HomeMy WebLinkAbout14-0809 Supreme Court of Pennsylvania
CourW Comm n Pleas
• For Prothonotary Use Only:
aCivil',C Sheet
Cumbe(la d - _;;� County Docket No:
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
S 0 Complaint El Writ of Summons ❑ Petition ❑ Notice of Appeal
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T Members 1st Federal Credit Union Patrick J. Neal & Lisa M. Neal
I ❑ Check here if you are a Self- Represented (Pro Se) Litigant
0 Name of PlaintifflAppellant's Attorney: Karl M. Ledebohm, Esq.
N
Are money damages requested? : NYes ❑ No Dollar Amount Requested: within arbitration limits
A (Check one) x outside arbitration limits
is this a Class Action Suit? ❑ Yes O No
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Zoning Board
S ❑ Product Liability (does not include ❑ Statutory Appeal: Other
E mass tort) 13 Employment Dispute:
Slander/Libel/ Defamation Discrimination
El
C El Other: ❑Employment Dispute: Other
T Judicial Appeals
❑ MDJ - Landlord/Tenant
I ❑ Other: ❑ MDJ - Money Judgment
O MASS TORT ❑ Other:
❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
0 Mortgage Foreclosure Restraining Order
PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto
❑ Dental ❑ Quiet Title ❑ Replevin
❑ Legal
❑ Medical ❑ Other: ❑ Other:
❑ Other Professional:
P&R.C.P. 205.5 212010
S
O � ' ! j ff
3 � 1 (��IIV
FEB 12 A = : '3'
Cul COUNTY
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070 -0173
(717)938 -6929
MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
9
Vs. NO.: O �V .
�
PATRICK J. NEAL and CIVIL ACTION — LAW
LISA M. NEAL
DEFENDANTS MORTGAGE FORECLOSURE
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
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 claims 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 A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO ( \
FEE.
)2 '20/sy-?
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249 -3166 OR (800)990 -9108
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus obj ectiones a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA LISTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249 -3166 OR (800)990 -9108
IF THI'S 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.
SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE THE
VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30)
DAYS OF THE RECEIPT OF THIS NOTICE, COUNSEL FOR PLAINTIFF WILL
ASSUME THE DEBT TO BE VALID.
IF DEFENDANT(S) NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN
VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S) PROVIDE
COUNSEL FOR PLAINTIFF WITH A WRITTEN REQUEST 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 THE 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 REQUESTS 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.
IF YOU HAVE FILED BANKRUPTCY AND /OR RECEIVED A DISCHARGE, THIS
IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A
LIEN ON REAL ESTATE.
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
(717)938 -6929
MEMBERS I" FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANT(S) : CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
COMPLAINT
1
AND NOW, comes Members 1" Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1. Plaintiff, Members 1 St Federal Credit Union ( "Members 1 S r '), is a National Federal
Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA
17055.
2. Patrick J. Neal and Lisa M. Neal (collectively herein "Defendants "), are adult
individuals having a last known address of 82 Keefer Way, Mechanicsburg, PA
17055.
3. On or about March 8, 2006, Defendants borrowed from and agreed to repay to
Members lst $47,172.34 (the "Loan"). The Loan is evidenced by a Closed -End Note,
Disclosure, Loan and Security Agreement dated March 8, 2006 (the "Note ") executed
and delivered to Members 1 st by Defendants. A copy of the Note is attached hereto as
Exhibit "A" and made part hereof.
4. As security for the Loan, Defendants executed and delivered to Members 1 St a
mortgage ( "Mortgage ") also dated March 8, 2006, on all that certain real estate and
improvements erected thereon situate in Upper Allen Township, Cumberland County,
Pennsylvania known and numbered as 82 Keefer Way, Mechanicsburg, PA 17055
(the "Property "). At all times relevant hereto, Defendants have been and continue to
2
be the record and sole owners of the Property. A description of the Property is
attached hereto as Exhibit `B" and made part hereof.
5. On or about April 4, 2006, the Mortgage was recorded in the Cumberland County
Recorder of Deeds Office at Mortgage Book 1945, Page 3170. A true and correct
copy of the Mortgage is attached hereto as Exhibit "C" and made part hereof.
6. The Note and the Mortgage have never been assigned by Members 1 St and remain
held by it as a valid and subsisting obligation of Defendants.
7. Defendants obligations under the Mortgage and the Note are in default for failure to
make the bi- weekly payments of principal and interest due to Plaintiff as set forth in
the Note in the amount of $253.06 each for October 5, 2012 through January 24, 2014
as more particularly set forth and described, in part, in the Act 91 Notice attached
hereto as Exhibit "D" and made part hereof.
8. Members 1 St gave written notice of its intent to foreclose Pursuant to the Act of
January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. 3eMc ., and in particular
section 403 thereof, and of Defendants' rights in accordance with the Homeowners'
Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35
P.S. Section 1680.401(c), et. 3eMc ., by letter dated December 3, 2013, addressed to
Defendants at the Defendants' last known address set forth in paragraph 2, being the
Property, via certified mail, return receipt requested. A copy of the said notice is
attached hereto as Exhibit "D" and made part hereof.
3
9. Simultaneously, Members 1 St forwarded to Defendants the same Notices and
addressed to Defendants at the same addresses as set forth in paragraph 8 by United
States mail, first class, postage prepaid, bearing the return address of Members 1St
The Notices forwarded in said manner have not been returned to the offices of
Members 1 St as undeliverable or otherwise.
10. Defendants are indebted to Members 1" under the Mortgage in the amount of
TWENTY FIVE THOUSAND SEVEN HUNDRED FORTY and 36/100($25,740.36)
dollars itemized as follows:
a. Outstanding principal $23,142.83
b. Interest to February 10, 2014 1,182.48
c. Late charges 215.05
d. Attorney fees and expenses 1,200.00
e. Total due to Members 1 St $25,740.36
11. Defendants also agreed under the terms and conditions of the Mortgage that in the
event of default there under Defendants would pay, in addition to the amounts set
forth in paragraph 10 above, costs incurred by Members 1 St as a result of the
institution of these legal proceedings.
12. The obligation owed to Members 1 St on the Mortgage continues to accrue interest at
the rate of $4.4320 per day, through the date of payment.
13. Members 1" is not seeking a judgment of personal liability (or an in personam
judgment) against Defendant(s); however, Members 1" reserves the right to bring a
4
separate action to establish that right, if such right exists. If one or more of
Defendant(s) have received a discharge of personal liability in a bankruptcy
proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such
personal liability discharged in bankruptcy, but only to foreclose the mortgage and
sell the Property in accordance with Pennsylvania law.
14. As set forth above, Members 1 St has made demand upon Defendants to pay to
Members 1 St the amounts due under the Mortgage and the Note. However, as of the
date hereof, Defendants continue to refuse and fail to make payment of such amounts
to Members 1St
WHEREFORE, Plaintiff, Members 1 St Federal Credit Union, demands judgment, IN
REM, against Defendants, Patrick J. Neal and Lisa M. Neal, in the amount TWENTY FIVE
THOUSAND SEVEN HUNDRED FORTY and 36/100($25,740.36) DOLLARS plus interest at
the rate of $4.4320 per day, through the date of entry of judgment on this complaint and at the
legal rate thereafter through the date of payment, additional legal fees and costs of suit as well as
other costs and charges collectable under the Mortgage and for foreclosure and sale of the
mortgaged property.
jarl ect s itte ,
Date: 1'L
. Lede bohm, Esq.
eme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070 -0173
(717)938 -6929
Attorney for Plaintiff
5
CLOSED -END NOTE, DISCLOSURE,
�St FCLIRITY 4(;RFFMFNT
5000 Loulse Drive, P.O. Box 40 BORROWER'S NAME AND ADORE BB
LISA M NEAL
Mechanicsburg. PA 17055
82 KEEPER WAY
g4.ECH_,AiN_1CS6.UR.G S PA 17055
MEMBERS Is � u raR£R
S NAME
PATRICK J NEAL
PRIh.,,r ^ CO- BORROWER'S NAME
OAT 03/08/2008 MAI VHI DATE %� FIXED VARIABLE X❑ Erlployse
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed: The amount of Total of Payments: The amount
RATE: The cost of your credit as a The dollar amount the credit will credit provided to you or On your you will have paid after you have
yearly rate.' cost you. behalf. made all payments as scheduled.
