HomeMy WebLinkAbout14-0604 For Prothonotary Use Only:
-c e Courtpf Penn sylvania
Cou .0m Pleas
_�31Xltn, ,and Docket No.
'. ffl O
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The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and set-vice ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
F S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiffs Name: BENEFICIAL CONSUMER DISCOUNT Lead Defendant's Name: Ward S. Mansbarger
C COMPANY DB /A BENEFICIAL MORTGAGE CO OF
T PENNSYLVANIA
1 Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: 13 within arbitration limits
O (check one) ❑ outside arbitration limits
N
Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No
A
Name of Plaintiff/Appellant's Attorney: McCabe, Weisberg & Conway, P.C.
❑ Check here if you have no attorney (a Self- Represented JPro Se] Litigant)
I 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
I you consider most important.
IIII TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Department of Transportation
❑ Premises Liability (does not include ❑ Statutory Appeal: Other
S mass tort)
❑ Slander/Libel/ Defamation ❑ Employment Dispute:
E ❑ Other: Discrimination
E C ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other
I
I
O ❑ Other
N MASS TORT
❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
B ❑ Toxic Waste. ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/fenant Disput ❑ Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
j ❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/1/2011
McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. S WARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716 x °'
JOSEPH I. FOLEY, ESQUIRE - ID # 314675 ' --M
=
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 ;= CD L c - )
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
.._ CO
LENA KRAVETS, ESQUIRE - ID # 316421 cj .
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790 -1010
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
BENEFICIAL CONSUMER DISCOUNT Iq
COMPANY D/B /A BENEFICIAL MORTGAGE CIVIL ACTION NUMBER: �(J`7
CO OF PENNSYLVANIA
961 WEIGEL DRIVE
ELMHURST, IL 60126, COMPLAINT IN
MORTGAGE FORECLOSURE
Plaintiff,
■
V.
WARD S. MANSBARGER
428 PROWELL DRIVE
CAMP HILL, PENNSYLVANIA 17011
-
AND
= KELLY A. MANSBARGER
428 PROWELL DRIVE
CAMP HILL, PENNSYLVANIA 17011
Defendant(s).
CIVIL ACTION/MORTGAGE FORECLOSURE
PA Complaint 1 -A (CMLOwner) 11 DEC I2ver3.0
1
t
1. This is an action to foreclose a mortgage brought on behalf of Plaintiff
BENEFICIAL CONSUMER DISCOUNT COMPANY D /B /A BENEFICIAL MORTGAGE CO
OF PENNSYLVANIA.
2. The Defendants, WARD S. MANSBARGER and KELLY A. MANSBARGER
( "Mortgagors ") are the real owners of the mortgaged property hereinafter described. The last
known address of Mortgagor, WARD S. MANSBARGER, is 428 PROWELL DRIVE, CAMP
HILL, PENNSYLVANIA 17011 and Mortgagor, KELLY A. MANSBARGER, is 428
PROWELL DRIVE, CAMP HILL, PENNSYLVANIA 17011.
3. Attached hereto as Exhibit A is a true and accurate copy of the promissory note
and/or loan agreement ( "Note ") bearing the date of DECEMBER 15, 2004, in which WARD S.
MANSBARGER and KELLY A. MANSBARGER promised to pay the sum of $131,720.06
( "Loan ").
4. Attached hereto as Exhibit B is a copy of the mortgage ( "Mortgage "), dated
DECEMBER 15, 2004 and bearing the names of Mortgagors, as the mortgagors, on real estate
together with all improvements thereon, located at 428 PROWELL DRIVE, CAMP HILL,
PENNSYLVANIA 17011 ( "Real Estate "). A true and accurate copy of said Mortgage is
attached as Exhibit B. The Mortgage was duly recorded on DECEMBER 17, 2004 in Mortgage
Book 1891, Page 3483, in the Office of the Recorder of Deeds of CUMBERLAND County,
Pennsylvania.
fi
5. The Real Estate subject to the Mortgage is described in the legal description
attached hereto as Exhibit C.
PA Complaint 1 -A (CML Owner) I 1 DEC I2ver3.0
2
ti
6. The Mortgage is in default because the payments due and secured by the
Mortgage have not been made. The Loan is currently due for the MARCH 2011 payment and all
payments thereafter.
7. The business records maintained by Plaintiff, demonstrate that a combined notice
( "Combined Notice "), was mailed by registered or certified mail, to Mortgagor(s) at
Mortgagor(s)' last known address and, if different, to the address of the Real Estate, on the date
set forth in the Combined Notice. A true and accurate copy of the Combined Notice is attached
as Exhibit D.
8. As of DECEMBER 27, 2013, there is due and owing amounts secured by the
Mortgage in the sum of $171,806.03, which amount due includes the following:
Principal Balance: $121,722.83
Interest through 12/27/2013 at the Current Rate
of 8.48000%: $44,077.17
Advances for Taxes: $2,171.35
Advances for Hazard Insurance: $3,834.68
Advances for Private Mortgage Insurance: $0.00
Total: $171,806.03
Less Suspense Balance or Escrow surplus, if
any: $0.00
Less Restricted Escrow Balance, if any: $0.00
Total Amount Due or Owed: $171,806.03
The per diem interest due from DECEMBER 28, 2013 is $28.2797. These itemized amounts
may not include all fees currently due and owing under the Note and secured by the Mortgage,
PA Complaint I -A (CML Owner) I 1 DEC 12ver3.0
3
including certain late fees, inspection charges, property preservation expenses, and attorney's
fees, since Plaintiff has decided to forgo collecting those fees, but that decision does not indicate
that such fees were not properly due and owing at the time of any prior communications to the
borrower(s) on the Note.
WHEREFORE, Plaintiff demands in rem judgment against the Defendant in the sum of
$171,806.03, together with the current interest at the rate of 8.48000% and other costs and
charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged
property.
By:
McCABE, & CONWAY, P.C.
Attorneys For Plaintiff
VERIFICATION
I am a VPghd -1� 5 "-C- of the Administrative Services Division of the Plaintiff and
do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff
and the facts set forth in paragraphs 1 through 8 of the foregoing Complaint are true and correct
to the best of my information and belief. I understand that false statements therein are made
subject to the penalties relating to unsworn falsification to authorities.
By.
Signature
L -R, w r'- 'Jce- - Fb- TTRZ)A,e
Printed Name of Signatory
On behalf of BENEFICIAL CONSUMER
DISCOUNT COMPANY D/B /A BENEFICIAL
MORTGAGE CO OF PENNSYLVANIA
Its: V �' PtS'S - r '.
Signatory's Title
PA Complaint 1 -A (CML Owner) 1 I DEC I2ver3.0
4
LOAN REPAYMENT AND SECURITY AGREEMENT (Page 1 of 4)
LENDER (called "We ", "Us ", "Our ")
BENEFICIAL CONSUMER DISCOUNT COMPANY OIBIA BENEFICIAL MORTGAGE CO OF PENNSYLVANIA
4910 CARLISLE PIKE
SUITE 104- HAMPOEN CENTER
MECHANICSBURG PA 17050
BORROWERS (called "You ", "Your ") LOAN NO.
MANSBARGER, WARD S
Ss# �
MANSBARGER, KELLY A
Ss#
428 PROWELL OR
CAMP HILL PA 1 1011
DATE OF LOAN FIRST PAYMENT DUE DATE OTNERS SCHEDULED MATURITY CONTRACT RATE
12/1512004 01 t 15120p6 WN MOM BA11 12115/2034 8I 0 %
AMOUNT FINANCED PRINCIPAL
124,999.06 131,120.06
CLWING FEE OFFICIAL F10
t 135.04 48.50
LIFE INS PREMIUM DISABILITY INS PREMIUM IUI PREMIUM
1158.08 Monthl t NONE NONE
ORIGINATION FEE /FEE
6.586.00
T iNSTA L ENT MONTHLY Ns7 TERM PERIOD
1,169,01 1,1$8.01 360
PREPAYMENT PENALTY
Y ES
■
YOU ARE GIVING US A SECURITY INTEREST IN THE REAL ESTATE LOCATED AT THE ABOVE ADDRESS,
REQUIRED INSURANCE. You must obtain insurance for tarns of loss covering security for this .loan as indicated by the
word "YES" below, naming us as Loss Payee
YES Title insurance on real estate security
YES Hazard Insurance on real estate security.
You may obtain any required insurance from. anyone you choose and may assign any other policy of insurance
you own to cover the security for this loan.
(See "Security" paragraph above for description of security to be insured.)
NOTICE. THP.. FOLLOWING PAG CONTAIN ADDITI A CONTRACT T RMS.
