) Alluopald water and scwage-di.tposal charges for services rendered after tho dare of'delivery of Ihis Agreement.
(ll) AU contracts Or agreements. recorded or unrecorded, for furnishing gas, electricity. water, or sewage-disposal
cet'Vtco.
(12) Tho constitution bylaws, rnIes. regulations, te3trictions. chlliCS, or asSOllsments of any civic improvement or
other usoclation. corporation.or district. which affcx:t the property.
(13) Coal Noth::o under tbe Bituminous Mille Subsidence and Laud Conservation Act of 1966 attached.
The Buyer shall indenmif)' and save barmiess the Seller from all 1018 and liability that arise by teason of any and aU
obligations llI1d liabilities eitlshng or wing out of any of 1he foregoing matters.
4. Buyer shall PRY to SeUet fot' the property ,he sum of
($ 96500.00 ) in lawful JDOney of tho United States or America at the (Regional Orfite) (C~l\1er). Department of
Vetet6n5 Affaits. an agency of the United States.or llt SUch other place within the United State, as the Seller or the Seller'!
Agent. may from time to rime designate in wliting. at tbe times, in the amounts. ttnd in the manner following:
{$
($
I) in cash prior to or upon the execution and delivery of this A81C01tk:nt; lUld the balllnce of
) h.~in referred to 1U Mprincipat sum- or as "principal" with inferest thereon nt the mte of
SIX percent ( 6.00 )% per annum, (rom the date of October 23 2002 ,
which. said pri.1cipa! .1nd intere!Jt on tho unpaid portion thereof sh..t11 be payable in equ31 monthly iI\!.la\1ment~ a~ follows:
95700.00
800.00
(.~ 57'3.77 ) on the first day of December ,2002, and a liJre sum on the first day of each and every
month fhereafier for 359 consecutive, additional months, until said prindpal dI1d interest shall have been tbUy paid.
Unless !ooner paid. (he unpaid balance of principal plus the accrued and Wlpaid interest shall be due and payable on tbe First day
of November ,2032.
or the total purchfl~e price paid rot the s\ltd ~e:sc(ibed propeny, rne amount (If $ ______.._______~ is. 3. rehnbilifation 101m
granted pursuant to Public Law 100-198, to be disbursed under a separate Escrow Agreement which rehabilitation IQan bears the
samo rute: of interest as the batance of the amount remaining and to be paid for tbe Ex.cept as lLeteinaftet mherwise 'Ptovided, cflch
payment made beteunder shaU be ere direct first on the interest then due as herein provided lUtd tbe remainder shall be credited
upon unpaid principal. Additional payrmmts of principal in any amount not less thM the amount of the monthly instaUments
abov", provided or One Hundred Dollars ($100). wbichevor is less, may be madf; at 'AnY timo and slutll be credited on the unpaid
principal sum In such mamrer as the Buyer ma.y elect, or in the ab:sence of such election, as Seller may elect.
5. All real estate taxes, water rents, sewer charg~g, asse5Sment~, and other charles payable in years subsequont to the year
2002 or levied after the date of executiau of this Agreement, or for hnprovements which are not then completed upon the
property. are And shall be the obligation of the Buyer, and Buyer covenants to pay the-same in the manner ptQvided in pa(a~taph
seven hereof. Water/sewer nnd lpedal 'Dsessmrmts to be paid directly by buyer.
1.----
6. Buyer shall obtain and contiouausly maintain hanrd inSUt~ of 1UCI1 t)'pe ~ type! and amouD~5 as the Seller ~y from time
(0 timo notify Buyer to obtain on the imrrovementl now or hereafter made on said premises .and will pay any prepuwns theJ'efor
promptly wbell duo. AU lnsulllOCO shal bo carried in <011lpanlts approved by SeIfer and policies and renewel thereof sluIll be
held by SeUer and have anached rheretO loss payable c:hwses in ravor of Sellor u StJcretllIY of Veterans Affairs in acccpta;bJe
form In the. eYenr of 105B Buyer wW give immediate DQCicc by mail to Sellet nnd Seller may, but fa not under duty to make
pr<loi of 10... If .1Ic1t proo; I. not made \"""'PUy by Buy<<. AU insutanoe ClItrlcn are horeby t.\IlI1Ori-<ed and directed to ma\<O
payments for lIucb tau directly to Se1ler lJutead of to Buyer and SeHor jointly. The proccedJ from the payment of such Jo.n or
any part thereot may be applied by Setter either ttI redu.dton of the Inde1>tcdm:8:s or to the mtoration and repair of the propertY
damage.
7. Togeth~r with and in addition to the ntOnthIy payments of principal 8Jtd interest payable uuder tho terms hereof, B.11~er will
pay tbe Sellet on the first day of each month untn thO' terms of this contract: have been fully compJied with. the following sums:
(a) Such amount or amoun~ as may be.oecessary to equnlaU or any or the Vremiuma.micl1 'M~t btcomt. dub and. payub1e
on the policy or polides of fuo aDd other hazard iDmrance covuinglbe property, ph.., raxest JlOJtt due ou the property
(aU b estimated by Seller, and of which Buyer is notified) less till sums already patd d1emfor divided by the number of
months to elapse befote one ~l\t\\ pMt ro the date 'Wben such ptemiwns, taxes wm become delinquent, such sums 10 be
beld by Seller in Tru:il (irrevocablo untit all of Buyer's obligations under thilJ Agreement are discharged) to payaaid
.. premlums~ taxes:
(b) The installment fat princlp<U and interest stated in paragraph 4 wbich. sum pius the amount, payable put~ant to
subparagraph (a) of this patalllaph shall be: paid in I. single payment llach month, B~cept 83 otherwise provided in
paragraph 14, 8uch payment shall be applied to the itett1$ and in the ordet' stated below:
I, Tues, fire and othet}la28Id inswancc premium;
II, Interest 04 the unpaJd portion of the principal; and
m. Unpald priocipal.
(e) Any deficiency in ooy suett payment shalt, unless made 1000 prior to the due date of the naxt payment, constimre an
event of ddfault hOIalnder. The SeJIC(' may collect a "late cluu:ge- not to oxCftd an amount equal to four (4%> per
centUm. of tho installment whicl1 is. not paid within fifteen (15) dayS from tbe duo dale thereof, to COVcr the t;(trJ expmse
involved in handling delinquent paymenrs.