6.88 % $ 18,685.51 s $ 47,17541 a $ 65.860.92
Variable Rats: If your loan has a variable rate as indicated above the Annual P—m age Rate may increase dung the tens of this transaction it the (index) changes. The
credit union will and a magln d to the Index value. The rate will Charge monthly on the firat day of the month. The rate MR never be higher then the maximum rate allowed by
low. and it wll never loo less than . Any interest rate Increases will resuh m more payments of the same amount. For Example, tryout loan was for $5,000 at 15% for 48
months and the Annual Percentage Rate Increased by 2% alter one year, the term of your loan would increase by two months
•Prefmsd Rat.: If chocked. the following applies to your loan:
® Automatic Payment Discounted Raw Because you have agreed to make your mouired monthly payments through an automatic deduction Imm your Checking15avings
Account, your ANNUAL PERCENTAGE RATE has been discounled by .20 %. The ANNUAL PERCENTAGE RATE disd ... d above In the ANNUAL PERCENTAGE RATE box Is
v the Automelic Payment Discounted Rate, This min will Increase by .20%If you cease the eutomellc payment enangamanl or fail to rzinteln suf ix9enl lunds in your account to
cover the automatic payments. In such a case, the effect of the increase will be W extend the term of your loan. Fa example, it your lwtomauc Payment Discounted Rate la 1o%
on a $5,000.00 ben for 60 months and you cease the automatic payment arts ngement, your rate will increase to 10.20 %, resulting In 1 addilbonal payrnenl.
Vedebl► Rats Preferred Losna- 11 your loan is a variable rate loon and you qualify for a preferred rate, your preferred discount is taken al the time you lake out your loon. This
initial pmfened ANNUAL PERCENTAGE RATE will then vary according to charges in the Index (as disclosed above). For example, N a variable male loan's Initial ANNUAL
PERCENTAGE RATE Is 12% at the time you lake the loan, your initial preferred ANNUAL PERCENTAGE RATE will be NIA %. Your Initial preferred ANNUAL PERCENTAGE
RATE will then vary according to the Index, as disclosed In the Variable Role' provisbn above.
Fl..d Rata Preferred Losna, It your loan Is . fixed Isle bon erd ycu qualify for a preferred rate, your ANNUAL PERCENTAGE RATE will be the preferred ANNUAL
PERCENTAGE RATE disclosed above for as long as your prelened atstus remams In effect.
Number of Payments Amount of payment► Payment Frequency When Payments Are Due Property Insurance: You may obtain property
your insurance from anyone you want that Is acceptable to
P,ym.m 259 $253.32 BI- Weekly - Beginning 0411472006 the credit union. It you gel the Insurance from the
srAgW. credit union you will pay
will be: 1 $251.94 Final Due - On 03 812 01 6 $NIA
Security: Collateral securing other loans with the credit canon the goads or pmparty Other
will also secure This loan. You era giving a eeniriry Interest in being purchased. (Describe):
your shares and/or deposit in the credit union, and:
Late Charge: If a payment Is late by 10 days or more you will Required D►posh Balance: The Annual Percentage Rate does Filing Fells: Non- Flling Insurance:
be charged ► late fee of 5% of your scheduled payment, not take into account your required deposit balance, It any. $ N/A $ N/A
ry coy Many. , you not v. t. Pay c Pena Y. Ina N:I]u Cam uM'epaayn any nlund cab p_Maa: • Mnp.rman .0 1, any ".,an np"monl n on
ITEMIZATION OF
AMOUNT FINANCED $ 47.175.41 Amount Paid to others on your behalf (Describe)
AMOU G IV EN T YO D IRECTLY $ 0.00 So' To Mnnlaoa Ul. $ To
$2.990.19 To M Lrl. $ To
AMOUNT PAID ON YOUR ACCOUNT$ 25,2B4.D8 $1.121.1 To FNB OMAHA $ To
$ 11.779.3a To CHASE $ ON To Fe..
PREPAID FINANCE CHARGE $ 0.00 $ To
M d SolutioM $ TO Nl.d S.tu a
SECURITY INFORMATION
MAKE MODEL YEAR I.D. NUMBER TYPE VALUE
OTHER (DescrilOe): 82 KEEPER WAY
You Pledge Shares AMOUNT ACCOUNT NUMBER AMOUNT ACGOUN7 NUMBER
ondlor Deposits of $ $
You egmee that the lemma and conditions In the d 3cJmum slelament and the ban and socurity egreemenls localed on page 2 of this document shall apply to this loan. II there is more
than one borrower. we agree that all the conditions of the loon and security agreements governing INS loan shall apply to both jointly and Severally. You acknowledge Ural you have
received a copy of the loon and security agreements and disclosure statement. Co- signer. II you era signing as co- signer. you acknowledge receipt of the notice to co- signer
contained an page 2.
BORRO R'S SIGN TU DATE �` C - OTHER OWNER [3 "CO-SIGNER DATE
X 1 (SEAL) a ?- D' X / ✓ l/L (SEAL) - �O
0 CO -MAKER 0 *OTHER OWNER (3 "COSIGNER DATES O O-MAK []'OTHER OWNER O "CO- SIGNER OATS
X (SEAL) x (SEAL)
C) CO -MAKER -OTHER OWNER 0 "CO-SIGNER DATE 0 CO -MAKER O'OTHER OWNER 0 "CO- SIGNER DATE
X (SEAL) x (SEAL)
'OnaR OValFA: AnY wrv.r,a ti . PwaM1 tla�r (art Or, w •,war w mewl M V. Wow d...da.a wl�ra Mn iM.Na vr,r, ur.a. • wmW,, Y col odbnau b pry rM b0. as ub.nlaN.IM
a.dll unl.n N •.avdM1 k,1a�1 M D. m4arY w .ap.kad N a.. e.w1M1 pwwwa - 'Ga31anER: Ipm dl.uM1 M n.dn u� Inn wM Iiw+.eMM wr+�M man w pwrwb d wY rN N w.. M m,M lore rM
rem W.� W m n wa M a err. •outl ew.rwY. M wtxlra mw ti.
APPLICATION FOR GROUP CREDIT INSURANCE
I Iw) In .pPATp for in —W Naunm. wv.raau) .ewaetl alvw and .lire. a pry lee nqui id pre I T vldanbnd Oat I rtuY a Paid b/ In..wunr In wnn.ucn wM ux. covw.D. w 0. Cndhar,
I (w► n_u no seal iM Purchase or this hmnnu b wkman, and real mquimd n ON 1 b oblwl dndd, Ind Nn I Iw) may Ism:Mle it M ury bm..l hwi urduna na Nat "1_1 Its kawanw ..d.c1.d, urn
. 0u,
.1 b6, and kndiridu.11y m I,. ,d.,imI. -. one Nal ws9anard puanmon Nnot .r4itl lOm NSUnnu, APPLICANT CO.APPLICAM
fh.ldlowing q—ti on., l and t, mum
be anavnndt.= rmletmyiour ),IIpiDIIltylorlMUnnea: YES NO YES NO
1. (Appliubl. to ll. in.unnce wv.npe only) tall you w un0ar Ipe 70 On IM .cheduled maturdy ilea W yaw bans a ❑ 0 0
2. (Appliutl. to diseblity wv.reps oNY) W91 you b under ape 10 on 0, .ch —lad maturity dam of your ban AND an �ou pre.anOf wom g El O El O
oW.ld. your hors ar _.k for cope. or pmrd b, 00 faun or man p.k •red Mv. bsen w vvrkrg for 70 d+Y..r Iron Mlon due -.7 In .ddluol. It y r Io.n 1 l 2!.000.00 1M IdloMmq q adore mv.l also a •n.w.nd In orMr lv dal.rmla Mlplbllity, 0 a a D
J D. N. bat fwo Ye.n, hIw you b.en medic.av dA and 01 or Instal 1.. cs— hsen IaG a comnary a—y due. a., abort,
cid+o . "uind Imuna o.rxu.ncy Syndnra (AIDS) or NDa Raaad Dvrrpl.r (ARC)?
My loon • wan b Ne sbov. wwbn. era Irua a Mst of my o kmwls0ge d b.IM If my lum . ?P or I Inrwx'NO'to gw.ten 1 w 7, w� can dn.nnd tral this pen Pn u not .11pida Ira cu u—na are
rut ba In'.me l(my w aPWcanl or 1 am wr'Yas' N. to d —.ibn �, -d—and Nalco are ayCr. tom insunnc. up to an annum ml...ding $1 00.
iM saacdv. dart e/ rrry (rxx) M.uranu w� b. N. d.n d 1hY appeusen. Any p.m.n who kneel.ly •red MN Inl.nr a d.fnud any Nsunnce comrtpa yy tar W rose n Pp I-fion for M.unnca
Ml.rtan, W cMlmconMlnl. a yrMtNlaay false lnlonnatwn car consul. for N. purpou imiaaadlnp, Info/m.Wn e.ncamin n Iaclnal.Aat M.nty comMaslnudW.m N.unnc. wL
.hkh 1 ...... . • enra and .ub).e s h P.non w eriml Ml.nd cal P.allh.. Do not sign Nn .ppllulbn N anyy pDtl<.IN. IlMnll. This apPliealbn will not b. used In ronaat b all.ppllesbl.
blank sp.c.. nave nW b.m compat IM dabta Ma nvt alpr.d and d.hd IM •ppllcaaon and II N..ppllcnlO n.. rw/ bsen wh,.....d.