1ST'MTG PPP FA1365891
a177017259394CEA9000PAB858910 " s ORIGINAL EXHIBITA
LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 4)
PAYMENT, In return for your loan described below, you agree to pay us, the Principal and Interest computed at the
Contract Rate (subject to any adjustment under the Adjustment to Contract Rate Section below) and any monthly
insurance premium, if elected, until fully paid. Principal is Amount Financed, plus The Fee. The term Fee means the
Origination Fee (Fee) shown an page one. You shall pay us monthly payments, at our business address or other address
given you. If more than one Borrower is named on page one, we may enforce this Contract against all, or any Borrowers,
but not in a combined amount greater than the amount owed, Payments are applied in the following order: late charges,
interest at the Contract Rate for the actual time outstanding, principal, and insurance. For any past due amounts, payments
will be applied to the most delinquent monthly installment first, in the same order shown above, until all past due
monthly installments are paid in full.
DATE ON WHICH INTEREST .BEGINS. If you do not cancel this loan, the date on which Interest begins, payment dates,
and effective date of insurance purchased are postponed by the number of days from this contract's date to date you
receive this loan,
ADJUSTMENT TO CONTRACT RATE. The Contract Rate, as shown on page one, will decrease by one quarter of one
percent (.25) beginning with the thirteenth (13th) month after every twelve (12) consecutive month period where all
payments were made in full within 30 days of their due date. Up to maximum of twelve (12) Contract Rate reductions are
available during the term of the loan. For each Contract Rate reduction, the monthly installment payment will be reduced
accordingly. Notwithstanding anything to the contrary in this paragraph, you will not receive any Contract Rate reductions
or the reduced monthly payment after four periods of delinquency. A "period of delinquency" begins when you fail to
make a payment in full within 30 days of the due date and ends when you have no payments that are outstanding for more
than 30 days past their due date,
PAY You agree to payouts of Amount Financed as shown on Truth- In-Lending disclosure form. If payouts
change because loan closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will
be reduced to cover additional payouts.
PREPAYMENT. Subject to your choice of a Prepayment Penalty on this loan, you may prepay any or all of your loan at
any time. If you chose a loan with a Prepayment Penalty, the word "YES" will appear in the Prepayment Penalty box on
page one of this Agreement. In any event, if you fully pay before the final payment due date, the amount you owe will be
reduced by unearned credit insurance charges, if any. If you prepay before the final due date, Points and Closing Fee are
fully earned when this loan is made and you will not receive a refund of that part of the Finance Charge consisting of
Points and Closing Fee,
PREPAYMENT PENALTY. If "YES" is printed in the Prepayment Penalty box on page one of this Agreement, you agree
to the following penalty. If you prepay in full within two (2) years of the date of this loan shown on page one, you agree to
a pay a Prepayment Penalty equal to six (6) months interest at the Contract Rote (as stated on page .one) of the unpaid
principal balance. No Prepayment Penalty will be imposed (a) if this loan is refinanced by another loan with us; (b) after
two (2) years, (c) if the loan is prepaid from the proceeds of any insurance; or (d) if we sue you,
LATE CHARGE. If you don't pay any payment in full in 10 days after it's due, you will also pay 5% of the unpaid
amount of such payment.
BAD CHECK CHARGE. We will charge you a fee of $20 if any payment check is returned because of insufficient funds or
is otherwise dishonored. You agree that we may deduct this charge from a monthly payment.
SECURITY. There is a mortgage on your real estate, located at your address shown on page one unless a different address
is stated. You agree to give us a security interest in the real estate as described in the Mortgage/Deed of 'Trust.
PROPERTY INSURANCE:
A. YOUR OBLIGA'nON TO INSURE. You shall keep the structures located on the real property securing this loan
insured against damage caused by fire and other physical hazards, name us as a loss payee and deliver to us a loss payable
endorsement. If insurance covering the real property is or expires while the loan is outstanding and you do not
reinstate the coverage, we may obtain, at our option, hazard insurance coverage protecting our interest in the real property
as outlined below.
B. LENDER'S RIGHT TO PLACE HAZARD INSURANCE. You authorize us, at our option, to obtain coverage on the
Property in an amount not greater than the outstanding balance of principal and interest on the loan or, if known to be less,
NOTICE; THE FOLLOWING PAGES CONTAIN ADDITIONAL CONTRACT TERMS,
05-t8 - 04 RE $' PA865892
1111111 ��11�I1�1�� � 1111 111111lit1111 111 Ilfi�� 111�LXHIBIT A
1ST MTG OPT PPP
*177017259394CEA9000PA685892O N4A"aAROER " ORIGIML
LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 4)
the replacement value of the Property, in the event that you fail to maintain the required hazard insurance outlined above
or fail to provide adequate proof of its existence. You authorize us to charge you for the costs of this insurance and add the
insurance charges to your loan. The Insurance charges will be added to the unpaid balance of the loan which accrues
interest at the Contract Rate. The addition of the insurance charges slue might increase the amount of your final
installment. The cost of Lender placed hazard insurance might be higher than the cost of standard insurance protecting the
property. The Lender placed insurance will not insure the contents of the property or provide liability coverage. The
insurance might not be the lowest cost coverage of its type available and you agree that we have no obligation to obtain the
lowest cost coverage. We or an affiliated company might receive some benefit (i.e, commission, service fee, expense
reimbursement, etc.) from the placement of this insurance and you will be charged for the full cost of the premium
without reduction for any such benefit. If at any time after we have obtained this insurance, you provide adequate proof
that you have subsequently purchased the required coverage, we will cancel the coverage we obtained and credit any
unearned premiums to your loan.
DEFAULT. If you don't pay on time or fail to keep any required insurance in force, or if permitted in the event of default
under the Mortgage, (1) all your payments may become due at once and, (2) without notifying you before bringing suit, we
may sue you for the entire unpaid balance of Principal and accrued Interest and (3) any judgment in our favor may include
our reasonable attorney's fee and court costs as determined by the court. You agree that, should we obtain_ judgment
against you, a portion of your disposable earnings may be attached or garnished (paid to us by your employer), as provided
by Federal law. You agree to pay interest on any judgment at the Contract Rate.
CREDIT REPORTING AND CUSTOMER INFORMATION PRACTICES. If you fail to fulfill the terms of your credit
obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree
that the Department of Motor Vehicles (or your state equivalent of such department) may release your residence address
to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls
between you and our representatives in order to evaluate the quality of our service to you. You understand and agree that
we will call you from time to time to discuss your financial needs and any loan products that may be of interest to you as
may be permitted by Applicable Law. For more information regarding our privacy practices, please refer to our Privacy
Statement, which is included with your loan documents,.
OPTIONAL INSURANCE. Optional credit insurances and any required insurance disclosures are attached to this
Agreement and are incorporated herein by reference.
ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDERS. The terms of the Arbitration Agreement and any
other Riders signed as part of this loan transaction are incorporated into this Agreement by reference.
APPLICABLE LAW. This loan is made at an agreed rate authorized by Section . Part A, Title V, Public Law
96"221, also known as Section 1735f (a), Title 12, United States Code (USC).
If you do not pay the full amount of an instalment when it is due, and we intend to foreclose on the Mortgage, we must
comply with the provisions of Section 403 and 404 of the Act of January 30, 1974, which is known as Act No. S, and the
provisions of the Homeowner's Emergency Mortgage Assistance Act (Act No. 91 of 1983).
NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS.
05 - HE SI PA065993
1ST NlTG OPT PPP I IIIINIIII 1111 III �1111III im�IiIIIII11 I B II I
* 177017259394crA9000PA96SOS3C %4A"B »GtH EXHIBIT A
LOAN REPAYMENT AND SECURITY AGREEMENT (Page 4 of 4)
ANY ADVANCE OF FUNDS PURSUANT TO THIS LOAN REPAYMENT AND SECURITY AGREEMENT
AND THE MORTGAGE WHICH SECURES THE AGREEMENT MAY, IN THE EVENT OF ANY
DEFAULT, RESULT IN THE LOSS OF YOUR HOME OR OTHER REAL PROPERTY PLEDGED AS
SECURITY FOR YOUR LOAN.