(d) If tho total of lbe paymeDl. IlIlldo by Buyer under .ubpar.gmpb (n) of Ibis puagraph .bllll at nny time in !be oplllion
of Solter exceed the amount required for the payment of taxes or it1S1l(8nCC: premiums, 8S the case may be, such excen
shall be credited on subsequent payments to be: made by tho Buyer rOt such itmas. {f, however, :Nch m.ontll\y payments
shall not be sufficient to pay such items when the 3ame ,haIl become due and paYilble, the Buyer shall pay Ihe Selh::r any
amount necessary to make up the deficiency.
(e) All payments of sl\ld Items made by SeIfer may be in auch amounts .as are shown. by reoords, or by billa obtained by
Setter, or on the basls of any other infoOllation receiVed by Seller. or be due, payable. pMt dUf3, ot' dcl.~t.nt 0\1
3CtO\l.nt thereuf. U requested. by Seller, Buyer shall promptly obtain, approve and dellvtr to Seller aU bills for !aid
items. .
8. Buy~ covenants and agrees to deposit witb Seller at the excculion and delivery of this Agreement an amount to be de1:mnined
by Seller to be re:quiret1 to meet the payments of taXe.s and any premiw:ns for hlWd insurance wbich it may be neceJsaty to pay
prior to the accumuluion of a. fund &UIf\clfit tMrefur ~ provi.ded llt~rein.
9. AU payments otprinciplll, interest And otber iteUJ.'J required to be made by the tenDS oftms contrllCt, sl1all be mada to. the
A.gent CaMde:t .t tl\e ()ffltt: of '\be Department of Veterw Affairs designated in paragraph 4, to rhe order of the Department of
Vetetam Affair., unless the Buyer IIl1a1l be uotifled in writing to make such paymcnt3 to another payee or place,shd only Juch
payments as shall be receipted (or by the !laid Agertt Ca8hltr. or othet ~cc a(te't notlce tQ the Buyer, shall be recogoized by the
Seller, and all othtr payments, if any. shall be Dlade at the risk of the Buyer.
10, AU moneys paid to Seller he~under ,hall be deposited with. the Treasurer of the United Srate.i who ls hert:by autllOrized to
conunloele the sam~ with the gcneral t\1nd$ of the Unittld States. No interest shall be payablo on the funds received by Seller (or
any purpose: punlUattt to any provision of this Agreement.
11, Buyercovonaots not to commit, pennit, or suffer any waste to the propertY, to keep the property in a good state, order and
repair. Buyer further COYenants not to ablmdon said property and not to U4e, permir, or suffer the u&c of any of the propeny for
any illogal or immoral purpose, and agrees to comply with alllaw8 and ordinance.! wllich may in any miUlner affect the property.
12. The Buyer b authoriz.ed and pennitted to make such repairs, aUcmions, and renovations to said prope.rty as desired and
determined to be necessary 31: Buyer's own expenlle lll1d without any liability on tho part of the Seller for same, as are appooved in
adVlUJce by the Sellor. Failure ofdlc Buyer to obtain advance approval tor repairs, altettlti0D9, and renovations. to .sald property,
may o.t the opUon of \hi} Sel1er, be considered n breach of the tenns of tb.ls ngreement and IUl act of default. Buyer'furtber
COveDant" lUlU agrees to make prompt paymenl for all labor and material!'f in such behalf e1i.pended and not to suffer any
mechanics' or materialmen's lieD$, to attach fo slIidpropecty. All such repair! and alterations m~dc by the B\lyer shalt inure to the
beQofit of th~ property and the Scl.1er in the event of a default in the terms: of this Agreement by the Buyer. Buyer also covenants
and agrees ro complete and pay for the following repairs of a(teratioruJ within ' ( )
days after execution of this Agreement and that bre<\Ch of this c(}venant wm cOfl~titme. ~ act of defl\llh,
13. No part of Ulc ptopcny shan be U!td in the manulacrure, sale, or di!lrrlbution of intoxicating Hquors.
14. In the event Buyer failll, neglectll, or refuses to pcrform, in wl10le Or in pan, any afthe covenants4 agreements. or obli~3tJons
bereJR provided upon tflt.l part of Buyer to be performed, Seller is hereby authorized and ero,\lOwcre.d 'H\U\QU.t notice and at tho C03t
af Buyer. to pctfonn or CllUse ro be performed, any or all or said covCDmts, agrce:ments and obligations, and to expend such,
~UDl$ of money as may be reasortable therefor, or for any other purpose which in the opinJon of Seller is re<Ulonably nccCllSSty for
the protection of Seller, Seller's Jien. investment or pro~ny. AU such. sums of money SO CI,pendcd by Seller, togerh'er witb
intere"t thereon, at the rate: aforesaid, from the sevtlraJ data of expendLture thereof until paid. shall become so much llddidol'l.aI
indebtednos3 under this Agreement and shaU be repaid by Buyer to Seller, in lawful monty of Ute United States of America.
immeditlrely and Without demand, at the lIamc p\aw or platt3 fl3 other .sums alC payable horeunder, unle!s ScU~r shall Agree tbat
such mms be otherwise repaid, in wbich event such repayment shall be mad~ by Buyer: to Seller at such lime, and in such manil:er
as Sellltl' shall require. Any failure, neglect, or refusal by Buyer to repay sucl1 sum$ as herein provided shall comtitutc default
hereunder. My pl1yment~ made under tbe te:tn1s of this Agreernont may, at the electron of Sellor, Ire applied first to the
tepaymenl or any :!turns Seller shall have expended ill accordance wirh the terms hereof.
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15 Buyer berebr auigns transfer3 and sets over Co Seller, up to ihe amount or lhe total indebtedness of Buyer fo SeJler
bc~nder a)1 of Buyer'. tight, dlle.' and interest In OT to tll awardll and clab113 in connection with copdemnation of any of the
property ior publio use or lor Injury to My pordon tllerool, and !be p~ ot .ll .... awarn. or claims. all., payllltl1!
therefrom of aU tl:aSonable expeIl8es incurred, including kea for attomcys rcpresenrin& Seller in any such proccedinS. shall be
paid to Soller and Buyor', oblljllion _dor oI1,Ulher.by be mllH:ed an equal 1Dl0tl1ll '''''Pt.''' tbe .",.nt S.ller .Iects to .,.
th. funds ro Imp"'....,.. propelty in l1CCQrdance witb pal>8I1lph 16. Soller i. hereby authorized Il1I1u: name of Buyer to "",,,Ul.
and detiver yalid acquittanc:C5 thereof and to appeal from or otherwise appropriately lid,ate any or all of such. award.tf or olaims.
SeJJe: shall be under no obUianon hcceunder to sell or convoy all or any part otthe property. or right or lnrereu tbereJJ1: which Is
condemned. .