CRE01T INSURANCE APPLIED FOR: NOTE: ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE.
❑ Yes ❑X No Single Credit Life Total Premium Yes ❑ No Credit Disabilty Total Premium
❑ Yes Q No Joint Credit Life
Indleatewtddlepplicanl(s): ❑ Appp®nt❑ Co- Applicant ; $0.00 Indicisawhichappecanl(s). ❑ Applicant❑% Co- AppEmnl; $ 2,990.19
Y.v a wwnO only for N.lypa. d wwr for whidl. Wrp. u IMiut.d on NV applipdon
APPLIC T'S SIGNATU DATE OF BIRTH DATE CO -AP L AN 5 IG ATURE DAT J OF BIRTH DATE
lfd �l- -7G 3 x 4 7(0 3 g acs
55 A E .� SECONDARY 13ENEFICIARY (APPLICANT) SECONDARY BENEFICIARY (CO- APPLICANT)
HGse -43se 37 A '
MNG91a2p0.37 LASER.w RD F. 1376. R.v. 1101 G . n/ n COPYRIGHT 1997 M w. MWn Lama,:.., Inc M rVha —'In.
Exhibit "A"
1 a0RRO1nER'6 NAME LOAN NUMBER rn„ua , A'unER RATE OF LOAN
LISA M NEAL ) 0310812006
IN THESE GREEM NTS WORDS "CREDIT UNION MEANS MEMBERS 1ST FEDERAL CREDIT UNION. THE WORDS 'YOU.' "YOUR" AND 'YOURS' MEAN THOSE
N LOAN AGREEMENT SECURITY AGREEMENT
Pa"' talFlnance Charge ...
s: For value received, you promise to pay, at 1. To.ra payment of this loan and all expenditures Incurred a iM ,.oil
the y Credit Union's Office, ell 8m0Un16 due. All payments Shall be made unlon In connection with this ban, or In .aliaing on a security of, you
pursuant to the disclosure statement on ge 1 of this document. You grant to the credit union a security Interest In m• F v tlescdbed on
Understand that the finance Char a and total OI a menls shown on a e 1 p• n 1 of this documenL The security Inlana on the secured property and all timings received train the
st Include % Inc.ues.
9 D 9 suB%dbttlons and additions to the secured property, proceeds from any
OI this document are based on the assumption that all Installment pa meets Insun
will be made on the scheduled due dates, and , if you have qualified �or Sac ..d property.
preferred rate that you continue to satisfy the conddiDns OI that preferred Cross•collsteraibaticn: Prope given an ecurity for this loan or for any
rata. it you tall 10 any Installment by lll0 time h is due, you writ pay other loan Borrower has with the credit union wilt secure dl •mounts
additional inleres on the overdue amount. Borrower owas the credit union now and In the fuwm. However property
♦ curing another debt will not ec n this loan It such proppeertyla
Allocation of Payments and Additional Payments: Payments and Borrowers pfincipat ..loan,. lunIase the proper..&salon notice an
credits shall be applied in Me following order. any amounts past due; any plvm and any %1hor tepel .qulmm•nm a. nbseed), or en nompurohase
to or charges owing, Including any insurance premiums; accrued interest moray how•h ld
goo
or finance charges; outstanding principal. Payments made in addition to 2. Y v w ill n unions. prior written co sal or translar the collateral unless you hero
regularly scheduled payments shall be applied in the same order, 3, You warrant that you have good doe to me collateral, free of all security Interests
Preferred Rate: II you quality for a preferred rate as disclosed on page 1 of except mat given to me vedil union end except Iai any interval of a rionca
This document or in a separate preferred rate addendum, you understand maker owner of the collateal who has signed the agreement in the Indicated
that you must meet the conditions disclosed to you in order to quality for the pbco•
preferred rate and must continue to meet those Conditions In order to keep e. You will pay ea taxes assessments, and liana against ai attached b the pro ny
your preferred tale. If you fall to meet those conditions, your rate will described and funher agree to keep the property in wood condition, housed In e
Increase, IhereDy extending the terms of your loan. You promise to continue suitable .nailer. You apnea to e.cma nnendrq .%, a enls and so B t 4
making Payment end to meet all oblipati0ns under IRIS even it p prye t amandmenU al the credit union's requosl and wiu delend the progeny
you no longer receive the profaned role. against a dverse third pony .alms
es: If u make a late a ment, you agree to a a tale chi a 6. You wwill eln Insurance to cost Trey vehicle omen pna (a In wwhich the
Late Char
g yO p y y g p y r9 aeon uniion m h hall a y to th y Interest. o n fancy a will be In o dorm and i
d one Is satisfactory page 1 of this OCUmen(. amount selislaory to she credit union. . You oil coil credit with l su001y the edil union h Onol
Prop Insurance: It y ou obtain a loan secured D a motor vehicle or of war insurance until ail wms owed 10 credit union and secured by this
P rtY Y Y property ere. Id. n yoY for to maintain such Insurance, credit union may bun
other tangible property, you must obtain insurance which protects the credit real requires Qo, obt y mWmKe of our own end add the mat of such b tha
union from fihanGal loss. The amount and cover of the property auras owed. This cost will peer interest at tiro CAnlredl me until Said. You lulhef
Insurance must be acce to the credit union. Such a policy must assign to the credit union the dull to receive the proceeds of any Insurance an
provide al least fire, 1hel , combined additional coverages and collision suroperty. and died any insurer to pay incise proceeds dimcuy2� o credit
lnaUrenco. It must contain 8 loss Pa able douse endorsement namin the union. You eulhOflte ere voWt union to endorse any stapcckk or dell Graveled as
Y fl proceeds of such insurance. end apply mole procee s owed to
ds to the e aPm
Credit Union as lien holder. You may obtain this Insurance from any agent of Ot the credit union
your choice end direct the agent to send the credit union a copy Of the You
fanner eulrhorixe the credit union to proNde your Insurance Service Center
DOUCy. with the necessary Infonnstion forvenfbation of adequate cowrege.
Debtor Responsibility: You promise to notify Credit union of any change In You acknowledge that Insunna of an eslanston thereof, placed by the ooudil
your name address or employmenil. You promise not to apply for a loan it union Is without benefit to you IN Mclue ly but It primarily for me pro action of ins
you know there is a reasonable probabilityy that you will be unable to repay credit Union. yyour obligation according the terms Of Ufa Credit azlenslon. You promise 6. S$hould the credit union feel at en time that the security oscines has
10 inform credit union Of a new information which relates to our ability to diminished i^ Valle, or for any r.Ys w, 1..) Ihal addllbna(aa
to adW s neqd.,you
ny Y Y agree to assign Io aeon union wimp ten (10) days w afavor ad iional ulre aecu
reppay your Obligation. You promise not to submit lake or inaccurate the credo d m
union feels is necessary to prolee adult union against possible
in(Onnslion or willfully conceal information regarding your Creditworthiness, loss.
credit standing, or credit Capacity. 7. if a default as Burned In me Loan Agreement should o the credit union rte
Default: You shall be considered In default If not the following occur: 1) the euth Drtty, upon Such do a Buli t to repossess and vet the cdlateral h lawful
11 Y y oil break an P remise made under this Loan A Manner. In suit caso, the crddi unlan w the credit union c authorized
fl f0errdnl or under the is n resentadvaa my. at de =oil Union's oDdon, onto, the premif whero line
Sec Agreement; or (2) gy not d u do t use the money the credit union coAeterel la kept and take p0caesMOn. wgea to epplicede lawn. �ha vedit
loaned yoil lot the p�rppOose ataled in your application; or (3) if the credit union has the nC to render the .perry pledged as collateral unused, and
union should, In ood laiih, believe that prospect Ot ymenl, p�7eC rionnance cony dlsp..B a1 the colelanl an premises where the collateal h kr. a ere
or reali28lbn of tRe collateral, if any, is Impaired: or 4 II Y Ou Or (5) i1 = union decides to sun the collateral of a public add, private sale d
otherwise dispose of the collateral, the ,twill union will notify you of the lime and
you file a petition in bankruptcy Insolvency or reo&ershiF or are pill glace of the Intended disppoose Ibn Ian 150) days pear to the sib cur du osiUan. II
nvoluntanl Into such proceedings; or 16 trine collateral. I any, given as me crcuit union sells a dtherwlw disposes of loo maelea me vedil union may
secudlyy for this account is lost, damaged or destroyed, or if it is levied con,. homh yo reasonable expenses, incurred to the reukhe. holding and
a galnsL attached or pamished; Or (7 If you dD red pay On time any of your preparing Ina m ate at 1°r and artsnppvuhp h ale of me ma°le.I. The avail
olhar or future debtsRo the credit un ion, I1 ou dataull, the Credit union may, uunnion may , ,tiles rcosonoble alfomeys lees�nd,bpel expenses, peirnilled
y Y py app icable law, Incas ed In co recision w th dis f Iron of the De ry Union
at the credit union's option and wilhout prior notice, declare this loan you do"" * You may keep possesslOn of the progeny (m141era doecAtiod end
immediately due slid pa yable, and you mull iQhmOdiataty pay to the cretin use 11 In any lewlul manner consistent wen thi " s _ o with me lnsurerrce
union al that time the total unpaid balance, as well as the Finance Charge pal' on the cdlalcral. You understand Mal me vetllt unin has certain r ights
to dale, any tale charges and Costs of collection permitted under law, ..... d Otte, __it.. rvalbble o the aeon union unoar me Unyortn Comma vael
inGudin reasonable atlome 's teas, That the credit union ma incur, up to Coda nd °iner o icace Iowa end met the crodil union ran us. tease t nu
g y Y to orce payment If you tleleulI In thwl avant.y wit et fee ueda union's
20% of Ota unpaid principal and Interest. Costs of collection tnciude, bill are . puo st essemtse the property scat. rap end make k avamgl Io rte credit nOi limited 10, repossession fees. appraisals, environmental Site union at d place of the crodd union'. ch. nng. d Vise aeon union decd°. to
assessments, casualty damage Insurance cover and attorney's fees for waive this
defeul . it will
tut donsihule waiver of any
oth er suDSequenl dcrcds.