YOU HAVE RECEIVED A COMPLETE
COPY OF THIS AGREEMENT AND THE
TRUTH -IN- LENDING DISCLOSURES,
BORROWERS:
(SEAL)
(SEAL)
NESS: (SEAL)
s -18 - R E sr Iil ® I IIIII� � XHIBIT A PAB65894
i ST MTG OPT PPP
* 1770172S9394CEA9000PA8658940s 'Qr44iW WGER ORIGINAL
(Page 2 of 10)
.r
r • ♦ a ______.____.. __
ZC_n -UZR Of —DEEDS
0 6c- C- 28__Wj_� -
- BOX�S�HECKED; THIS RIOR�' GAGE I"N GPEN=E MORTGACE - AN ^
SEC_LIRES EVUVRE- _IZVAN_ > S
THIS MORTGAGE is made this day 15TH of DECEMBER 20 , between the
Mortgagor, WARD- S— MANSBARGER- AND - KELLY- A- .- MANSBARGER,- HUSBAND- AND -W if-E
- ereiu- orrowei =and- ortgai6ii =BE - NEFjC TAL`CONSUMERD 1 SC COMPANY =B�BI"
BENEF- -1_C 1_AL- M9A_TGA_GEC P ENNS Y LV AN I A
corporation- organized- and- existrng- under - the - laws -of- NS - - . -hose
address is 4910 CARLISLE PIKE, SUITE 1 04-HAMPOEN CENTER, MECHANICSBURG, A 17050
The_ following -par__a.graph_ preceded by achecked box_is applicable.
WHEREAS, Borrower is indebted to Lender in the principal sum of S 131. 720:06
==== e videnced- b"orrower!s=L Repaysneni_and Seeuri>;y Agree o r- Secen -y- - r-t -s age- n
Agreement dated DECEMBER 15, 2004 and any extensions or renewals thereof (herein
"Note" ), providing r or monthly ins a Iments oo principal and - in eresr inOwding - any adjustmertsrto�tlE
amount of payments or the contract rate if that rate is variable, with the balance of the indebtedness, if
not soener- paid,-due- and- payable-on DECEMBER -.5,- 208-
WHEREAS, Borrower is indebted to Lender in the principal sum of $
or -so- muchth- as mad! be advanced pursuant to Borrower's Revolvin an A eement Uatea
and extensions and renewals thereof (herein "Note "), providing for
mfln +ns a1 meats ands tes ose;inciudin"
A djustments_ in_the_interest-rateLif that_r_ate -is vari_a- Isere, aad rov-iding_for a credit limit stated in the
principal sum above and an initial advance of $ ;
TO_SECUR endee the repayment of (1) the indebte evidenced by the Note, with
= interest thereon, includg inany increases if the contract rate is variable; (2) - future advances under a
Revolving Loa r en -0 - e t�f all= other =sums wi#IV- int
accordance herewith to protect the securi�f - this Mortgage; and - (4) - the perfntntiance of the covenants
and- a g feet-nents- -ef - - Bor- rower- herein -- contained, B does_her_eby__mortgage- gr ant and convey to
Lender and Lender's successors and assigns the following described property located in tEe County o
UMBERLAN - ommonwealth el R�nnsy#vani
Att - 0 CERTA 1 PROPERTY - S 1 - ED 1 T HETOWNSH I-P- OF- HAMPOEN
I_N_THE COUN OF CUMBERL AND COMMONW OF
PENNSYLV ANl - A ; BEl - NG DESCRI'BED AS - FOLLOWS - LOTS - 9 AND - 10.
BE -I- PIG - MORE — FULL -Y -D €SCR- I_SED- I -N -A- DEED- DATED_06 AND
RECORDED 06/17/1992, AMONG THE LAND RECORDS OF THE COUNTY
to -z CaI��IUED ON EXHIBIT A -LEGAL DESCRIPTION eaooa
1 .11 1111 11 I Ill Illl 1111111111111111111111111111 lilt 311111111111111111 - 11111
,, 17-70- 173 59394MTG9 D00P_A00.12E1O�— N MANSBARGE R " OA- ►_GINAL__
i
E B
(Page 3 of 10)
r• 1
TOGETHER with all the improvements now or hereafter erected on the property, and all
ease ments - _r-ights,=appurtenances - -and - xents,::all:: c" ich= shafii be - =be= and part=nft
p roperty c overed by this M ortga ge• and all of the foregoin tog ether with said -�ropert or th i
_ l easehold- estate - if - t his Mortgageis on are - hereinafter - referred - to - as - the "Propert ."
Borrower covenants that Borrower is lawfully seised of the estate hereby conveyed and has the right
to- mor- tgage- grant and- convey -the- Property, - and -that the - property- is- unencum -bered; except for
encumbrances- of-recor --d._Borr-ower_covenants_that- Borrower- warrants -and_w -ill- defend- generallythe�i
to - the Pro erty against all - claims and demandg, subject — encumbrances of rem.
= UNIFORM COVEN_AN STS.._ B- or_m_w_er- and - Lender- co_vennni and_agree_as- f_ollo�ys:
t.- Paym-entof - Prim pal and - l - nterest - at - V - ariabie - Rates. -- This m ortgage secures all paym enu -
r- inGipal- and - interest - due- on- a- var- iable- r- a- te-loan� -contr -ac r- ate- of- i- nt erest -an d- payment amounts
may be subject to c ange as prove eed in the Dote, Borrowers sha p - lr romptly pay whe - all a amounts
_ — requi by the-Note.
= 2 Funds for aT xes and nsurance, u ject to app cable law an on y requeste m wr — icing by
Lender, Borrower shail to off day monthly of - pr ncipal�tl�irlte�es are
payable under the Note, until the Note is paid in full, a sum (herein "Funds ") equal to one of the
= yeariy taxes - and -- assessmen (iitctudin condominF m - and - p lanned - unit - devel - o me"sessm-ents - i
any) which may at tain pri ority over this Mortgage an ground r ents on the Property, if any, plus
= one twelfth of yearly premium installments for — a�d plus o1 ne o year yl premium
installments for mortgage insurance, if any, all as reasonably estimated initially and from time to time
b y Le er_on the basis of assessor _. e 5 and =bi, s_an.- _reasoraa imaies t ere — - Borro wer_shall_noY_ -
obligated to make such payments of Funds to Lender to the extent that Borrower makes such pa yments
= a the of a prior mortgage or eed of rustif such holder i an inks itu�ional - lemon er.
If Borrower pays Funds to Lender, the Funds shall be held in an institution the deposits or accounts
of which are insured or guaranteed by a Federal or state agency including Lender if Lender is such an
institution). Lender shall apply the F unds to pay said taxes, assessments, insuran premiums and
group rents. Lender may not charge or so herding and applyin analyzing said account or
veri fying and com piling said assessments and bills, unless Lender p Bor interest on the Funds
= and applicable law permits Lender to make such a charge. Borrower and Lender may agree in writing at
the time of execution of this Mortga that interest on the Fund s hall be p aid to Borrower, and unless
such agreement is made or applicable law requires such interest to be paid, Lender shall not be required
to- p ay -Bor_row-er -anyAn -or - earnings -on the_F-unds. lender-shall _eveto -Borrower,_witho
I an annual accounting of th Fu nds showing credits and debits to the Funds and the purp ose for whi
each�e _Fumes v as made'heFunds are_pI- edged�diiionaLsecur><iy fo�theaums ru
I this Mortgage.
If the amount of the Fun held by Lend t ogether with t e -tuture __monthly -installments- of_F-un
p prior to the due dates of taxes, assessment insurance p remiums and g round ren shall exceed
the- amount - required to- pay - said -axes, assessment insurance- premiums- and-- ground - rents- as- they-fal
due, such excess shall be, at Borrower's option, either promptly repaid to Borrower or credited to
Borrower- on_monthl -y- installments -of - Funds. -If the - amount- of- the-F-unds- held- by-Lender- shad- not
sufficient to pa taxes, assessments insurance p and ground r_ent�as�hey�all_due,_Boriowe
shall- pay- to- L- ender-any- amount necessary -to make - up - the - deficiency - in - one or -. - ender
may require.
Upon-payrnent in- ful -l-of -all- sums - secured -by- this - Mortgage; L- ender - shall - promptly- refund -to —
Bor-r_ower_anyJ-unds_held_by- Lender -If -under - paragraph- 1.7_hereof_ the_ proper- ty-is- solder- theProperxy
10-20 -03 MTG PA0012E2
lul l_I��I I �Illll llllll111 11111 I IIINlll1111111( 11111111111111111111 1 111111 1111111111 oi 111111111111
- % 171017259394MTG9000PA0012E20MMMANSBARGER " ORIGINAL
i
(Page 4 of 10)
-3-
is otherwise acquired by Lender, Lender shall apply, no later than immediately prior to the sale of the
rope - - woe i
ts acquisition by Lemon er — any Funds�eld - by Lender et t�time a applicati na as ?� crit
— agamstt e sums_secu - -y -this- orxga
3. Application of Payments. Except for loans made pursuant to the Pennsylvania Consumer
Discount Company Act, all payments received by Lender under the Note and paragraphs 1 and 2 hereof
shall -be- a b L-,endcr- fi-rst-in- pa -of- amounts pay able -t o-Lender- by- Borrower_under_par-agrap
2 hereof, then to interest, and then to the principal.