16. AU moneys J'tceivtd by Seller under any policy or policies. of lnsutmce or any candtmnation awud or otl\er award. a(ter
payment therefrom of all rcason"ble expenses Incurred in CC)nnection therewith. including fqs fur a((011lOj'S representing Sellcr,
may at Ill!! option of Seller be used for the purpoae of repairing, restorinS, or improving lIw damaged Slrtacturc upon tho
prop.rty, or may be credited on the Indebtedness in ~ with the provlsl... of lhls ^_t
17. Ex.COlltion ftJld acCeptllllC6 of tltJ" Agret:ment by the Buyer tonstltutts deU"ery to and acceptance by Buyer of {loS!ession of
the property herein described. and the buildil18$ and }mprovemenls thereon erected. and acknowltdgmetlt by the Buyer that Ihe
properly, JJ1d th, buildings and improvements tl1otcon erecte<l, have been. in~led and examined. that b~cr js utisfted with its
and tholr condltfun, and ibM the property and the bWldings and Irnprowments thettoa erected tn r.uth condition arc bc.ing bwght \
and accepted without BIl)' leprellcnlaUoQ wlultsoever by the SeJlC'r. except as may be provided in. parqraph 11 of Agreement of I
Sate dated . nlo Buyet !SSUme& respon:ribiUty for Injury or death Q1l or arising ont of the I
property tU1d .a.l3o assumes. the: rl&k oC toss OI dramage to 'he bui\dinp now situate, or herellfler coustfU1 <:ted, l~l or upon S8bid ,
propeny by fire, casualty, or other happening and sholt indemnify and l3avo the Seller harndes.lI from 4111 ass at~ ng from or y
reason of these c'Veht& or incidents. !
I
t 8. Time Is of the essence of this Agreemel1lll'nd if default be made and continue for a period of thirty (.30) days in the payment
of MY or the ilUltallmonts of principal. interest. or any other items her6inbefote atip1llated. 'When tht t.ame become rovemlly due
hereunder. or in the payment of any other sum herein agreQd to be paid by Buyer, or If default be IDadC in the performance by
Buyer of any other Ilgreement, oovennnt, or obligation of Buyer hereunder. then in either. or any of said eovents. the wbole
unpaid bo.lenoo due under tM terms of lIlis Agrecment sball. at the option ot Seller. jrnmedialely become due and payable and
Seller may, at hltlhcr option. <a) tenninatc by ,,;mp1e declaration of an election so to do with or witho1.\t notice. all of Buyer's
rigbls under thQ Aereement Ilnd aU of Buyer's right. titlo, and mterest in Ille property; or (b) tormlnate all of Bu.ycr's rlghC!
un~er Ihl. Agreement and 011 of Buyer's right, title. and. interest in the property in any appropriate proceeding, legnl or
equltabl~ or (c) enforce Buyer's obligations hereunder in any approptlllte proceeding, legal or eqUitable. Buyer Iljree5 to pay all
tOMa and ~pemes, Including a relllOllable SUln {or atto.mcy's fees ittcurcW by Seller In. tttrninatlng ~t"S rlS"\8 under this
Agreement or c(ailM to the property or 10 enforcing any or BlJ of the teml!I of this Agreement; and m appropriate judlelal
proceedings, If any are Jnldated to esrabJlsh or maintain Seller's right Ot tiUe to. and pOSli~on of said property after breach by
Buyer, free or any titteor dw.ms of Buycr. .
19. Upon Seller cxcrCi~dng the tight of termination IS provided hereirJ, aJI rights, estate. and lntetes.t hereby Cleated and then
~btln& in ~1)'et and in any 8J'\d aU penons claim1ns under Buyer, mall wholly cease and detenmne. Buyer sballlhereupon quit
and surrender to SeIler withOlJt dmnand, pCDCCrut possession of laid premb:et in 83 good condition as they now arc, reasonable
wcllr and tOllr atone excepted. In the event Bl,l)'e.r neglects or tcluBCI to snrrendet such llosscssion when obligated 80 to do it
shall be lawful for Seller to enter upon and take possession of sueh prcm!acs without notice and remove all persons and thelr
property.
20. The Provisions of paragntph 19 and 20 or this Agreement shall also apply, at the option of Seller, to (1) any viQlatiol\ or
breath of any of .he covenants. conditions, or 1'C!trlctions. indicated In this Agreement or which. may be t)f reeoro, and (Z) to
any viola\\on of any law8 or ordinances in any manner affecting said property.
21. Seller agrees upon receipt of payments in accocdanoe with the proviskms bfm)f. of lhe tnt\rc plintipal sum with interest. to
execute and deliver a spe<:lnl Warr:anty Deed on VA Porm 26-6436a conv6}'ing the title to said property 10 Buyer in such manner
and fonn as SelJer elects. Such deed may be delivered at such earlier time 118 Seller may el<<t, Said Deed will be on Seiter's
form and conveyance shall be made nnder nnd subject to any restrictioDs. reservatious, and exception of record and also subject
to all Natiollal. and State laws, statutes, and regulations, then affecting the tnmsfer of real esrate Dr of any rigbt therein. In Iho
event any part of said principal sum shall not bave been paid lit the time of the execution and l1eUvctY uf the deed to said
proptrty. Buyer shall .simllltllOeOU31y executo and deliver to Seller I'l MortJage Note in the jut or principal sum remalnlng
unpllld, toðer with jnlere!t tberoon al tM rate provided in pat>aph 4 hetCOt, payable in Installments of the Same amounts as
,lllled in eaid paragraph. and a purcha.'IC moMy mortgage. of Hid p~misea to secute the same. which mortgage shaU be II rust
lien on the property; the Mortgage Note and Mortgage shall flear tho same date as said Deed; they shall be on the fornu of such
lnsttuments then in use bf. the Department of Vctorans Affairs or its successor In lntelll5t, modified and amended as to !Nch
t.etmS. cond.itioru;. and dehuted pro....lsions nllllrc in conflict with rbIs Agreement.
22. Buyer represents and covenants tbal Seller's title is satisfactory to Buyer as ar ttle date beroa{.
23. Buyer shl\ll pay for all recut.ding, transaction. tralUfer. coQ.veyattC'C, and .o.l"!er taxa, upon thIs Agreement and upon any
detd, bond. mortgage, or other (~trum.ent elecuted under 111l';. termJ and proVll110nS of this Agreement, and for nil reVenue.
documenrary. ?( other stamps reqUired to be affixed to any such Instrumcn~ and shill also pay the fees for recording the deed and
the lllortgll8e. If any. when executed. liS well as all coats a~d expenses for such title searcb as tbe Buyer may eLe.ct to h3.Y~ mad~.