any action taken by an attorney in order to Collect lhis loan or preserve, or e. The Credit union it hereby appointed as your Ahomeyan-Faa to PadOrm en
protect the Credit union's rights and remedies, including, without Ilrtdlation, W3 which the credit union feels am necessary to plated the conatetel and &
pre -sun demands for payment, pre -suit mediation or selllemenl security Interest which this agreement veetea
neggootiations, investigation and assessment of the credit unions rights, s. a then i' righ more la mom en one borrower, rut obligations under this agreement are
pariiapation in bankruptcy cases, matters, and proceedinggs (including, joint and Several. each being ewelTv nsponstbie to fulfill the terms d gig
without limitation, filin proofs of claim, pursuing reaffirmation agreements, agreement.
attending meetlnps fill and pursuing complaints, motions, and to. This s•wdry agreement not a* binds you, but your executors. aamenist.ton.
obj ections that relate inany way to the credll union's collateral of right to heirs, and assigns.
acllo on nsn l an collateral l. 49e balance D in default shall bear Interest at
the contract rate.
Statutory Lion: It you are in default, federal law gives the credit union the
riIht to appN the balance of shares and/or dividends in your a¢ount(s, at
tree time off delau8 to sagsN this loan. Once you are in oelauh, the cr it
union may exercise this right without further notice to you.
Delay In Enforcement: Credit Union may delay enforcing any d the credit
union rights under this agreement without losing them.
Irregular Payments: The credit union may accept late poyymenis or partial
paym oug
ents, even thh marked "payenl n full, without bsing any of the
credit union rights under this agre m
ement
Co- makers: If you are slpOning this agreement as a co-moker, you agree to
be equal)y responsible ml the borrower, but the Credit untQn may sue
either or born of you. The credit union does not have to nasty you that this
agreement has not been paid. The credit union may extend the terms of 6100 2t9e
payment and release any security without notifying or releasing you from
responsibility on this agreement.
cont.ctud Pledge of Shams: You pledge ail your slam% and deposits In the
credit union, Including future additions, as security for this loan. In call you
default, the credit union may apply theme share and deposits to m. payment
of .11 sums due at the time of default, Including costa of colbcUon and
reasonable ahomey's lee, that the credit union may Incur, up to 20% of the
unpaid principal and Interest. No Ilan or right to Improso • lien on shams and
deposit. shall apply to any of your shares which may be hold in an "Individual
R•limenorit Account" or "Keogh Plan."
NOTICE TO CO- SIGNER
You are tieing asked to guarantee this debt. Think carefully before you do. II the borrower doesn't pay the debt. you will have lo. Be sure you can afford to
pay it you have lo, and that you want to accept this responsibility.
You may have to pay up to the full amount of the debt It the borrower does net pay. You may also have to pay lute fees or collection costs, which Increase this
amount
The creditor Can collect this debt from
rro yott without first trying to Collect Irom the borrower. The creditor can use the same collectron methods a f street you that
can be used against the bower, such cis suing you, gamtshing your wages. etc. It this debt is ever In delaurl. that fad may become a part o your Credit
record. This notice is not the contract that makes you liable for the debt.
F. 43768 1102
APPRO syctw.. Inc.. 22 -107e "
Pape 2 of 2
ALL THAT CERTAIN PIECE OR PARCEL of ground situate in Upper Allen
Township, Cumberland County, Pennsylvania, being Lot No. 86 as shown on a Plan entitled
"Phase X Bowman's Village, more properly known as Bowman's Village, Upper Allen
Township, Cumberland County, Pennsylvania" recorded December 14, 2000 in Plan Book 82,
Page 63 and re- recorded on January 3, 2001 in Plan Book 82, page 85, prepared by Dawood
Engineering, Inc. more particularly bounded and described as follows:
BEGINNING at a .5/8" rebar to be set, said rebar being on the dividing line
between Lot No. 86 and Lot No. 87 where said line intersects with the southern right -of -way line
of Keefer Way (50' right-of-way); thence along Lot No, 87 South 46 degrees 27 minutes 15
seconds East, a distance of 1.10:00 feet to are 5/8" rebar to be set at the common corner of Lot No.
54, Lot No. 55, Lot No. 86 a.nd Lot No. 87; thence along Lot No. 55, South 43 degrees 32
minutes 45 seconds West, a distance of 37.00 feet to an 5/8" rebar to be set at the common comer
of Lot No. 55, Lot No. 56, Lot No. 85 and Lot No. 86; thence along Lot No. 85, North 46 degrees
27 minutes 15 seconds West, a distance of 110.00 feet to an 5/8" rebar to be set on the southern
right -of -way line of Keefer Way; thence along the southern right -of -way of Keefer Way, North
43 degrees 32 minutes 45 seconds East, a distance of 37.00 feet to an 5/8" rebar to be set on the
lot line of Lot No. 85 and Lot No. 86, THE POINT OF BEGINNING.
CONTAUiING 4,070 square feet, more or. less.
UNDER AND SUBJECT to a 10' access easement along the western side of the
lot and to all covenants and agmements of record.
1
ALSO UNDER AND SUBJECT to Declaration of 1Protcctive Covenants,
Restrictions and Conditions as act forth in Miscellaneous Book 664, Page 882.
Having thereon erected a two -story townhouse known as 82 Keefer Way, Mechanicsburg, PA
17055.
Being the same premises which Fine Line Homes, Inc., by its deed dated July 26, 2004 and
recorded in the Cumberland County Recorder of Deeds Office at Deed Book 264, Page 2143
granted and conveyed onto Patrick J. Neal and Lisa M. Neal.
Being Tax Parcel No.: 42 -29- 2456 -202
Exhibit "6"
` R
JAN -14 -2014 11:43 From:MEMBERS 1ST 7177955207 To:7179320317 P.4/18
j 0��
Prepared 13y: :Members 1st FCU _ R
L. 5000 Louise Drive �
Mechanicsburg, PA 17055 E c G it D
C lr PERI_A "!ia Cn.si'r'' -iti1
. , •ti
When recorded mail to:
FIRST "E•R]'CAN T121EINSVR NCE 0066 ACS 10 43
1228 EPUCLlD AVENUE, SUITE 400
CLEYEI'.,AND, OHIO 44115
AT'TN:.1
MORTGAGE
Made 03/08/2006
- Between
PA TRICK 7 NEAL AND L18A M NP.AL
(hereinafter called "Mortgagor'
And
MEMBERS 1 FEDERAL CREDrF SON (hereinafter called - Mortgagee'
Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter
called the "Note ") of even daze herewith, payable to the order of Mortgagee in the principal sum of
S 47,175.41 , lawful money of the United States of America, and has provided therein
for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with
interest thereon at the rate provided m the Note, in the manner and at the tinges therein set forth, and
containing certain other terms and conditions, all of which are specifically incorporated herein by
reference;
Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the
payment of the same and interest as aforesaid, together with all other sums payable hor=der or under
the terms of the Note, does grant and Convey unto Mortgagee,
All that certain property of the Mortgagor located in UPPER ALLEN
�TOMSHIP Cumberland _ unty, Pennsylvania
SEE M41BI "A"
which currently has the address of 82 KEEFER, WAY
[Street]
MFGi TA NTGSF3t'.IRC.r- Pennsylvania 17055
— ^ [City] ['Lip Code]
AM No _ � AppID ' ' - -' Page 1 of 4
Exhibit "C"
JAN -14 -2014 11:44 Froni:MEMBERS 1ST 7177955207 To:7179320317 P.5/18
Together with the buildings and improvements erected thereon, the a�tpurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thcrco .