4. Prior Mortga and Deed of Trust; Char ges; Liens. Borrower shall perform all of
- Borrower's obligations under any mortgage deed of trust or other sec urity agreement with a lie w
lia s - pri - arity - over - this - M - ortga ge;includmg Borrower' s - toting e- paw- whe�ue.. Borrower
shall pay or cause to be paid all taxes, assessments and other charges, fines and impositions attributable
to - Property - which - may - attain - a - priority - over this- Mortgage, leasehold pay meats - ound -ren ,
s
if-an,
5. Hazard Insurance. Borrower shall keep the improvements now existing or hereafter erected on
t he-P- roper -t -y- insured - against _loss- b- y_fire, -hazardsincl.uded wishinthe term "extended coverage = and such
other haza as Lender may re
he iinsurance carrier providing the insurance shalI be cchosen b he Borrower sut lect to approver
Lender provided, that such approval shall not be unreasonably withheld. All insurance policies and
renewals then shall - be in a form accep able to Lean er and shall standard - in
favor andina form acceptable L shal - 1 - have t-he -right to- hold - the - policies- and- r- enewals
thereof, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which
h as_ n,ority - gt _a_ge.
In the event of l oss, Borrower shall g ive P rompt notice to the insurance carrier and Lender. Lender
may make proof of loss if not made promptly by Borrower.
If the Property is abandon by Borrower, or if Borrower fails to re spond to Lender w ithin 30 days
f rom the date notice is mailer by Len thatthe - insurance - Eimerr fers _ claim fo
insurance benefits, Lender is authorized to collect and apply the insurance proceeds at Lender's option
either to r estorati on or repair of th Property or to the sums secured by this Mortgage.
_ Preserva #ion-and- i= nnenanse -of =P- roper- t - Coed om iniu-ms;= P- launed i)nii
n ev-eloptnents ._Borrower_shall_keep their-oper_tyin -good- r-e- pair_and -shall com mit waste or rmit
impairment or deterioration of the Property and shall comply with the provisions of any lease if this
Mortga ge_is_on -a easehold.- this - Mortgage is on a_unit -in a condo or a planned unit develo pment,
Borrower shall perform all of Borrower's obligations under t eclarat�on or c or sing or
governing the condominium or planned unit development, the by and regulations of the
condominium or planned uni development, and constituent documents.
' �'roteciion of =Le 's ecur t lf= Bar- rowe�fails:lo= perform -the= covenants -an _agr_eements
contained in this Mortgage, or if any action or proceeding is commenced which materially affects Lender's
interest in the Property, then Lender, at Lender's option, upon notice to Borrower, may make such
a ppea.r_anc-m-- _disbucse_such- sums inc4- udi "n atxor- neysfees, -and -take- such- actionas_is_necessary
to protect Lender's interest.
Any amounts disbursed by Lender pursuant to this p aragraph 7, with interest thereon, at the contract
r ate,_ shall_ bec- o.m- e_additiQnal_i.ndebtedn of Borrower secured b y this Mortg Unless Bor rower an
ffder agree to ayment - such amounts= shall be- payaab e- u=por� ice- from�ender�t- o=
Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall require Lender to incur
any e xpense or take any action hereunder.
PADD12f-
TO= ZD= D3 - MTG
I111111111111111111III mill 11111 oil 1111111111111111111111111 I IN 11111111111- 11111 -III 1111111ill 1111
7 T7- 2b9394MT -G9000PAAGD-12E30"NMANSBARGER GiNAt
DX Flul- 9 -{-P -G 3 -4 -g 5 EXH.IBI_T_�
(Page 5 of 10)
r
8. Inspecti Lender may take or cause to be made reasonable entries upon and inspections of the
roperty- prov>ded= tha� -L - en e-r -s -gry ctiun peci#
reasonable- cause therefac-r-elated-to- Lender's- inter-estin-theP -
9. Conde n ion. ['he p - mss of ny - award or - ciaiTn for ,direct -or- consequential in
connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu
of con- le de are and - shat be to Lender,- sabjeet to the terms of -arry- mortgage deed
f- trust -or- othe secu rityagreernen #itha law -hich has prior -ity overthisiortg
0.Bofrower Not Release — eased; By Lamer Not a Waives. Extension of - ti3ne - for
payment or- m odificati on -of- amor tization - -the- s ums - secured - bythis Mor_tgage -granted -by Lender to any
successor in interest of Borrower shall not operate�o release, in any �rit►er - tlie llability�f the original
Ba and - Borrower's successors - in - interest - L en der - shall - not -- be - require - to - commence proeeedi - ngs
against such successor or refuse to extend time for payment or otherwise modify amortization oft e sums
secured - bythis - Mor tgag ebyreasonof- any - demand- made -by- theoriginal Borrower and - Ber - rower's - successor - s
in interest. Any forbeara by Lender in exercising any right or rem h ereunder, or of erwise farmed by
app icablee law, shall not be a war ver o or prec ud lie exercise of any such sight or �em�dy.
11. Successors and Assigns Bound; Joint and Several Liability; Co- signers. The covenants and
agr_eeme ereingained Shari bi d ri ghtyhereunder shall tth - res ctivesuccessors and
assi gns of Lender and Borrower, subject to the provisions of paragraph 16 hereo All co venants and
agreements of Borrower shall be joint and several. Any Borrowe r w o co this M rtgage, but does not
execute the Note, (a) is co this Mortgage only to mortgage, grant and convey that Borrower's interest
_ . . .nthe -P -r- oiler -ty-to Lender -under_the- tersns.o Ahis- . ortgage, _ _ not-persona y_ ia. eon t e- o e or - under
this Moxigage and (c) agrees that Len and any other Borrower hereunder ma ag ree to extend, modify,
f orbear, or ma a any other accommo ations wiih regard to the terms ofthi`s Mortgage ort e o e wit )ou
that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that
Borrower's interest in the Property.
12. Notice. Exce for any notice required under applicable law to be given in another manner, (a) any
notice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing suc if notice by
certified -mail- addressed to- Borr-ower_at the Psoperty-A or at such other address a s Borro ma y
= designate by notice to Lender as provided herein, and (b) any notice to Lender shall be given by certified mail
= to Lende address s tated herein or to such other address as Lender ma desi b noti to Borrower as
= provided herein. Any notice provided for in this Mortgage shall be deemed to have been given to Borrower
_ ^ Lender- w- hcn- ai- ven-in- the - manner - desi gnated - herein.
= 13. Governing Law; Severability The applicable law contained in the Note shall control. Wher no
a pplica- blelaw is- contained- therein,- thestate - and - awsapp caabie -to -this- orthI
hill
�eI it-- elaws_of t e
jurisdiction in which the Property is located. The foregoing sentence shall not limit the applicability of
_ Fede ral-law -to- this - Mortgage. -In- dw- eventthat any-provision- or-clause-ofthisMortgage- orthe -N -ote confli -c_ts
with applicable law such con flict shall not affect other provisio of this Mort or the Note which c an be
ven effect - without the - conflicting -provision ,and- and-end the-provisions- of�his lvloetgage and the Not
are declared to be severable. As used herein, "costs," "expenses" and "attorneys' fees" include all sums to the
— e xtent- not- pr- ohi- bited�by- applicable-law- orlimited- herein.
= L4— B- otr-ow- ees_Cop-y -Borrower_ shall_be-furnis.he -d_a_cQnfoarmned copy of the Note and o th is
a s W orafterrecardatiorifiereof.