24. The Buyer shall not!{y the Seller of an tl.1signmcnt of th? Buy~r"6 intorest In this wntract. Seller may at any time sell and
convey tho property SUbject to this Agreement Md may assIgn IhIS Agreement and any and aU rights helcunder withom the
consent of the Buyer.
25,. Any notices from ono party hereto to the ul"eI party shaU be in writing and delivered in pefSQn or forwM:fcd by certified
mati: Notices. shall be addrc!Js~d to the property hereinabove described ualess written of a differenr addrcss sbaU have been
prevIOusly delIVered to Seller, tn which. event notice shall be sent to such address. Notices to Selter shalt he adt.lres!l:d tll the
Loan Guaranty Officer, Department of Veterans Affa1r5 at the Office where this Agreement I! oxecuted until Buyer is notified in
wrlUng of a changed address. Thetoafter any notice shall be sent to tho last address Df which Buyer lIhalt have been norificd.
1.6. Buyer hereby authorlzes and erUpoweJS any attorney or any couer in the Commonwealth of Pcrinsylvania or eJsewhere to
appear fo1' them and eac~ of them in any 8fId all accioas to be brougbt for MY breach or default of the terms of Otis Agreement
and f:ereby confes.~~ Judgment In faVor of Che Seller for the whole: amount of the principal sum and any lntercst remaining
unpaId tllereon. whetlier the same shall ha'fe been due or not, together with an anomey's commilllliof\ or fee of five (S%)
percent. with or without prior declaration made. waiving stay of execution, inquisition. and aU exemption laws,
27. And thO:laid Buyer hereby, upon tbe brmwh Of any of the condltioDS of this Agreement, authorlleS anY attomey of any court
of Record to appoar for Ibent and ..ell of them and enter an aml~. action of ejeotmcnt and tOIlf... . Jud$ment of <J~
therein for Ibe premises borcI. described and do authorize III. unmcdlate IlsUlng and ...cutlon uf . Writ of habere [1CI83
poas08slonem with elauaes of fiori factas tor com and nve (5%) percent attorney's comuu.ssion or fee, without asking leave of
court.
28 All moneys paid by Buyer to ScHer under the terms of this Agreement shall be malned. by Seller lIS compensation fot the use
and occupancy of the ptopOrty. consideration foT tile execution of this ~nt and not as liquidated damages 10 SeDer for
default or 1& a penalty.
29 Failure or delAy of the SeUer to enforce lIDY ria:bt or to exercise MY option hereunder availablo because of any default shall
DOt operate as a watvet of the right of the SeUor to thereafter enfotce such right or to exercise such option. or any other right or
option, for the same or for any lubsequcnt default.
30. Buyer expressly agrees !bot the rip" and -os beTeln granted Seller In the avent of detiwlt, to ..foree lbe ICllllB and
conditions of Chis Agreement, the remvery of damages lor my breach, or po!!tSJlon of the above dcacribcd property, may be
exercisable as often as th<<e is default 00 the part of Buyer and ShaH not be exha.usted by one or more \llIes thereof, IInd that it
shall Dot be .D~e8SlIJ)' to file the o~al of th1$ contract as a wltTant of attorney if a true copy hereof shall be filed in anyactiQn.
31. The cov....", obligations, liabllllles, I."", and provisions herein ""'talned aball be binding upon, and !be beIlefilS and
advantages hereunder shalt inure to tOe Buyer jointly and senrally and to their and each of their respective heirs, executors,
adrnlnl.!ltral0f3, and assign3, and to the succ:esaors and assigns of the Seller.
32. 'fhis Asrcmncnt shall not be te<<ltded in the office fot !he recording of deeds or any other office at place of pubJic record.
If Buyer causes It 10 be recorded he/she will be considered in default with the right of Seller to forthwIth terminate this
Agreement and 10 enforce and exercilla Seller's rights hereunder because of such default.
33. lJtlyer understands and agrees tbat if this Installment Agreement is terminated by Buyer or Seller. any remaining amount of
the rehabilitation loan in thc bands of WI. Cll(row IIgent sb:aJl .immediately bo returned 10 Seller (Department of Vtterans AfMrs),
34. 'Ibis loan may be declared Immediately due and payable upon transfef of the property aecuring auch loan to any transferee,
tlll1csa the ftCtePtability of the WUPlPtiQD of tho Joan is established: eirhot purauant to tho provjaions of 3CCtioo 3114 of chapter
37, t\tle 38. United State Cod&, or by OlD loan holder If the loan has been sold. without recourse.
3S. A fee equal to one-half of 1 percent of the balance qf this loan aa of the date of traD.!ifer .thaU be payable to the Department of
Veterans Affairs at the lime of tIanst.,r. H the anwner fai18 to pay tl1fs fee at the time of transfer, the fee ahan constitute an
.Mlllo.aI debt to Ibal already secured by !hI< instrument and aball bear Inter,,, at !be rate ber.1n provided, and, at !be oplion of.
tho payee of the indebtedne.!s hereby secured or any transferee hereof, the fuU iodebtedness ball be immediately due and payable.
This fee is automaticallf wlli.ved if the assumec is exempt under the provisions of 38 U.S.C. 3729(b). The assumet is not
obligated to pay this fee If Ihe Department otVeterfIDS Affain has 30ld Ihis 101Ul without recourse.
36. Upon application for approval t<J allow 8SIlumptioo of this loan, a procwing fee may be charged by the Department of
Veterans Affairs or its successors or uklgnl for determining the creditworthiness of the assumer and subsequently revi:ring tho
owncr.shlp records when an approved transfer is completed. The antount of this charge shan not exceed $300.
IN WITNESS WHEREOF, the Selier hilS cauaed tbilt instrument to be signed and sealed in hislher name an din his/her behalf by
tbe undersigned employee, being thereunto duly QPPOlnted, qualified and acting pursuant to title 38. UoiCed States Code section..
212 and 1820, and title 38, Code of F'ederal RegulatiQll3. aoctiona 36.4342 and 36.4.520, pursuant thereto, os amended,' and who
Is authorized to execum tbi1J Jnstroment. and tho Buyer has hereunto let hisJher individuDl hand and leal on the day and year flut
above written.