To Have and To Hold the .same unto .Mortgagee, its successors and assigns, forever.
Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby
granted and conveyed shall become void.
TIxIs Mortgage is executed and delivered subject to the following covenants, conditions and
agreements:
(1) The Notc secured hereby shall evidence and this Mortgage shall cover and be security for any
future loans or advances that may be made by Mortgagee to Mortgagor at any tune or times hereafter and
intended by Mort4agor and Mortgagee to be so evidenced and secured, and such loans and advances shall
be added to the principal debt.
(2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and
discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water
rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt
secured hereby, (b) pay .all ground rents reserved from the mortgaged premises and pay and discharge all
mechanics' liens which may be filed against said premises and which shall or might have priority in lien
or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax,
including interest and penalties thereon, if any, now or hereafter becoming payable on the Note
evidencing the debt secured hereby, tad) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of a=d and liability insurance as Mortgagee may from time to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear,
and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and
substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
Art No A ppTi7_ , . Page 2 of 4
JAN -14 -2014 11:44 From:MEMBERS 1ST 7177955207 To:7179320317 P.6/18
(4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to
maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the
principal debt secured hereby, and collect the same as a part of said principal debt,
(5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the
mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this
Mortgage.
(6) In case default be made for the space of thirty (30) days in the payment of any installment of
principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the
other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional
loans or advances and all other sums paid by Mortgagee pursuant to the terms of the''Note or this
Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice
become immediately due and payablo, and foreclosure proceedings may be brought forthwith on this
Mortgage and prosecuted to juagmcnt, execution and sale for the collection of the same, together with
costs of suit and an attorney's commission for collection of five percent (5 9 /o) of the total indebtedness or
$200, whichever is the larger amount, Mortgagor hereby forever waives and releases all errors in said
proceedings, waives stay of execution, the right of inquisition and extension of time ofpaymcnt, agrees
to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions
from. levy and sale of any property that now is or hereafter may be exempted by law.
(7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall
terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage.
Mortgagor shall pay any recordation costs. ;Mortgagee may charge Mortgagor a fee for releasing this
Mortgage, but only if the fcc is paid to a third party for services rendered and the charging of the fee is
permitted under Applicable Law.
The covenants, conditions and agreomerits contained in this Mortgage shall bind, and the benefits shall
inure to, the respective parties hereto and their respective heirs, executors, administrators, successors.and
assigns, and, if this Mortgage is executed by mare than one party, the undertakings and liability of each
shall be joint and Several.
Ami NO
App 1D Page 3 of 4
JAN - 14-2014 11:44 From:MEMBERS 1ST 7177955207 To:7179320317 P.7/18
b
Witness the due execution ,hereof the day and y
PAT '^ �
LISA M NEAL
Commonwealth of Pennsylvania )
ss:
County of cubff T:Ri.4M_ )
On this, the day of MAR(N1 2006 before me
_ ;4Te T-N, r -,- the undemigned officox, personally appeared
r I�S,1I �'`AT" �_ satisfactorily proven to
me to be the person S whose name s) 19 are su scn a to the with n 1. ortgGl ago, and acknowledged that
he/she cxccutcd the same for the purposes therein contained.
In Witness Whereof, I hereunto set my hand and official seal.
My commission expires:
COM FD
NoterialScal
Molwt:a S. Greenwood Notary Public
Lower Allan 1Wp., Curn QH Ad Caun
i�Y C.MmiWon Expires May i2, 20>1
Memtrsr, panrnytrania Ae. 904aflOm of NOWOO
Certificate of Residence of MorWaj!ee
Members 1ST federal Credit Union, Mortgagee within n I" by certifies that its residence
is 5000 Louise Drive, Mechanicsburg, FA 17055. `
B
AwNo. . Appir% — Paget4ON
JAN -14 -2014 11:44 From:MEMBERS 1ST 7177955207 To:7179320317 P.6 /16
EXHIBIT A
All that certain property Situated in the 'Township of upper
Allen, in the County of Cumberland, Commonwealth of
Pennsylvania , and,bei,n5 described as follows: 42292456202.
Being more fully described in a deed dated July 26, 2004 and
recorded +Suly 30, 2004, among the land records of the County
and State set forth above, in Deed volume 264 and Page 2143.
Pormanent Parcel Number: 42292456202
PATRICK J. NEAL AND LISA M. NEAL, HUSBAND AND WIFE
82 K2EFER WAY, MECjLz.N1CSBURG PA 17055
Loan Reference Number .
First .American Order No: 9055555
Identifiex: FIRST AMERICAN LENDERS ADVANTAGE
'IIIIII�fIIllllltll�l�l��
905g°�55
FIRST AMERICAN LENDERS aDVANTAGE
MOPTGAGE
41f611lll ll9lill�lilp {IUIftll�lillliuliliHlll
... _ .. .... Sri 1` 9..' `•:" .... ,.
JAN -14 -2014 11:44 From:MEMBERS 1ST 7177955207 To:7179320317 P.10/18
.
(Itev. 9/2008)
D ate: - 1?ccember 3, 2013
ACS' 91 NO'T'ICE
TAKE ACTION TO SAVE
YOUR HOME FRONT
FORECLOSURE
Jbi5 is AU QMcial 11ofice that the mortgage t in default, alld tbe lende
foreglosg. Specific information about the 11alure of the default is UrQyi,ded in the:ottaClLdpages
The HOMEOWNEJj'� EMERGENCY RTGAUE AS51S ' MEMA.P)
may be able to hetp to sag your dome. This Notice expJOjus how the �rogl works
To see if HE AP can he1g, XUjj roust MEET WITH A CQbj5LME[Y C EDI COIJNSELING
AGE NC'Y WITHIN.33 DAYS OF IM DATE OF THIS NOTjCE. Take this Notice with you
when.vou meet 3 Xilh ft Counseling Ag & =
The name. address and phone nun be of Cpnijjmer Credit Cot wdinp Agencies serving yoJ r
County are listed at the end of this Notj4g,, ](you have any.-qur,§jjgUs, you max g-all the
Pennsylvania Housing Unlinge A901Cy toll free at .1-800-342-2327, (Persons wwjrb imll aired
hgijrjj'g can call 7171780- 1869)
This Notice contains important legal information. If you have any questions, rep rosentatives at
the Consumer Credit Counseling Agency may be able to help explain it -. You ma 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 IMPOI' TANCIA, DUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL C:ONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMA.NDO ES'FA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO I "OR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM' EL CUA.L
PUEDE SALVAR SU CASA VE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Page 1 of 5
Exhibit "D"
JAN -14 -2014 11:45 From:MEMBERS 1ST 7177955207 To:7179320317 F.11/18
i
HOMEOWNER'S NAATF, PATRICK J NF.AL
LISA M NEAL
PROPERTY ADDRESS: 82 KEWFER WAY
MECHAN1CSBURG. PA 1
LOAN ACCT. NO.:
ORIGINAL LENDER Members I" hpdcral Credit Union
CURRENT LFNDER/S.ERVICER: Members 1" Federal Credit Union
HOMEOWNER'S EMERGENCE' MORTGAGE ASSISTANCE PROGRAM
YOU MAX BE ELI IR .F F) FINANCIAL INANNCIAt S ISTANCF
V' HI .H CANSAYE YOUR HOME FRQN FORECL OSULM AND
IJE V U M� A�KF ELI RE N0 CAUE 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 in.ING ABLE TO PAY YOUR MORTGAGT PAYMENTS, AND
• iF YOU MEET OTHER ELTGIBILITV REQUllH'.MENTS ESTABLISHED BY THE PENNSYC,VANIA I•IOUSING
FINANCE AGENCY,
TEMPORARY SJAY OFF RF . . )STIR . -- Under the Act, you are entil.led 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 MFE DIJIST OCCUR WITt IN THE - THREE (331 DA X5 OF THE DATT QP Tii14
NOTI 1l" YOU DQ N APPi,Y FOR FMFRGENCY MQR ASSISTANCE YnU MUST HiNG YOUR
MORTGAGE UP T DATE. TT PAI(J" OF THIS NOTICE CAi LEb "HOW TO CURE YOUR MORT C- 0 TE
D PA I ", EXPLAINS HOW 'fO BRING YOUR MOR'1'(sA(', E I1P QATC
QQNS_UMRRR R .DI '. UNSELIN G G N I' ".S -- If you meet with one of,the consumer credit counseling agency
listed tit the end of this nol.ice, the lender m a y NO take action ag ainst you for thirty (30) days after the date of this
meeting. 'Che names, gddresses and t elephone numbers of designated cons credit counsel in. g a.uencies for life county
in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face - tu -face
meeting, Advise your lender immediately of your intentions.