15. Loan Agreement. Bor rower sha fulfill all of Borrower's obligations under an
= home - rehabilitation — improvemrent, repair, or- other - loan agreeme tt- -which- Borrower - enters - into -wi
T e nder: - Lend o l-cr cnd er's- option, - may- r- equir- - Bvrr- ower-to- execute and- deliver to- Lender, -in-a -form
acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against
10 up i lf�(IIIIII III�111111111i ►11111111illt llllllf 1�11llllllillllllllll Illl�l�tlll� qty
70 -20 -03 M -s P_=_QE
" 177017259394MTG9000PA0012E40MI'MANSBARGER ORIGINAL
3 4 8 6
E—XHI- BI-T- -B
(Page 6 of 10)
— _
_ ____46.-Transfer-of-the - P- r I�Bor -r -over sells -or transfers - alt -or- any- part_of_ the -P-r- oiler -ty -or
an interest therein, excluding (a) the creation of a lien or encumbrance subordinate to this Mortgage,
'b) a ransfer- ntror�::by= operation lazes upon= the - death- of- a tenant, -( -c)= the gran --
of any leasehold interest of three years or less not containing an option to purchase, (d) the creation
_ o f: - _a_ puree znoney-7-secur-ixy- interest for_- household- appiiamesj t r$nsfer- to- aseiati — r esulting
from the death of a Borrower, (f) a transfer where th spo use or children of the Borrower become an
wner - o - the -prope ns er -resul -zing -from ecree- rssolut-on of-man tag , ega{
= se agreement, or from an inc p ro e�rty settlement a by which the s pous e of
the Borrower becomes an owner of a proper y(h) a tr" ansfer into an tier vivos trus ir�wtricfi t
- Borrower i a nd remains a beneficiary and which does not relate to a tr ansfer of rights of occupancy
in the property, or (i) any other transfer or disposition described in regulations prescribed by the
F- ederaLHome_ - oan-Banl- Board,-Bor -r-ow- er_shalLcause -to -be -submitted _ infD- rmation requited b y
Lender to evaluate the transferee as if a new loan were being made to the transferee. Borrower will
= onti true- to- be- obl-igated--under--t-he- Note- and - this - Mortgage - unless - Lender• r- eleases- - Borr- ower -i-n
writing.
Ifil der does not agree o such sale rir tyansf - declare al1 - the - sums secured by this
ortgage to im and - payable: I -f- Lender-exercises- such - option- to- aEeeierate,- 4.eader-shall
mail Borrower notice of acceleration in accordance with p aragra ph 12 hereof. Such notice shall provide a
period o not T_ ss than 30 dayss fromthe da e e notice is mate or detivered within w$icfi
may pa the sums declared due. If Borrower fails to pay such sums prior to the expiration of s uch
period, Lender may, without further notice or demand on Borrower, invoke any remedies permitted by
na ra graph- 17__her-eof
= NON COVENANTS. Borrower and Lender further covenant and agree as Follows:
1
Acceler ;- Remedies xcep - as- p_ ie pafagce h- ib hereof, Berrctwtr's
breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to
= due any -sums-seem r �by= this -I�Ior -gage, er -prir -tom arse gig
_ notice to Borrower as provided is paragraph 12 hereof specifying: (I) the breach; (2) the action
require�ic to cure such breach; (fir a dat , - less ban - 30 - days f7om the - t e notice is
mailed to Borrower, by which such breach must be cured; and (4) that failure to cure such
breach on or before the date - in the notice - resu t - a ecc oration -moo -t -sums
-_
sec-ur -lLy--this- Mort - gagc Jor- eclosure by judicial proceeding, and sale of the Prop erty. The
notice shall further inform Borrower o the right to reinstate of er accelera ion and the right
a _ to wssert_i_n t_he_ forec p -t -he- none- xis tence- of- a- defaul- t- or- an �other_defease�
Borrower to acceleration and foreclosure. If the breach is not cured on or before the date
!tiedin- the - notice, Letrder atender =s optiott��rray= declare_a:li -of =the su_secursd by_th
Mortgage to be immediately due and payable without further demand and may foreclose this
- ortgage - by judici$1 proceeding. Lender - shall - be - emit - led to- collect -in- such- pr- occedin- g-al-1
e xpenses of fore closure, includi but n limited to, reasonable attorneys' fees and costs of
documentary evidence, abst>�s and Title reports.
18. Bor Right to Reinstate. Notwithstandin Lender's acceleration of t he sums by th is
Mortgage due to Bo rrower's breach, Borrowe shall h the right to have any proceedings begun by
Lender to enforce this o diseont)n� at any time pr ior to entry y of a jud enforcing hi
Mortgage if �a�Bo Lender all sums which would be then ue under this ortgage and
the -Note- lad- no-acc- eler-ation occurred�-(b)Borro cures all breach of an other covenants or
10 -20-03 MTG PA OT
111110 1118 I ll l 1111111 1/1 x{ 1111111 111 1181 I IIII 1 1 1 1 1 1 1111 II I I 1 111111 I I II 1 1111 1111111 IN 1 IN III
" 111017259394MT09000PA0012E50M MMMSBARGER " ORIGINAL
(Page 7 of 10)
6-
agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable expenses
incur - red= by= lyendera n= enforcing- the enants =and- agmem enrs = Borrower =contained=in -thi
Mortgag and in enforcing Lender's remedi as provided in paragra 17 hereof includin but not
limited - to - reasonable attorneys' fees; and -(d)- Borrower - takes -such- action -as- Lender- may- reasonabl - y
require to assure that the lien of this Mortgage, Lender's interest in the Property and Borrower's
obl- i- gation -te- pay - the - sums- secured -by -this- Mor-tgage- shall- conti- nue- uni-mpai- red.-Upon- such -pay -men
and - cure - -- Borrower,- this - Mortgage- and- the_ obli. gati. ons - secured-her -eb-- y_shall -remain -in -full _ for -ce -and
effect as if no accete� ion had occurred.
- -Assignment_ oL-Rentc- Ap- po- intment_ of- Rec.eiver.-As_addi.tionaLsecurity hereunder
wer hereby assigns to ender the of the - Property; provided that - Borr prior
acceleration- under- paragraph47- hereof, -in- abandonment -of -the Property have- the - right to- collectand
retain such rents as they become due and payable.
' T pon -ac - c-eleration- under - par- agraph-1 hereof-or- abandonment of- the-- Pr- oper-t-y-L- ender - shall --be
entitled to have a receiver appointed by a court to enter upon, take e possession of and manage the
rope and to coil a rents f tfie Property including t1� past due. Allrent�caltected�y the
receiver shall be applied first to payment of the costs of management of the Property and collection
of rents; iriclndi , but- sat receiver's feesEremiums on - receiver's - bonds and reason
attorneys' fees, and then to the s ums secured by this Mortgage. The receiver shall be liable to account
on y for t ose rents actua ly received.
20. Release. Upon payment of all sums secur by this Mortgage, Lender shall release this
1v1or gage wi_ other charg to Bo�rower._Borrowe.r_shallay al cos_ o reco a ton zany_.
21. Wai of Homestead. Borrower hereby waives all ri of homestead exemption in the
Property under state or Federal - law.
22. Interest Rate After Judgm ent. Borrower agrees the interest rate payable after a judgment
is entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note.
23. A rbitration Rider to N ote. The Arbitration Rider attached to and made a part of the Note
is hereb eference and made a part of this ortgage.
(THIS SPACE INTENTIONALLY LEFT BLANK)
10-20 MTG IIIIII�INI�IINIII�III�IIiI � llt� 1111fllllTIIIIINf< IIIi�1�IiIN1111111111f111111lhlill11111 Hill IIIIIIIIIIIIIIIIfIi PA0012EIS
" 177017259394MT09000PA0012E60 ""MANSBARGER " ORIGINAL
EXkuBIT B
(Page 8 of 10)
•
- 7
REQUEST F OR NOTICE OF DEFAULT
- ND FORECL UNDER SUPERIOR
MORTGAGES_0"EEDS F TRUST
Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a
_ lien which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth on
page one of this Mortgage, of any default under the superior encumbr nce and o any sale or other
f oreclosure -actlo -- - /_ -
G - orrower
KEPLY f. BARGER' rrower
I- hereby_certif"hat_ the - precise_ addr- ess -of_thel,ender_(Mor-tgagee)-is: 4910 CARLISLE PIKE, SUITE 104
F HAFT SR11Rt^,PA 12050
On behalf of t e e—n er. By: JANINE M. SHEAFFER Title: SAI.FS ASSTSTANT
OMMONNVEALTH- OF- PEN-NS- 'EVANIA, CUMBERLAND County - ss:
I, DENISE M. CHUBB a Notary Public in and for said county and state, do hereby
certify - that — WARD S MANS AND SBARGER :i
persona known to me or proven satisfactorily to be the same person s w ose nam ffs
su scrlbe to t - he foregoing ins rat, appeared - be - fore in persots, anti acknew a ge - that
igned= and = deli- vered_ the instr-um.ent_as = -T-H =c_�= __ f ree- volunta;
act,or the uses and purposes therein set forth.