NOTICE. THIS DOCUMENT MAY NOT/DOES NOT SELL, CONVEY, TRANSPER. iNCLUDE OR iNSURE
T!Il! TITLl'. TO THE COAL AND RIGHT OP SUPPORT UNDEllNllATH Tim SURFACE LAND DESCRmED OR
REFERRED TO RERlllN, AND THB OWNllR OF OWI/ERS OR SUCH COAL MAY HAVE/HAVE T!Il! COMPLl'.TB
LEGAL RIGHT TO REMOVE ALL OF SUCH COAL AND, iN THAT CONNECTION, OAMAGB MAY RESULT TO THE
SURFACB OF THE LAND AND ANY HOUSE, BUILDING OR OTHER STRUCTURE ON OR IN SUCH LAND. THE
INCLUSION OF TIllS NOTICB DOllS NOT ENLARGB, RllSTlUCT OR MODIFY ANY LEGAL RIGHTS OR IlSTATIlS
OTHERWISE CREATIID, TIlANSFBRRBD, El(CEPTED OR RESERVED BY TIllS INSTRUMENT. (Thl. notice I< '" forth
in the mll1lnef provided in Section 1 of the Act of July 17, 19n, P.L. 984, as amended, and Is not intended as notjce of
unrecorded instmmenls, if any.)
SEALED AND DELlVERE
IN THE PRESENCE OF
.-.---.-....-...-...u- .--. -.-..--
.----Jt2t.. ~ .... ...
Th'~taryo"vetorans Affairs
vd;- lh.t&:f.&..tM/JfOtSEALJ
U- - J 'ce P. DiBenedetto
Title: _..b.~!!!!8..'=Q.'!Q.@!.~!y...Qm~.f.....,._...........~
V A Regional OffiCe or Region31 Office &
Insurance Center, PhitadeIphil'l. PA.
Telephcne:21H42_2000
Pursuel 10 a delcgalion of authority in 38 CFR
36.4342 and 36.4320.)
........~-~.
.S-<cL....L._2L~.. .... _.....jSBAL]
RICHARD L. NEENXN: 111 (Buyer)
e...~td.l:f.~d~~_.........___..[SEAL]
. CLARAMAE E. NEENAN (Buyer)
no .._.........~.....-.~._.__...............-- (iiuyer) .............fSEAL]
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REBEKAH ADAMS
(5701584-3784
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"J VAFonn26-6436a
S..lIoa18ZO. Title 31 U.s.C.
THIS INDENTURE made this 27
Officer of the United States of
20420. hereinafter called the Gran
Mortgage Trust 2003-1, Without R
February J, 2003, a trust which is
principal place of business at clo Co
CA 93063.
herein called Grantee:
lay
PENNSYLVANIA
00021827070200SN
y of February, AD. 2003, betWeen the Secretary of Veterans Affairs, an
'ca, whose address is Department of Veterans Affairs, Washington, D.C.
and Deutsche Bank National Trust Company, As Trustee For Vendee
urse, Except As Provided In A Pooling And Servicing A&reement Dated
lished under the laws of the STATE OF CALIFORNIA, having its
trywide Home Loans, 1800 Tapo Canyon Rd, MSN SV-103, Simi Valley,
WITNESSETH that the said Granto ) for and in consideration of the NINE1Y.FJVE THOUSAND SIX
HUNDRED AND FOUR DOLLAR 73 CENTS. {$ !l5604.73} DOLLAR(S).
the receipt whereof was acknowledg
the said Grantee and Grantee's heirs
BEGINNING - LEGAL D
MADE A PART HEREOF.)
T AXID: 08-32-232
BEING: 91 C LD SP
SRD
TOGETHER with all and singular
liberties, privileges, hereditaments,
appertaining, and the reversion and
interest, property, claims, and d
in, and to the same and every part the
ereby grants, bargains, sells, aliens, enfeoflS, releases, and confirms unto
successors and assigns,
N (SEE ATTACHED EXHIBIT "A" ATIACHED HERETO AND
on
ISL
***
mprovements, ways, streets, alleys, passages, waters, watercourses, rights,
ppurtenances whatsoever thereunto belonging, or in any wise
. ders, rents, issues, and profits thereot; and all the estate, right, title,
hatsoever of the said Grantor, in law, equity, or otherwise howsoever, of,
f.
TO HA VB AND TO HOLD the said I t or piece of ground above described with the hereditclmcnts and
appurtenances, unto the said Grantee Grantee's heirs or SUccessOIll and assigns, forever.
Grantor covenants to WllII1lllt and del<
claim the same or any part thereof by,
***
Property siJ;uated'
and Commonwealth
property" and mor
all that herein above described against all persons lawfullglainting or to
under Grantor. c..:> ';:' :_:~
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Dickinson Township county of Cumber:l.and
Pennsylvania. herein referred to as "the
fully described as above.
iloox 257 f'.I.cf1$32
.Mov 17 04 05,28p
REBEKAH ADAMS
15?0)584-3?84
p.17
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.
IN WITNESS WBE
instrument to be si
appointed, qualified
l1tie38,CodcofFed
and who is authorized
00011827070200SN
OF, Grmrtor on the day and year fust above written has caused this
sealed on Grantor's bchalfby the undersigned, being themmto duly
. pursuant to Title 38. United States Code, Sections 212 and 1820, and
Regulations. Section 36.4342 and 36.4520, pursuant thereto, as amended,
ecute this instrument.
SRALED AND DELIVERED IN
ENCE OF-
The Secretary of Veter... Affain
.B~~ --:::. [Seal]
RICHARD STRA
· \IA~ -/
[vette Osorio
Title: Authorized Officc:r
Countrywide Home Loans as Authorized
Officers for Vetenns Affairs Regional
Office or Regional Office & Insurance
Center Phila.. P A
Telephone (805) 577-4800
(Pursuant to a delegation of aulhority in VA
Regualtions. 38 C.F.R., 36.4342 and
36.4520.)
.-M~
Jacob Bass
STATE OF CALIFORNIA, }
}SS
COUNTY OF VENTURA }
On this 27th day of Febroary, 2
appeared, Richard Strayer, peno
the within instrument and ac:kno 1
capacities, and that by their si
the persons acted, executed the ins
WITNESS my hand and official s
3, before me, Stanley W. Shaw, Notary Public, per:sonally
known to me to be the persons whose name is subscribed to
ged to me that they executed the same in their authorized
on the instrument the persons, or entity upon behalf of which
ent.
9 w~L
Stanley W. Shaw
Notary Public - Commission No.1
Commission Expires: January 21,2
690
S
a STAH1fY W. SHAW
CommUslon t 12916PO
~. HoIary PublIc - CaIfanIa
Ventum County
1 MtCam>.&;>i1lIJan:u.2D5l
.~--- ~ ~----_.
[ hereby certify that the precise resi
clo Co 'de 0 Loans 80
*Print, typewrite, or .tamp aallle. of each
Se"" 181 bOb to:
Countrywide Ho"", Loaaa.