APPL.ICATIUN FOR IZ :LGA TE ASS -- Your mortgage is in default for the reasons set forth .later in this
Notice (see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance from the .fiomeowner's Pmergency :Mortgage Assistance Prognim. To do so, you must till out, sign
and file a completed Homeowner's Emergency Assistance .Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency, To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA
anti received within thirty (3 0) days of your face -to -face meeting with tl7e counseling agency
YOU SII.OUI,D FILE A HEMAP APPLICATION AS SOON AS POSS1BL6 iF YOU 14AVE A ME.ETING WTTT - A
COUNSELING AGENCY WITHIN 33 DAYS 'OF THE POSTMARK DATE OF THI.S NOTICE AN -u FILE AN APPLICATION
WIT -I PI WITHIN 30 DAYS OF THAI' MEETING, THEN THE LENDER WILL BE TEMPORARiLY PREVENTED FROM
STARTING A FORECLOSURE AGAI.NST YOUR PROPERTY, AS EXPLAiNED ABOVE, IN THE SECTION CALLED
"TEMPOKAKY STAY OF FORECLOSURE ".
YOU 11AVF, STTF RIGHT TO FIJ& A HEMAP APPLICATION EV-F BEYOND THF,SE TIME PERIODS A. I.A "I'E
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION BUT iF YOUR
APPLICATION IS EVENTUALIaY APPROVED AT ANY 'TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE Wi'LL BE
STOPPED.
Page 2 of 5
• JAN -14 -2014 11:46 From:MEMBERS 1ST 7177955207 To:7179320317 P.12/18
AGENCY r
A CTION -- Available funds for emergency mortgage assistance are very limited. They will ba disbursed by
the Agency under the eligibility criteria establishcd the Act, 'rhe Pennsylvania Housing Finance Agency his sixty (60)
days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued
ag<ai.nst you if you have met the time requirements set forlh above. You will be notified directly by I.hc Pennsylvania.
Hausi.ng Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FIDLING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING BART OF T:HTS NOTICE TS FOR INFORMATION PURPOSES ONLY AND S1401JLD NOT BE
{ CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT,
-- of you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
1
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it tip _W da'
Nj TURF JJ THE DEEA ► - -The MORTGAGE debt held by the above lender on your property located at:
1
�i 82 KEEFER WAY
{ M "ECHANI-CSBURG, PA 17055
1S SL'RTOIJSLY IN DEFAULT because:
I
i
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due: $198.53 for 10.5.2012, $253,06 biweekly from 10.19.2013- 11.29.2013
Other charges (explain/ itemize):
TOTAL AMOUNT PAST DUE: $7,790.33
B. YOU HAVE FAILED TO TAKE THE POT,,irOW1NG ACTION (D not utio if not alica.ble }:
I
NOW TO CUJJE. THR DEFAULT - -You may cure the default within THIRTY (3'0) DAYS of the date of this notice
,i
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHIC.II 'IS $ 7,790.33 ,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WT-IICII BECOME b'U.E DURING THE THIRTY (30)
DAY PE1tI.01), Payments trust to made either by cash ca% ices check cgrtified check or moneX grrder m 30 - 1) v�iblc and
sent" to
Membari I" Federal Crcjit Union, ATTN: Jennifer
5000 Luui�o Drive
M CCtlAlllest)ul•L, I'A t70S5
You can cure any other default by Taking the following action within TI - ll_RTY (30) DAYS of the date of this letter; (Uo
not use if nL)t applicable
Page 3 of 5
JHN - 14 -2014 11:46 Froin:MEMBERS 1ST 7177955207 To: 7179320317
P.13/18
4
IF YOIJ DQ N(2'(' CURB. 1HF. nb" A Ti ,T _,:ff you do not cure the default within TI-111M (30) DAYS of the date of
this Notice, thLlende_`int:ends to exgreise its rinhts to - ac cele rate the m rtyfrge d,S„ht 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 s tart legal action to forecl Upon =ur matjga 1 11roR
IF' NF, M (na .A, : F is F X UPON -- The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. ,lf 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 p4y 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 yon s.11re the dgU it wit Y f O) DA}( Period, 3:011 will
not be re. Uired to gjA X gttorney's few
QTHF , I,H�ND R 1 N U ' -- The lender may also sue you personally for the unpaid principal balance and all other
SUMS due under the mortgage.
RIGHT TO CURE T11E. DEFAULT PRICER TO S H R FEE SAi,F -- 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
pzeyynt the s ale at -any ti-Mc ul2 to one hour before the Sheriffs Salc. You may do so bX paying the total iimount then ast
i due plus any late or other charges then dug, reason4 le attorney's fees and costs connected with the (oreclosur sale a nd
any other cq�ts connected with the Sheriffs Sale a s specified in writing by the lender and- by perf(2rniitng any ni.hGr
req uirements under the ntortgU!x Curing your default in the manner set forth in this notice will restore your
mortgage to the same position is if you had- never defaulted.
II EARLIEST POSSIBLE SHIRRIF 'S SAL QATL -- It is estimated that. the earliest date that such a Sheriff's Sale of
i the mortgaged property could be held would be approximately Three (3) months from the date of this Notice. A
notice of the actual da.to 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 TH F, LENDER:
Namg of Lender• Members 1 Federal Credit Union
ii Addresse _ 5100 I,o pis ))rive
Merjianicxhura- C A — A70 , 55
Phone Number: 471 5nfi -see �rfSpU) 2U-2328 Fx �429
F ig Number: (7171 79 -5ZO7
Contact P rain: .Ie_
E -Djail Andre., nerUI C&memberslstsi-g
Ii
EFF OF SH ".RIFF'S SAU -- You should r ealize 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:.
H A_ S MPTION ( ?F MORTC:A('r -- 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.
Page 4 ot'5
TAN -14 -2014 11:55 From:MEMBERS 1ST 7177955207 To:7179320317 P.4/10
�CJY i1 MAX ALSO HAVE THE R1C11T:
• TO SELL, THE PROPERTY TO OBTAIN MONEY TO PAY OFF 'THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER 1 ,ENDING INSTITUTION TO PAY OFF THIS DEBT.
T O HAVE THIS DEFAULT CURVY) I3Y ANY 'I`HIRD PARTY ACTING ON YOUR DEI IA LF.
• TO HAVE T.HE MORTGAGE RESTORED TO THE SAME POS1T1ON' AS TF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS R1GHT TO CURE YOUR DEFAULT
MORE THAN TH REE'1 MES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE, OF A DEFAULT IN ANY FORECLOSURE p ROC ErDING OR ANY
OTHER LAWSUIT INSTITUT.> ..D UNDER THE MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PRO'] °.ECTTON UNDER THE FEDE BANKRUPTCY LAW.
CONSUMER C,( Lj p1'1' C'011NSELI W AGENCIES SERVING YQUH C,OUNTY
(acaNd. 118419. additional nuUA if_Aece' a
Certified Mail 9 9i 7199 9991 7031 7833 4266
page 5 of 5
JAN -14 -2014 11:47 From:MEMBERS 1ST 7177955207 To:7179320317
P.14/18
I
You MAY ALSO HAVE TiLE RWHT—
• TO SELL ".l'HE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO SORROW
MONEY FROM ANOTHFR LENDING INSTITUTION TO PAY OFF THIS DEIST.
• TO flAVE THIS DEFAULT CURED 13Y ANY T.HHU) PARTY ACTING ON YOUR BEI -IALF.
• TO HAVE THE MORTGAGE RES TORED TO THE SAME POSTTION AS IP NO DEFAULT HAD OCCURRED,
IF YOU CURE THE, DEFAULT. (HOWE' VE,R, YOU DO NOT HAVE T.HTS RIGHT.` TO CURE YOUR D13PAUL l"
MORE THAN TH REE TIMES IN ANY CALENDAR YEAR)
• TO ASS.ER'T T.HE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER I.,AWSUIT INSTITU ".I "ED UNDER T14E MORTGAGE DOCUMENTS,
9 TO ASSERT ANY OTHER DEFENSE YOU B.E1,TEVE YOU MAY HAVE TO SUC14 ACTION BY THE
LENDER,
• TO SEEK PROTECTION UNDER THE FEDERA B ANKRUPTCY LAW,
S�jT1V ER C'R DIT C�OU SE ING AQF.NQFS $F_,BVIN YC1i1I QXTNII
(Fi lLia a list Qf all . l ich ilia 1 7r o-var4L&
Certified Mail 9 917199 9991 7031 7833 4273
Page 5 of 5
JP N -14 -2014 11:47 From:MEMBERS 1ST 7177955267 To:7179320317
P.15/18
Se rvicemembers Civil U.S. Department of Housing MB Approval No, 2502.0565
Relief Act and Urban Development (exp 4/40!2007)
Notice Disclosure Office of Housing
1 gal. iAl s an Ero teethpils Under tl►e SCRA
Scrvice.members on "active duty" or "active service," or a dependent of such a
servicemenlber may be entitled to certain legal protections and debt relief pursuant to the
Servicemcmbers Civil Kehef Act (50 USC App. §§ 501 -596) (SCRA).