G iven under my an and official seal, , tthis 15TH day 0 FrEMBER 20 -04
COMMONWEALTH OF PENNSYLVANIA
10 S - -
My Commission expires: Denise M. Chubb, Notary Pu blic
R}� 7 - w.� '- CDUA2
My Commission Expires Oct 31, 2005
Member, Peartsylvama Association of- lotarles
COM OF PENNSYLVANIA, County ss:
I, a Notary Publ to an or sai county and state, do hereby
- rertify-tha
personally known to me or proven satisfactorily to be te same persons whose name (s
su scrybed to t�foregoi instrument; appeared before - me - this - day - in persoi, ack nowledge t $
he signed and delivered the said instrument as free voluntary
T ct-for -t-he- uses - and -pur- poses - therein- set - for -th.
Given under my hand and official seal, this day of , 20
M y commission expires:
Notary Public
This instr was prepay y:
,TANI NE _M_.__SHEAI±FER
4��� CARL SHE PIKE, SUITE 104
1Aaa ;may
MECHANICSBURG,PA 17050
UII�I IIIII �lll fill i�fl llill11111�1111111111111 I(li
111011011 Hill 11 hell loll 1111 11 11 llllll11f 6{i� 111 lllll�lf llll
M177017259394MTG9000PA0012E70 ""MANSBARGER '� DATG - RAt
E- XH I- Ba-T —
(Page 9 of 10)
_SSpaceL-Belo_w— Thisl.ine- Reserved -For- .endor_and- Record --
Return To:
R ecordsProc ing-Sevvi lres
577 Lamont Road
Elmhurst, IL 60126
Lo be rccurdt;d
• � 1 +'� -�z� n- County —P- -
.
10-20 -03 MTG PA0012E8
11Q1N1K11l IIlil 11l 11 III 11111h11II H ill oil 11 Hi 1111 llllll_��IIII= �Inil111111
* 177017259394MTG9000PA0012EB0 M ORIGINAL
fl
8 9 1 P G 3 �: EX -I-B I-T- -B
(Pgge 30 of 10)
EXHIBIT A (PAGE 1)
AND STATE SET FORTH ABOVE, IN DEED VOLUME S35 AND PAGE
777, TAX MAP PARCEn - D NO.: 10= 20-18 -98-16
1
i
_ IIIIIIIIil ID�IIIIIIIIIIIIII�IIIII�III I�llllll11111Illllllllll�lllllllllllll1111. 1111 _�_III III�III�ll�ll�lllllll�l�a
" 111017 259394MTG9000PA0012E00 N%MSBARGE - R — 6A7GINAL
i
E- XH -1 -B4 R
Exhibi 11 C 11
.........._... _
ALL TM C')sfMA.TW 1kiete or parcel of around aitvate ift R asrpde* ' Cua'ber] Q .
Cowat Comtooveeath of Ptamaylviasls, more V&rticularly hrauaadtd and deacrOed, as
follows, to Vit.
BMIXIrXM at n point on +.Nt canUr Bart of, Orr's Iridgea Road at the 7,i„ne of adjd aer�.,.'
between Lots $ and 9 on the 'hereinafter uentioned Mars -or Lott, tMace Swi% 72 '
deg"co 3 *inutea 36 *=**do West 3,,16.0 feet to the low voter zoxk of bare '
C 00dogul set Creek; thence ]North 11 degree* 52 v&nuteo 32 oeaoodo Vest bar the low
vater mark of the Cocv4oguinttt Creels 7'3.80 feet to a ppint; thence by saw North 14
degreeo 16 minutes h seccods Vest 26.% feat to e: point; dunes 'air Southern It'" of
Lot Teo. 11 Nortb 72 degr,eee 3 m1mu:tes 36 seconds Psat 112.84 toot to a part cro the
eenter lines of brir o Drupe Road-, theaca by tbt Uter $cutb. 16 degrees 38 m1autes 39
sass As tact 15.92 feet to it point: thence by amist South It degreewe 13 m1notto 59
stocada East 83.58 teat to the pout W4 place of 8f%TIMM.
WX Lt11'& 9 and 10 on the Plan of bred S. Metier as, recwrdtt# in Cu*erlmA County
Reaorde is Offlee im J'Un Nook 4 Page 101 and snorer opeciti,c ally shorn on the attached
survey fox Terry L. and Kathleen S. Schell by C. W. 4Tu0*1ns and Associates, vh3ch lots
e wmot be sold separately vitboat Towaesbip opprovel..
MAC part; or tbo where permits vhieh Aobt" R. Scht l tsteLte, et al, by deed dated
Ampot 5. 1987 ants reieorded tat said Recorder's Office La Deed Sook 32.v, Page 837
greaated and conveyed moto Terry L. Sane 1, Sr. and Kathl S. Scbell, 'tbe Cnmtaers
herein, vhc rave since been divorced by 7Detrett of Court or Coeation Pleas of Cumberland
County. 1?enaey►lvamia,.
UM:Mt Ab SUA1=T to all Act* of A6se`mbly, County and Tmonohip Ordinances,
rightc of Public Utility abd Public SCrv:cc Companies, zx1sting restrictions
wA escAmente, v1ci'b1t or of rearm, to the extent that air p+eroomo or eent1tits �
boaxe acquired ,1ego4 rights beroto.
rSMD PAAUSM An ALSO CQ3Ni" M vv&eor bad oul4tet to the folleavingn
i. A 30e right of Vm 3=V* as Pzoval Drive Awn on attached r"Vey aloaarthe:
'swedt of said Creels for iroomas had egrena for all lot amem. mov or culasequent their
lenents, users and occupier* a.:l Cireat+ceb, for themclves„ tbelr beirs and anai8ns,
6oeuaee the 2iab4l At7 at their expense to maizdein in its present cmdi ti4m that
se ct en of said right of v*y tlset caroaues said Lots 9 and LO.
2. r There fj)v#. 1 be no seltln; or minufecturixg upon the txe Atsee.
3. The ri&btt of lot avers on Bald PUn. now or embomesat oad. oil. others, it
any, leaving a 111ce 'right to u" the grmrel drive ahavn an at%selled cmx -vey , croos3* '
said preuists from i'roveU DxLyo to Orr's Aridge Aomd "a Grantees at their expanse
for th"mewlves, their teirs used, easaigns, assuage the liesbslO r to mibtolu 044d gteilfel
drite~voy in its pkeoeaat catictltioo on twat section of sesaie which is on eaid Loth 9 W
EXHIBIT C
McCabe, Weisberg & Conway, PC
PO Box 9025 9 9025
Temecula 7196 90116 9296 3637 3732
deuce to: 2p12'�2'10 132
Send CorreSP° g Conway, PC
M ��, UVeisberg
1266 Broad Street
Suite 2080 1910 Ward Mansbar
P -
Philadelph�a, A
428 P {Hill,I Drive
PA 1701
Camp
EXHIBIT D
PAACTC FLAT
7196 9006 9296 3837 3732
December 10, 2012
ACT 91/ ACT 6 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in
default, and the lender intends to foreclose. Specific information
about the nature of the default is provided in the attached pages.
The HOMEOWNER'S 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 CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS
NOTICE. Take this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit 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 I -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, PLIES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE AL LAMARD A ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED 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.
69213
Page 1
1
EXHIBIT D
HOMEOWNER'S NAME(S): Ward & Kelly Mansbarger
PROPERTY ADDRESS: 428 Prowell Drive, Camp Hill, Pennsylvania 17011
LOAN ACCT. NO.
ORIGINAL LENDER: BENEFICIAL CDC DBA BENEFICIAL MORTGAGAGE CO. OF PENNSYLVANIA
CURRENT LENDER/SERVICER: HSBC Consumer Lending (USA) Inc.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN
SAVE YOUR HOME FROM FORECLOS URE AND HELP YOU MAKE
FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOS URE --Under the Act, you are entitled to a temporary stay of foreclosure on your
mortgage for thirty (30) days from the date of this Notice. (Plus three (3) days for mailing). During that time you must
arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this
Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS
NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELINGAGENCIES - - 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 ofdesignated 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. To temporarily stop the lender
from filing the foreclosure action, the application MUST be forwarded to PHFA and received within thirty (30) days of
your "face -to- face" meeting with your counseling agency.
69213
Page 2
x
EXHIBIT D
YOU SHOULD FILER HEMAPAPPLICATION SOONAS POSSIBLE IF YOUHAVEA MEETING WITH
A COUNSELINGAGENCY WITHING 33 DAYS OF THE POSTMARKED DATE OF THIS NOTICE 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.
AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWINGPART OF THIS NOTICE IS FOR INFORMATIONPURPOSES 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: 428 Prowell Drive, Camp Hill, Pennsylvania 17011 IS SERIOUSLY IN DEFAULT because:
Y (_) IIAVE .NO'l.' �'IA €.)E 'Il }.)_E MON\T 11..1_,.L ' PAYMEN - TS for the. following 1l orlihs and Ole f `bllow.inO
amounts ar now past clue: $22,498.00 for the trionihs of .? !latch 2 {I, 20.1 1. throug.h Deceiytber 1, 2012.
Other charges have also accrued to this date in the fo ?llotiyink amounts:
Tax Advances: $2 35
The too anio vint now reqalred to cure this default., or in other words, get caught. up.ln your payments,
as of the date of this letter, is $24,669.35.
HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $24,66935, 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 checkor money order made Davable andsent
to.'
HSBC Consumer Lending (USA) Inc.
2929 Walden Ave
Depew, New York 14043
69213
Page 3
E
EXHIBIT D
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 morteaeed property
IF THE MORTGAGE IS FORECLOSED UPON - -The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up
to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees
actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the
lender, which may also include other reasonable costs. if you cure the default within the THIRTY (30) DAY period,
you will not be required to pay attorney's fees
OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - - If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and
prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then past
due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale
and any other costs connected with the SheritTs Sale as specified in writing by the lender and by performing any other
reauirements 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 FIVE 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: HSBC Consumer Lending (USA)
Inc.
Address: 961 Weigel Drive, Elmhurst, Illinois 60126
Phone Number: (888) 395 -6000
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 XX 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.
69213
Page 4
EXHIBIT D
YOU MA Y A LS 0 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.
0 TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
0 TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU Ci THE THEDEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
0 TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
0 TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE
ATTACHED LIST.
NOTE: Unless you notify this office within thirty (30) days of the date of this notice, that you dispute the validity
of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing
within thirty (30) days from the date of this notice, this office will: obtain verification of the debt or obtain a copy
of judgment and mail you a copy of such judgment or verification. You are also advised that any information
which you supply to this office may be used by us in the collection of debt. If you request this office in writing
within thirty (30) days of the date of this notice, this office will provide you with the name and address of the
original creditor.
Although we have requested that you make payment or provide a valid reason for nonpayment, you still have the
right to make a written request, within thirty (30) days of the date of this notice, for more information about the
debt. Your rights are described further, hereinafter.
THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THIS PURPOSE.
Enclosure: Validation of Debt Notice
Consumer Credit Counseling Agencies
SENT VIA REGULAR AND CERTIFIED MAIL
RETURN RECEIPT REQUESTED
r�
69213
Page 5
EXHIBIT D
Validation of Debt Notice
Pursuant to the Fair Debt Collection Practice Act ( FDCPA) (15 USC 1692), a consumer debtor is required to
be sent the following notice: (1) unless the consumer, within thirty (30) days after the date of this notice, disputes the
validity of the debt or any portion thereof, the debt will be assumed to be valid by the debt collector, (2) if the consumer
notifies the debt collector in writing within the thirty (30) day period that the debt or any portion thereof, is disputed,
the debt collector will obtain verification of the debt or a copy of a Judgment against the consumer and copy of such
verification or Judgment will be mailed to the consumer by the debt collector, and (3) upon the consumer's written
request within the thirty (30) day period, the debt collector will provide the consumer with the name and address of the
original creditor, if different from the current creditor.
Our demand for immediate payment does not eliminate your right to dispute this debt within thirty (30)
days of the date of this notice. If you choose to do so, we are required by law to cease our collection efforts until
we have mailed that information to you.
Although we have requested that you make payment or provide a valid reason for nonpayment, you still
have the right to make a written request, within thirty (30) days of the date of this notice, for more information
about the debt. Your rights are described further, hereinafter.
The Law Office of MCCABE, WEISBERG & CONWAY, P.C. is acting as a debt collector, pursuant to the
FDCPA. THIS NOTICE AND LETTER ARE AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. The Federal Trade Commission has ruled that the FDCPA does
not preclude the institution of legal action prior to the expiration of the thirty (30) day period.
Acceptance of funds and reinstatement of the mortgage are both subject to verification by my client. Please
note that I may be instructed to proceed with foreclosure and fees, costs and/or advances by the mortgagee may be due
in addition to the sum quoted above.
Please further note that any funds tendered will be subject to verification and correctness before the matter is
concluded.
DATE: December 10, 2012
McCabe, Weisberg & Conway, P.C.
for HSBC Consumer Lending (USA) Inc.
69213
Page 6
EXHIBIT D
Cumberland County
*CCCS of Western Pie •• York
55 Clover Hill Road
Dallastown PA 17313
888.511.2227 / 888.511.2227
www.cecspa.org
Community Action Commission - Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
www.cactricounty.org
I- arri:> butg Fair Housing Council
2100N 6th St
Harrisburg PA 17110
717.238.9540
Housing & Redevelopment Authority - Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907 / 717.249.0789
www.cchra.corm
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
www.ruralisc.org % pathstone_pa.htrm
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
www.adamscha.org
TA
69213
Page 7
EXHIBIT D
McCabe, Weisberg & Conway, PC
PO Box 9025
Temecula, CA 92589.9025
7196 9006 9296 3837 3749
Send Correspondence to:
McCabe, Weisberg & Conway, PC
126 South Broad Street 20121210 -132
Suite 2080
Philadelphia, PA 19109
Kelly Mansbarger
428 Prowell Drive
Camp Hill, PA 17011
EXHIBIT D
PAACTC_FLAT
7196 9006 9296 3837 3749
December 10, 2012
ACT 91/ ACT 6 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in
default, and the lender intends to foreclose. Specific information
about the nature of the default is provided in the attached pages.
The HOMEOWNER'S 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 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 NOTIF'ICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE AL LAMARD A ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED 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.
69213
Page 1
EXHIBIT E
HOMEOWNER'S NAME(S): Ward & Kelly Mansbarger
PROPERTY ADDRESS: 428 Prowell Drive, Camp Hill, Pennsylvania 17011
LOAN ACCT. NO.:
ORIGINAL LENDER: BENEFICIAL CDC DBA BENEFICIAL MORTGAGAGE CO. OF PENNSYLVANIA
CURRENT LENDER/SERVICER: HSBC Consumer Lending (USA) Inc.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN
SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE
FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE the Act, you are entitled to a temporary stay of foreclosure on your
mortgage for thirty (30) days from the date of this Notice. (Plus three (3) days for mailing). During that time you must
arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this
Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS
NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT ". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELINGAGENCIES - -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 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. To temporarily stop the lender
from filing the foreclosure action, the application MUST be forwarded to PHFA and received within thirty (30) days of
your "face -to- face" meeting with your counseling agency.
69213
Page 2
EXHIBIT D
YOUSHOULD FILER HEMAPAPPLICATION SOONAS POSSIBLE IF YOUHAVEA MEETING WITH
A COUNSELINGAGENCY WITHING 33 DAYS OF THE POSTMARKED DATE OF THIS NOTICE FILE
ANAPPLICATION 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.
AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR 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: 428 Prowell Drive, Camp Hill, Pennsylvania 17011 IS SERIOUSLY IN DEFAULT because:
YOTJ MON':l'I l -.Y :t- 'AY:NIl:;N'i:s for the followi.nst mori .lEs and the f'o €lowina
arnount:s are now past: clue: 522,498.00 for the months of March 2 -0, 20 l 1. throur:.h Dec,uuber 1, 2017.
Offier charges have also accrued to This elate in the following amounts:
Tax 42,171.3
The total aniount now regLdred to cure this default.. or in other words. get cauV-ht up in your paymenvs,
as of the date of this letter. is $24,669.35.
HOW TO CURE THE DEFAULT - -You may cure the default within THIRTY (30) DAYS of the date of this notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $24.669.35, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Pavments must be made either by cash cashier's check certified check or money order made yoyable and sent
to.
HSBC Consumer Lending (USA) Inc.
2929 Walden Ave
Depew, New York 14043
69213
Page 3
K k
E
EXHIBIT D
IF YOU DO NOT CURE THE DEFAULT - -If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage
in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property
IF THE MORTGAGE IS FORECLOSED UPON - -The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up
to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees
actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the
lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period,
you will not be required to pay attorney's fees
OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - - If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and
prevent the sale at any time up to one hour before the 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 connected with the foreclosure sale
and any other costs connected with the SheritPs 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 FIVE 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: HSBC Consumer Lending (USA)
Inc.
Address: 961 Weigel Drive, Elmhurst, Illinois 60126
Phone Number: (888) 395 -6000
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 XX 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.