AtlD: AJ>drca Calmata
17S7 Tape Cacyon Road
MSN SV-34
Simi Valley, CA 93063
bOOK 257 PAGE1933
.Nov 17 04 05:28p
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DAllA VEGA
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1800 TAPO CYNRD. MSN SV-I03
'"I TRANSFER DATA
'1' OF VE'r'Ell'AN
R GIONAL LOAN CENTER
5000 WISSABICKON AV~.
PHILA ELPBIA PA
C PROPliRTY LOCAnO
CUMBERLAND
'D VALUATION DATA
1.
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E EXEMPTION DATA
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577-4493
SIMIVALLEY. CA 93063
FAIRS BANK NATIONAL TROST COMPANY
COUNTRYWIDE HOME LOANS
TlU'OCYN. RD, HSN SV-I03
19101 VALLEY CA 93063
-
08 32-2326-0022
+ 00000
X . \,0\
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=: 95,604.73
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~_of_l_fICIrlY",,'--'''''
_ and ___ by gilt. dociaatiQn. _-I _. '" In '"" of ...o....cman.
allado ""Pl' of ...aIotiaa.l
"lI..... '" __ -.-....N_ .,_ N_bot
. copy of.. prior ... being c:orr.cted Dr -n.m...d.l
dI.Iolc.. (Aa<odJ cap,. of _I
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0212712003
AttACH N'PUc:AlIU! l>OCUMlNTATlON MAY IlESULT 1M neE _'S RII'lJ$Al.
iioo"R 257 PAGE1935
U"/U~/U5 TlIb 1U:J6 FAX 6107190307
MARY SCROCCA
IjiJOOl
ACT
91
NOTICE
(INSTALLMENT CONTRACT)
TAKE ACTION TO
YOUR HOME FROM
EVICTION
SAVE
DATE: January 4, 2005
Richard L Nct':nan
91 Cold Springs Road
C",lislc, P A 17013
Claramae B. Neenan
91 Cold Springs Road
Carlisle, P A 17013
THIS FIRM IS A DEBT COLLECTOR ATI'EMPTING TO COLLECT A DBBT. THIS NOTICE IS
SENT TO YO U (N AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBT AlNED FROM YOU WILL BE USBD FOR THAT PURPOSK TF
YOU HAVE PREVlOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE TS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEM.ENT OF A LIEN AGAINST PROPERTY,
This is an official notice that 1I1e Installment Contract on YOUr home is in default and 1I1e lender intends to
start evictiOIl proceedinl!S. Specilic information about the JIllturc of the default is orovided in tile attOlChed
Dages.
The HOMEOWNER'S MORTGAGE ASSIST ANCB PROGRAM (REMAP) may be able to help to save
your home" This Notice """lams how the program work~"
To see ifHEMAP c3.llheln. you must MEET WiTH A CONSUMER CREDlT C_01JNSELTNG AGENCY
WITHIN 33 DAYS FROM THE DATE OF THIS NOTICE" Take this Notice with VOll wheu. you wcct
the Counseling kcncy.
The name, address and ohonc nwnbcr of Consumer credit Counseling A~encies serving vour Couulv arc
listed at Ole end oftnis Notice. livou have any auestions. YOU may call (he Pennsylvania Housing Finance
Agency toll free al 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important lcg-d1 infonnation. Tfyou havc any questions, representatives at (he
Consumer Credit Counselin.g Agency may bo able to help explain it. Y"" lllay also w<mt to contact an
attorney in your area. The local bar association may be abloto help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORT ANCIA, rUES AFECT A SU DERECHO A
CONTINUAR VlVlENOO EN SU CASA 51 NO COMPRENDB EL CONTENlDO DE ESTA
NOTIFTCACION OBTENGA UNA TRADuccrON INMEDIT AMENTE LLAMANDO EST A
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENClONADO ARRIBA. PUEDES SER ELEGlBLE PARA UN PREST AMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS BMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CASA DE LA FERDJDA DEL DERECHO A. REDIMAR SU InPOTECA
U':::IU"IU:) 1Ub lU:JIj l'AA. tnU71HU3U7
MARY SCROCCA
',JJ 00 2
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Richard L Neenan and Claramae R Neenan
PROPERTY ADDRESS: . 91 Cold Springs Road, Carlisle, PA 17013
LOAN ACCT NO 21827070
ORlGTNAL LENDER: Department ofVelerans Atfairs
CURRENT LENDERlSERVICER: Countrywide Home Loans, Ino.
HOMEOWNElt'S EMERGENCY MORTGAGE ASSISTANCE pROGRAM
YOU MAY DE ELlGWLE FOR FINANCIAL ASSISTANCE THAT WILL PREVENT
TERMINATION OF YOUR CONTRACT FOR THE SALE OF REAL ESTATE PENNSYLV ANB.
(lIEREINAFTER CALLED "CONTRACT") FROM EVlC'flON AND HELP YOU MAKE
FUTURE INSTALLMENT PAYMENTS
TF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSIST ANCE 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 CONTRACT
PAYMENTS, AND
, IF YOU MEET OTHER EUGIBILlTY REQUTREMENTS ESTABLISHED BY THE
PENNSYL VANIA HOUSING FINANCE AGENCY.
TEMPORARY ST AY OF TERMINATION OF YOUR CONTRACT -Under !he Act, you are entitled to a
temporary stay of eviction on your contract for fuirty three (33) days fronl the date of this Noticc. During
that timc you must arrange and attend a face-to-face mectingwith one of the conSumer credit counseling
agencies listed at the end ofthis Notice" TIDS MEETING MUST OCCUR WITHIN THE NEXT (33)
DAYS" IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE NlSTST ANCE. YOU MUST
BRING YOUR CONTRACT UP TO DATE. THE PART OF TmS NOTICE CALLED "HOW TO CURE
YOUR CONTRACT DEFAULT" EXPLAIN'S HOW TO BRING YOUR CONTRACT UP TO DATE
CONSUMER CREDTT COUNSELING A.GENCIES-If you meet with one of the consumer credit
counseline agencies listed at the end of this notice the lender lllllV NOT take action ~g.inst 'Iou for thiny
lllrcc(33) days after the date of this meeting. The names. addresses and Icleohone numbers of desieJlated
consumer credit connseling agencies for the coumv in which the llfOllertv is located are set forfu at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatcly
of your intentions.
APPUCA TION FOR CONTRACT ASSIST ANCE-Y OlIr contract is in a default for 1he reasons Set forth
later irI fuis Notice (see following pages fur specific iniormation about thll nature of your default) If you
have tried alld are Illlahle to resolve this problem with the lender, you havc !he right to apply for financial
assistance from the Homeown",,'s Emergency Mongage Assistance Program. To do so, you must:fill out,
sign and file a completed Homeowner's Emergency Assistance Program Application with oue of the
designated consumer credit counseling agencies listed at the end Oftllis Noticc" Only consumer credit
counseling agencies Mve applications for the program lll1d they will assist you in submitting a complete
application to !he Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within lllirty three (33) days of your face-to-face meeting.