Who MiX c titled.yLegal Protections j1n. der Jhe SCRA?
Active duty members of the Army, Navy, Air Force, Marine Corps, Coast C.ivard,
and active service National Guard,
• Active service members of the commissioned corps of the National Ocem - de and
Atmospheric .Adnlinistratiort;
+ Active service members or the comrnissiancd corps of the Public Health Service;
+ United States citizens serving with the armed forces of a nation with which the United
States is allied in the prosecution of a war or military action; and
• Their spouses,
What L9.9111,Prntecti ns ArL&Xvic . n g n►beQ 1 t To Under t . S '. A?
+ The SCRA states that a debt: incurred by a servicemember, or servicc:membor and spouse
Jointly, prior to entering military service shall not bear interest at a rate above 6 percent
during the period of military service,
+ The SCRA states that in a legal action to enforce a debt against real estate that is tiled
during, or within 90 days after the servicamembcr's Inilit.ary service, a court may stop the
proceedings for a period of time, or adjust the debt.. In addition, the sale, foreclosure, or
seizure of real estate shall not be valid if it occurs during, or within 90 days after the
servicemember's mil itary service unless the creditor has obtained a court order approving the
sale, foreclosure, or seizure of the real estate.
+ The SCRA contains many other protections besides those a.pplicablo to home loans,
flow Does A Servicialew , •r nc Tkae dent Rea r st R t li f ffmigir ihe 5 As
+ 1.n order to request relief under the SCRA, a servicel11cn1ber or spouse, or both, must
provide a written request to the lender, together with, a copy of servicememher's military
orders. The Lender providing this Notice is Members 0 Federal Credit Union, A'17N:
Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The
phone number is toil free (800) 283 -2328_
Han Does a Service ►ejnber or Depenflglit Obtahl fnforn alion Abant the SCRA?
• The U. S. Department of Defense's information resource is "Military OneSourcc ".
Wc:bsite: littD:/ /www.mil it arvonesource.com
The toll free telephone number for Military OneSaurce are;
o From the. United States: 1 »800 - 342.9647
o From outside the United States (with applicable mxess code); 800 - 3429 - 6477
o international Collect (through Icing distance operator): 1- 484 -530 -5908
+ Serviccmembers and dependents with questions about the SCRA. should contact their
unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal,,,
assistance office locator for all branches of the Armed Forces is available at
l � ttp: / /lc>?a.lassistrfctce I; iW a. 1 ,11111
form HUD -92070
(2!2007 j
— JAH -2014 11:47 From:MEMBERS 1ST 7177955207 To:7179320317 P.16/18
Comprehensive Housing
'ri�tr�er>9 °,FUt1,G IN w ,eu€ Counseling Agenc
Agencias de Consejo al Cliente para Vivienda
� Cou nty
Cumberland Co —..— — —
_
ACCC5. of Western PA
114 N Hanover St
Carlisle PA 17013
888.511.2227
vnvw. advantauec ".ptu
- CCC3 of Western PA
55 Clover Hill Road
Cana &town PA 1731.3
888.511.22271 888, 511.2227
wv✓w.a�RptBggccs.oru
Community Action Commission - Capital Region:
1514 Ucrry.St
Harrisburg PA 17104
717.232.9757
wa,� rl.caciricoun
Harrisburg Fair Housing Council
2100 N 5th St
Harrisburg PA 17110
717.238.9540
Housing & Redovelopment Authority - Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
855.683.5907 r 717.249,0789
r chra.rnm
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234,6515
y�a �.QtgJp�tnst him
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
w�,yy .ad9ma .n, e rg
i
NQTE: M Of the agencies offer workshops at various location altos; call to find a location Haar you. ~
Report last updated: 11/11/2013 945'17 AM Page 1 of 1
G
02/ ,03/2014 10:00 7179320317 KARLLEDEBOHM PAGE 07107
MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO..
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANT(S) : CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
VERIFICA TJON
I, Jennifer ferry, Collateral Liquidation. Specialist for Members l st Federal Credit Union,
being authorized to do so on. behalf of Members 1 st Federal Credit Union, hereby verify that the
statements made in the foregoing pleading are true and correct to the best of my information
knowledge and belief. I understand that false statements are made subject to the penalties of 18
Pa. C.S.A. Section 4904, relating to wasworn :falsification to authorities.
Members I" Federal Credit Union
Date: February _ , 2014
�4"
J tfer a y, C . l.a oral Liquidation
S�iralist
6
L�
7 - I6� .r l+�J
FEB z Ail
Karl A Ledebohm, Esqu
r
P.O. Box 173 CU�'�` ERLAND COUNTY
New Cumberland, PA 17070 - Okp , N 5 Y LV *A f A
(717)938 -6929
MEMBERS 1 ST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF :
Vs. NO.. 1 � S O � �
PATRICK J. NEAL and CIVIL ACTION — LAW
LISA M. NEAL
DEFENDANTS MORTGAGE FORECLOSURE
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.
Res c 1 r , mb ed,
Date: February 7, 2014
Karl Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070 -0173
(717) 938 -6929
Attorney for Plaintiff
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine, possible options while working with your
Please provide the following information to the best of your knowledge:
CUSTOMER/PRIMARY
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:
1�4 Cell: Other:
Email:
# of people in household: How long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FI FORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles boats motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (hot 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
T Mort a e Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Mone
Da /Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I/We, , authorize the above
named to use /refer this information to my lender /servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. UWe
understand that I /we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and
lend er's counsel:
V Proof of income
^Y� Past 2 bank statements
V Proof of any expected income for the last 45 days
Y Copy of a current utility bill
Y Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the market)
3
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY,
• 73 a t� �, t:•rrur� ± C
(F 1,7,,E OF r.:E s sR�FF
n-- .� .
c
Cs3
m
Members 1st Federal Credit Union
vs.
Patrick J. Neal (et al.)
Case Number
2014 -809
SHERIFF'S RETURN OF SERVICE
03/04/2014 02:17 PM - Deputy Dawn Kell, 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 Lisa Neal, wife, who accepted as "Adult Person in
Charge" for Patrick J. Neal at 82 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055.
DAWN KELL, DEPUTY
03/04/2014 02:17 PM - Deputy Dawn Kell, 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: Lisa M.
Neal at 82 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055.
ZO-LitY)-N
DAWN KELL, DEPUTY
03/04/2014 02:17 PM - Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in
his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage
Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as Not Served" at 82 Keefer
Way, Upper Allen Township, Mechanicsburg, PA 17055. Per defendant Lisa Neal there are no other adult
residents at this address other than herself and Patrick J. Neal.
SHERIFF COST: $80.79
SO ANSWERS,
March 05, 2014 RONi' R ANDERSON, SHERIFF
(c) CountySuite- Sheriff, Te!eosoft,
Uro h
(fn I� f'. U �f.;; i.
2/ ,
1 I
P[NNSY V COUNTY
tirriA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANTS
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 14-809 Civil Term
: CIVIL ACTION — LAW
: MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY:
Please enter judgment in the above captioned proceeding in favor of Members 1st
Federal Credit Union, Plaintiff, and against the Defendants, Patrick J. Neal and
Lisa M. Neal, in the amount of TWENTY-SIX THOUSAND ONE HUNDRED
SEVENTY-FOUR AND 70/100 ($26,174.70) DOLLARS, plus interest at the rate
of $4.4320 per day from May 19, 2014 through the date of judgment and at the
legal rate thereafter until the date of payment, additional attorney's fees and costs
of suit as well as other charges collectable under the mortgage and for foreclosure
and sale of the mortgaged property. Judgment is entered pursuant to Pa. R.C.P.
1037 for failure to file an Answer on behalf of Patrick J. Neal and Lisa M. Neal
a,,v.‘ \10.0 athl
Cx-M 2111
Noh� t\ocu.Feo
to Plaintiffs Complaint within twenty (20) days of service thereof and after a 10 -
day Notice was sent.
Date: May 19, 2014
Respec,' 1 ub 'tted,
•_
arl 7edebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I hereby certify that notice of intent to take a default judgment was forwarded to
Patrick J. Neal and Lisa M. Neal by United States Mail, First Class, postage prepaid on
May 6, 2014. The aforesaid notices were each contained within an envelope bearing the
return address of the undersigned. The notices have not been returned to the undersigned
as undeliverable or otherwise. A copy of the notice and Postal Forms 3817 are attached
hereto and marked Exhibit "A".