69213
Page 4
EXHIBIT D
YOU MAYA LS0 HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBTOR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURETHEDEFAULT. (HOWEVER, YOU DO NOT HAVETHIS 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.
FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE
ATTACHED LIST.
NOTE: Unless you notify this office within thirty (30) days of the date of this notice, that you dispute the validity
of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing
within thirty (30) days from the date of this notice, this office will: obtain verification of the debt or obtain a copy
of judgment and mail you a copy of such judgment or verification. You are also advised that any information
which you supply to this office may be used by us in the collection of debt. If you request this office in writing
within thirty (30) days of the date of this notice, this office will provide you with the name and address of the
original creditor.
Although we have requested that you make payment or provide a valid reason for nonpayment, you still have the
right to make a written request, within thirty (30) days of the date of this notice, for more information about the
debt. Your rights are described further, hereinafter.
THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THIS PURPOSE.
Enclosure: Validation of Debt Notice
Consumer Credit Counseling Agencies
SENT VIA REGULAR AND CERTIFIED MAIL
RETURN RECEIPT REQUESTED
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Page 5
I
Y
EXHIBIT D
Validation of Debt Notice
Pursuant to the Fair Debt Collection Practice Act ( FDCPA) (15 USC 1692), a consumer debtor is required to
be sent the following notice: (1) unless the consumer, within thirty (30) days after the date of this notice, disputes the
validity of the debt or any portion thereof, the debt will be assumed to be valid by the debt collector, (2) if the consumer
notifies the debt collector in writing within the thirty (30) day period that the debt or any portion thereof, is disputed,
the debt collector will obtain verification of the debt or a copy of a Judgment against the consumer and copy of such
verification or Judgment will be mailed to the consumer by the debt collector, and (3) upon the consumer's written
request within the thirty (30) day period, the debt collector will provide the consumer with the name and address of the
original creditor, if different from the current creditor.
Our demand for immediate payment does not eliminate your right to dispute this debt within thirty (30)
days of the date of this notice. If you choose to do so, we are required by law to cease our collection efforts until
we have mailed that information to you.
Although we have requested that you make payment or provide a valid reason for nonpayment, you still
have the right to make a written request, within thirty (30) days of the date of this notice, for more information
about the debt. Your rights are described further, hereinafter.
The Law Office of McCABE, WEISBERG & CONWAY, P.C. is acting as a debt collector, pursuant to the
FDCPA. THIS NOTICE AND LETTER ARE AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. The Federal Trade Commission has ruled that the FDCPA does
not preclude the institution of legal action prior to the expiration of the thirty (30) day period.
Acceptance of funds and reinstatement of the mortgage are both subject to verification by my client. Please
note that I may be instructed to proceed with foreclosure and fees, costs and/or advances by the mortgagee may be due
in addition to the sum quoted above.
Please further note that any funds tendered will be subject to verification and correctness before the matter is
concluded.
DATE: December 10, 2012
McCabe, Weisberg & Conway, P.C.
for HSBC Consumer Lending (USA) Inc.
69213
Page 6
EXHIBIT D
Cumberland County
*CCC%, of W esters PA - York
55 Clover Hill Road
Dallastown PA 17313
888.511.2227 / 888.511.2227
www.cccspa.org
Community Action Commission - Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
www.cactricounty.org
Harrisburg lair Housing Council
2100N6thSt
Harrisburg PA 17110
717.238.9540
1 k)using & lei #evOopment l" uthocity ° Cumberland fv niy
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907 / 717.249.0789
www.cchra.com
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
www.ruralisc.orgi pathstone_pe.litrn
Pennsyluan4i Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
www.adamscha.org
69213
Page 7
EXHIBIT D
r
FORM l
Beneficial Consumer Discount Company IN THE COURT OF COMMON PLEAS OF � :A Plaintiff CUMBERLAND COUNTY, PENNSYL�A4DL �+
C)
V
Ward S. Mansbar er and Kell A. Mansbar Ter `�� Civil
g Y b - . Defendants
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE`
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, you must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date [Signatu of Counsel for Plaintiff]
69213
Page I
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:
CUSTOM ER/1"RI MARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payment Amount $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile # 1: Model: Year:
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model
Year: Amount owed: Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 " Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Da /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
I /We, , authorize the above
named to use /refer this information to my lender / servicer for the sole purpose of
evaluating my financial situation for possible mortgage options. I /We understand that I /we am/are under no obiligation
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:
I Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation (hardship letter)
Listing agreement (if property is currently on the market)
3
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 ex- puestas en las paginas siguientes, usted
twenty (20) days after this complaint and tiene veinte (20) dias de plazo at partir de la
notice are served, by entering a written fecha de la demanda y la notificacion. Hace
appearance personally or by attorney and falta asentar una comparencia escrita o en
filing in writing with the court your defenses persona o con un abogado y entregar a la corte
or objections to the claims set forth against en forma escrita sus defensas o sus objeciones
you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea
the case may proceed without you and a avisado que si usted no se defiende, la corte
judgment may be entered against you by the tomara medidas y puede continuar la demanda
court without further notice for any money en contra suya sin previo aviso o notificacion.
claimed in the complaint or for any other Ademas, la corte puede decidir a favor del
claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con
may lose money or property or other rights todas las provisiones de esta demanda. Usted
important to you. puede perder dinero o sus propiedades u otros
derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER
TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE
DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO
TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO
BELOW. THIS OFFICE CAN PROVIDE TIENE A UN ABOGADO, VA A O
YOU WITH INFORMATION ABOUT TELEFONEA LA OFICINA EXPUSO
HIRING A LAWYER. ABAJO. ESTA OFICINA LO PUEDE
IF YOU CANNOT AFFORD TO PROPORCIONAR CON INFORMATION
HIRE A LAWYER, THIS OFFICE MAY BE ACERCA DE EMPLEAR A UN ABOGADO.
ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE
INFORMATION ABOUT AGENCIES PROPORCIONAR PARA EMPLEAR UN
THAT MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER
ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON
OR NO FEE. INFORMACION ACERCA DE LAS
AGENCIAS QUE PUEDEN OFRECER LOS
Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS
32 South Bedford Street ELEGIBLES EN UN HONORARIO
Carlisle, Pennsylvania 17013 REDUCIDO NI NINGUN HONORARIO.
(800) 990 -9108
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990 -9108
PA Complaint 1 -A (CML Owner) Page 2 11 DEC 12ver3.0
This is a communication from a debt collector who is attempting to collect a debt, and any
information obtained will be used for that purpose.
Please Note: (1) unless, within thirty (30) days after your receipt of this notice, you dispute
the validity of the debt, or any portion of the debt, we will assume that the debt is valid; (2)
if you notify us in writing within thirty (30) days of your receipt of this notice that the debt,
or a portion of the debt, is disputed, we will cease collection of the debt until we obtain
verification of the debt or a copy of the judgment against you and mail to you a copy of the
verification or judgment that we obtain; (3) upon your written request to us within thirty
(30) days of your receipt of this notice for the name and address of the original creditor of
your debt, we will cease collection of the debt until we mail to you the name and address of
the original creditor, if different from the current creditor.
Case Name: BENEFICIAL CONSUMER DISCOUNT COMPANY D /B /A BENEFICIAL
MORTGAGE CO OF PENNSYLVANIA v. Ward S. Mansbarger and Kelly A. Mansbarger
Cumberland County
PA Complaint I -A (CML Owner) Page 3 11DEC12ver3.0
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson i i t ita d0 t r{R Ct�f i ''
Sheriff
Jody S Smith r, ff 2014 FEB 1 1 PM 3: f 5
Chief Deputy
Richard W Stewart CUMBERLAND COUNTY
Solicitor PENNSYLVANIA
Beneficial Consumer Discount Company d/b/a Beneficial
vs. Case Number
Ward S. Mansbarger(et al.) 2014-604
SHERIFF'S RETURN OF SERVICE
02/05/2014 02:24 PM- Deputy Jamie DiMartle, 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 Ward Mansbarger, Husband, who accepted as
"Adult Person in Charge"for Kelly A. Mansbarger at 428 Prowell Drive, Hampden Township, Camp Hill,
PA 17011.
ILA „ 0
JAI I: DIMARTLE, H P
02/05/2014 02:24 PM- Deputy Jamie DiMartle, 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: Ward
S. Mansbarger at 428 Prowell Drive, Hampden Township, Camp Hill, PA 17011.
Aat
J IE DIMARTL MPUTY
SHERIFF COST: $60.95 SO ANSWERS,
:"./1)
February 07, 2014 RONNY ANDERSON, SHERIFF