YOU MUST FILE YOUR Al'PLlCA TION PROMPTLY. IF YOU FAlL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTB IN THIS LETTER, EVICTION
MAY PROCEED AGAINST YOUR HOME lMMJ;;DlATELY AND YOUR APPLICATION FOR
CONTRACT ASSISTANCE WILL BE DENIED,
v..' vVI VV
.L'-,..... .LV.VV 1..n.Jlo. V.1.Vl.LOV....VI
Jl1t'\l\.J. .:J\.-l\VV'v.t\
14100:5
AGENCY ACfION-Availablc funds for eIllergency mortgage assistance arc vcry limit<Xl. They will be
disbursed by thc Agency under the eligibility criteria cslJlblish<Xl by the Act. The Pennsylvania HOUSUlg
Fimmce Agency has sixty (60) days to make a dc;cision after it receives your application. During dIat time.
no eviction proce<Xlings 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
applicali.on"
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE flUNG OF A PETlTlON IN
BANKRUPTCY, TJIE FOLLOWlNG PART OF TIllS NOTICE IS FOR INFORMATION
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATl"EMPT TO COLLECT
mE DEBT.
. f ou lIave filed bankru tey yoU can still a I for Emer ene Mort"a" Assistance.
HOW TO CURE YOUR CONTRACT DEFAULT (Bring it Ull to date\.
NATURE OF THE DEFAULT-The CONTRACf debt held by the above lender on your property located
at: 91 Cold Springs Road, Carlisle, PA 17013 TS SERlOUSL Y IN DEPAULT because:
A. YOU HAVE NOT MADE MONTHLY CONTRACf PAYMENTS for the following mon1hs and the
following lIll'lOunts are now past due: StartlEnd: 7/01104 through 1/01/OS at $752.35 per month.
Monthty Payments ptus Late ChaTges Accrued $5,386,81
mp mOO
Iuspections: $774.72
M~ moo
(Suspense): $0"00
Total amount tn ~ure default $6,161.53-
See paragraph below beaded
"ROW TO CURE THE D.EFAULT"
R YOU HAVE FAILED TO TAU THE FOLLOWING ACTIONS eRo not use if nm allolicable): N/ A
-ROW TO CURE T1IEDEj,"AULT.You may cure the default within THIRTY THREE (33) DAYS from
the datc of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$6,161.53, PLUS ANY CONTRACT PAYMENTS AND LATE CHARGES WillCH BECOME DUE
DURING THE THIRTY THREE (33) DAY PERIOD. Because ofintttest, late charges, and oth(]" enarges
dIal may vary from dayw day, the ltDlount due on the day you pay may be greater. Hence, if you pay the
amount sbown above, an adjUstllle11t may be necessary after we receive your check, in which evenL wc will
inform you before depositing the check fur eollection" FOI further infonnation, write the undersigned or call
and ask for lhe Reinstatement Department. Pavrnents mu.! be made either bv cash. cushier's chock.
ccrtified check or moncv order made oavable and sent to: PHELAN BALLINAN & SCHMIEG, L.L.P.,
One Penn Center at Suburban Station, 1617 JFK Blvd., Suite 1400, Pkiladelploia, PA 19103-1814.
You can cure any other default by taking the following action within THIRTY THREE (33) DAYS from
the datc ofthis letter. (Po \lot use ifnot allolieable.) N/A
IF YOU DO NOT CURE THE DEFAULT -lfyou do not cure the def.mlt within THlRTY THREE(33)
DAYS from the date of this Notice, the lender intends to exercise its rights to NXelerate the contract debt
The means that the entire outstanding balauce of this debt will be considered dne immediately and you may
lose the chance to pay the contract in rnonthlyinstaUments. Iffull payment of the total amount past due is
no\ madc within THIRTY THREE(33) DAYS, the lender also intends to instruct its atromey Lo start legal
action to start evictioll proceedings uoon your conlract molleItV.
V~!VO/V~ ~un ~V.~I rfiA U~UI~~U~UI
lI1fil'Ct ,:)\,1\UV\"l\.
LgJ 1I114
IF THE CONTRACT IS TERMINATED-If the lender refers your case to its attorneys, but you cure the
delinquency bcforc t11e lend.., begins legal proceedings against yoa, you will still be required to pay me
reasonable attorney's fcc.s that werc actually incurred, up to $50.00. However, iflegal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even
ifthey e~eeed $50"00 Any attorney's fees will be added to the amount to the lmder, which may also
include oIDC! reasonable costs, Ifvou cure the default within the TffiRTY THREE (3]', DAY neriod, vou
~n not be required to nav attorney's fees.
OTHER LENDER REMEDIES-The louder may also sue you personally for the unpaid principal balance
and all other sums due under thc contract
RIGHT TO CURE THE DEFAULT PRIOR TO EVIcrroN-lfyou have not cured the default within me
THIRTY THREE (33) DAY period and eviction proceedings have begun, vou still have the ricllt to cure
thc default and oreventthe eviction a1 anvtimc up to one hour before the eviction" You may do so by
navini' the total amount then past due mus anv tate or other cIulrll:es mOl due reasOllable attoIllCv's fees
and COSIS connecled with thc eviction ;md anv other cosIS connected wiTh The evicT,;on as snecified in
writ.iug by Llro j""cJ.",..aud by p.,normml{ any otil.er r<<luir_Ollts und.., the contract. Curing your default in
the manner set forth in 'this notice will restorc your contract to the same positioll as if you had never
defaulted.
EARLIEST POSSIBLE EVIGflON DATE-It is estimated that the earliest date that such eviction from tile
property could be held would be approximately SIX (6) MONTHS from tbe date of this Notice. A notice
of the actual date of the eviction will be sent to you. Of eo urge, the lllllolllltllccded to cure me default will
increase The longer you wait. You may Ilnd oulat any time exactly what tire required payment or action
will be by contacting the lender.
HOW TO CONTACT THE LENDER Attorney Representing Lender:
PHELAN lIALLINAN & SCHMJEG, .L. hP.
One Penn Center at Suburban Station
1617 John F. Kennedy Blvd.. Snite 1400
Philadelphia, l'A 19103-1814
(215) 563-7000 Attention: Reinstatement Department
EFFEcr OF EVICTION-You should realize that an eviction will end yonr interest in the property and your
rigbt to occupy it.
YOU MAY ALSO HAVE THE RIGHT:
o TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF TillS DEBT.
o TO HA VB THrS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF
TO HAVE THE CONTRACT RESTORED TO THE SAME POSTTTON AS TF NO DEF AUL THAD
OCCURRED. IF YOU CURE THE DEF AUL T. (HOWEVER, YOU DO NOT HAVE THIS RIGHT
TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
o TO ASSERT THE NONEXISTENCE OF A DEF AUL T TN ANY EVICTION PROCEEDTNG OR
ANY OTHER LA WSWT INSTITUTED UNDER TI-ili CONTRACT DOCUMENTS.
o TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
o TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY [S ATTACHED
U~/U~/U~ lUh lU:J7 FA..\. tnU7190J07
MARY SCROCCA
'ill 005
If tllis is the first notice that you Ilave received from this office, be advised tllat: you may dispute the
validity of the debt or any pOl1ion thereof. If you do so in writing within thirty (30) days from receipt
of tl.is leiter, this lir,!, will obtain and provide you witll written veriticatiou thereof; otherwise the
debt will be assumed to be valid, Likewise, if requested within thirty (30) days from receipt of tllis
letter, tile lirm will send you tlte name and address of the original creditor if different from above.
Very truly }'Ques.
PHELAN HALLINAN & SCHMIEG. L.L.P.
Cc: Countrywide Home Loans, Inc.
Arm: Donald Varnado
Account No.: 21827070
Mailed by 1'1 Class Mail and by Certified Mail Nos: 7003 3110 0004 6889 4848/4855
U..i:/U~/U:> i'llb lU:J7 FAX tSlU7190J07
MARY SCROCCA
I4J 006
(:(Imhim:d l,cUcr
Aa61.aUcT
NO!Lcucr
::L............ Comhined In~luJl
Ad. 6 Tn~ttl.ll
NOlInsmlt
Combil1ed (Matured)
Act 6 (Maturod)
NO! (Mal.rod)
Combined (P-Nott)
Act. (P.NolC)
NO! (I'.Notc)
File Name
Neenan
Loan Number
Z18Z7070
County
Cumbel'land
Original Mortgagee
Denartment of Veterans Affairs
Our Client
Conntrvwirlp. Rnmr. Lnans.. In('~
Attention of,
Donald Varnado
Current Lender
Conntrvwide Borne Loans, [qc.
Mortgagor #1
Richard L. Neenan\Claramae B. Neenan
91 C"ld Snrinl!S Road
..,
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U.S. Postal Service"
CERTIFIED MAIL.., RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
Carlisle. P A 17013
Property Address
91 Cold SDriDl~s Road. ClU'lisle. PA 17013
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CertltledFee
.2.30
50.00
SO.OO
Moothly Payment
7 (a) 752.35
Postage $
Delinquency Start
7/01/04
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D Ratlm Flec:tept Fee
(Endoramvnl Required)
I:J Rslltr1cled Delvery F&e
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Total Postage & 1"898
$ 52.90
Delinquency End
01101/05
Late Charge
120.36
Total Amount
6161.53
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NSF Fees Q
.Inspections 774.72
Other Charges Q
Sllspen.se 0
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CERTIFIED MAIL. RECEIPT
(Domestic Mall Only. No Insur.l;lnc~ CoverfJg~ ProVided)
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VERIFICATION
MICHAEL D. VESTAL hereby states that he/she is VICE PRESIDENT of COUNTRYWIDE
HOME LOANS, INC. mortgage servicing agent for Plaintiff in this matter, that he/she is authorized
to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment
are true and correct to the best of his /her knowledge, information and belief. The
undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec.
4904 relating to unsworn falsification to authorities.
MrvLf [) Vu{
DATE:
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SHERIFF'S RETURN - REGULAR
.
CASE NO: 2005-00760 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
NEENAN RICHARD L ET AL
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn accordin to law,
says, the within COMPLAINT - EJECTMENT was served upon
NEENAN RICHARD L AKA RICHARD L NEENAN III t e
DEFENDANT
at 1757:00 HOURS, on the 2nd day of March
2005
at 91 COLD SPRINGS ROAD
CARLISLE, PA 17013
by handing to
RICHARD NEENAN
a true and attested copy of COMPLAINT - EJECTMENT
together with
~
~
and at the same time directing His attention to the contents t ereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
5.92
.00
10.00
.00
33.92
~~~~
, - -
-
R. Thomas Kline
Sworn and Subscribed to before
me this 7 day Of'~
01.. P <0 ) ------- A . D .
.~~"
~ </)-
-pr Prothonotary .
03/03/2005
PHELAN HAL"::kI ~
By:
,I "
Deputy Sheriff
-<
-
-
I
SHERIFF'S RETURN - REGULAR
. CA~E NO: 2005-00760 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
NEENAN RICHARD L ET AL
RICHARD SMITH
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn accordin to law,
says, the within COMPLAINT - EJECTMENT
was served upon
NEENAN CLARAMAE B
DEFENDANT
, at 1757:00 HOURS, on the 2nd day of March
at 91 COLD SPRINGS ROAD
CARLISLE, PA 17013
RICHARD NEENAN, HUSBAND
by handing to
he
2005
a true and attested copy of COMPLAINT - EJECTMENT
togethe with
and at the same time directing His attention to the contents hereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
Sworn and Subscribed to before
me this "7 day of ~
./'"'.
d-P,Q.J A.D.
t /u'./ .111.( t . - -t ~
- prothonot;~ -r0
So Answers:
r-~~
R. Thomas Kline
03/03/2005
PHELAN HALLIN
By:
--
Sheriff
PHELAN HALLINAN & SCHMIEG, LLP
By: Lawrence T. Phelan, Esquire J.D. No. 32227
Francis S. Hallinan, Esquire J.D. No. 62695
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY. AS TRUSTEE
FOR VENDEE MORTGAGE TRUST 2003-1, WITHOUT RECOURSE,
EXCEPT AS PROVIDED IN A POOLING AND SERVICING
AGREMENT DATED FEBRUARY 1, 2003
Plaintiff
Court of Common Pleas
CUMBERLAND County
No. 05-760-CIVIL TERM
VS.
RICHARD 1. NEENAN A/KfA RICHARD 1. NEENAN, III.
CLARAMAC B. NEENAN OR OCCUPANTS
Defendant(s)
PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE,
AND DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark
this case discontinued and ended, upon payment of your costs only.
ljps
/
~'JVC;~~
Lawrence T. Phelan, Esquire
Francis S. Hallinan, Esquire
Daniel G. Schmieg, Esquire
Attorneys for Plaintiff
Date
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