Karl M. Ledebohm, Esquire
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANTS
Date: May 6, 2014
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 14-809 Civil Term
: CIVIL ACTION — LAW
: MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: Patrick J. Neal
Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY
SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE
CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A
DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON
REAL ESTATE.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS
, FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
Exhibit "A"
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
Date: May 6, 2014
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Respectfully submitted,
Karl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
UNITED STATES Certificate O;•
POSTAL SERVICES f1llaliLf�
This Certificate of Mailing provides evidence that mar has been presented tprf�'."P
This form may be used for domestic and International rail
From:
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
To:
Patrick J. Neal
82 Keefer Way
Mechanicsburg, PA 17055
PS Form 3817. April 2007 PSN 7530-02-000-9065
UllllltuSIAJtS
POSTAL SERVICE
Certifica
rhes Certificate of Mailing provides evider.e !ha' m.+ eas bee, preserved to
This toren may be used for domestic and ,r-rereal+orla rcrda
From
_ Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
ti)
z
m
z
c 3 c
24113z> •
3::,-‹
-...11,„
c 0
0)�r 00 �IWD
O+ co m--+ o
0W 1 Z. --.17700d --I •Or vs
OO - Z D
- o G)
•
m
D
0
0
O� OO �ADJ)
crnom.-.v
d
0
.d
To
— Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
PS Form 3817, April 2007 PSN 753002-000-9065
sn.
Z• es13700
—I •or- N
Z
0 0
Zr
D
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
: PENNSYLVANIA
PLAINTIFF
Vs. : NO.: 14-809 Civil Term
PATRICK J. NEAL and : CIVIL ACTION — LAW
LISA M. NEAL
DEFENDANTS : MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS NOTICE AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE
TO: Patrick J. Neal
82 Keefer Way
Mechanicsburg, PA 17055
Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
You are hereby notified that on 1 1 , 2014 the following
judgment has been entered against you in the above aptioned case:
Judgment in favor of Members 1St Federal Credit Union, Plaintiff, and against the
Defendants, Patrick J. Neal and Lisa M. Neal, in the amount of TWENTY-SIX
THOUSAND ONE HUNDRED SEVENTY-FOUR AND 70/100 ($26,174.70)
DOLLARS, plus interest at the rate of $4.4320 per day from May 19, 2014
through the date of judgment and at the legal rate thereafter until the date of
payment, additional attorney's fees and costs of suit as well as other charges
collectable under the mortgage and for foreclosure and sale of the mortgaged
property. Judgment is entered pursuant to Pa. R.C.P. 1037 for failure to file an
Answer on behalf of Patrick J. Neal and Lisa M. Neal to Plaintiffs Complaint
within twenty (20) days of service thereof and after a 10 -day Notice was sent.
Dated: 5041I
Prothonotary
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236
is: Patrick J. Neal
Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
A: Patrick J. Neal and Lisa M. Neal
Por este medio se le esta notificando que el de
2014, el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el
caso mencionado en el epigrafe.
Fecha:
Protonotario
Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado
de residencia:
Patrick J. Neal
Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
Dated: May 19, 2014
Respect
y s itted,if/vl
arl M. edebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs. : NO.: 14-809 Civil Term
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
PATRICK J. NEAL and : CIVIL ACTION — LAW
LISA M. NEAL
DEFENDANTS : MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned hereby swears and affirms on behalf of Members 1St Federal
Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff's
knowledge, Patrick J. Neal and Lisa M. Neal are not currently on active military service.
Date: May 19, 2014
Res. - • 11 ubmitted,/„P
,1
Karl . Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
f-
`ILED-O F CE
THE PROTHONOTARY
nRldM Y30 AMH:LIB
CUMBERLAND COUNTY
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANTS
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 14-809 Civil Term
: CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE)
TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE
MATTER,
Amount Due:
Interest from:
Attorney's fees
Costs
$26,174.70 Q
5/19/14 to 5/21/14 at the rate of $4.4320 per day and at the
legal rate thereafter to be added
$ to be added
$ to be added
Directed to the Sheriff of Cumberland County, Pennsylvania;
To satisfy the judgment, interest and costs in the above captioned case, you are
directed to levy upon and sell the following real property:
All that certain real estate and improvements erected thereon situate in Upper Allen
Township, Cumberland County, Pennsylvania, known and numbered as 82 Keefer Way,
Mechanicsburg, PA 17055 and as more particularly set forth and described on Exhibit
"A" attached hereto and made part hereof by reference.
a8.5o PQA ry
80. `Tq C BF
163.95 "
I (, .5o,__
-PArzm
$a.a5 Dui
•50 L -L
O&M
E (0t J9 °'
Dated: May 28, 2014
e
Karl M. M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN PIECE OR PARCEL of ground situate in Upper Allen Township, Cumberland
County, Pennsylvania, being Lot No. 86 as shown on a Plan entitled "Phase II, Bowman's Village,
more properly known as Bowman's Village, Upper Allen Township, Cumberland County,
Pennsylvania" recorded December 14, 2000 in Plan Book 82, Page 63 and re-recorded on
January 3, 2001 in Plan Book 82, Page 85, prepared by Dawood Engineering, Inc. more
particularly bounded and described as follows:
BEGINNING at a 5/8" rebar to be set, said rebar being on the dividing line between Lot No. 86
and Lot No. 87 where said line intersects with the southern right-of-way line of Keefer Way (50'
right-of-way); thence along Lot No. 87 South 46 degrees 27 minutes 15 seconds East, a distance
of 110.00 feet to a 5/8" rebar to be set at the common corner of Lot No. 54, Lot No. 55, Lot No.
86 and Lot No. 87; thence along Lot No. 55, South 43 degrees 32 minutes 45 seconds West, a
distance of 37.00 feet to a 5/8" rebar to be set at the common corner of Lot No. 55, Lot No. 56,
Lot No. 85 and Lot No. 86; thence along Lot No. 85, North 46 degrees 27 minutes 15 seconds
West, a distance of 110.00 feet to a 5/8" rebar to be set on the southern right-of-way line of
Keefer Way; thence along the southern right-of-way of Keefer Way, North 43 degrees 32
minutes 45 seconds East, a distance of 37.00 feet to a 5/8" rebar to be set on the lot line of Lot
No. 85 and Lot No. 86, THE POINT OF BEGINNING.
CONTAINING 4,070 square feet, more or less.
UNDER AND SUBJECT to a 10' access easement along the western side of the lot and all
covenants and agreements of record.
ALSO UNDER AND SUBJECT to Declaration of Protective Covenants, Restrictions and Conditions
as set forth in Miscellaneous Book 664, Page 882.
HAVING thereon erected a two-story townhouse known as 82 Keefer Way, Mechanicsburg, PA
17055.
BEING the same premises which Fine Line Homes, Inc., Pennsylvania Corporation, by its deed
dated July 26, 2004 and recorded on July 30, 2004 in the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book 264, Page 2143, granted and conveyed unto
Patrick J. Neal and Lisa M. Neal, husband and wife.
TAX PARCEL NO. 42-29-2456-202
EXHIBIT 'A'
4
•
•
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA l7070 -0173L,
(717)938-6929
PILED -OFFICE
OF THE PROTHONOTARY
201tillAY 30 AM H.; 48
CUMBERLAND COUNTY
PENNSYLVANIA
MEMBERS 1ST 'FEDERAL '
CREDIT UNION
PLAINTIFF
Vs:
•
PATRICK J. NEAL and
LISA M. NEA.11, ' t
DEFENDANTS
• ,! .4',
•
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 14-809 Civil Term
' te: CIVIL ACTION—LAW
: MORTGAGE FORECLOSURE
!•-I#
AFFIDAVIT PURSUANT TO RULE 3129.1
Members ist Fedefal Credit Union, plaintiff, in the above aCtion; sets forth as of
the date the praecipe for the writ of execution was filed the following information
concerning the real property located in Upper Allen Township, Cumberland County,
Pennsylvania, known and numbered as 82 Keefer Way, Mechanicsburg, PA 17055.
1. Name
and address of owner(s) or reputed owner(s):
t, •
Patrick J: Ne,a1 *It
Lisa M. Neal I
82 Keefer Way
Mechanicsburg, PA' 17055
2. Name
r
and address'of ileferidant(s) in the -judgment:
•. 1 * 'a
Patrick J. Neal
Lisa14. Neal
•82 Ke'efer Way k•vi *
PA11055
t r
.t. " •4 r.,
, • . - • 1#7.'..::; • • *!.
•:••r,
3. Name and'addres of every judgment creditor whose judgment is a record lien on
the real property to be sold: ,
FILE��-OFFICE
CF THE PROTHONOTARY kVARY
KI MAY 30 t`M II 4 3
CUMBERLAND COUNTY
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
" MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs. : NO.: 14-809 Civil Term
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
PATRICK J. NEAL and : CIVIL ACTION — LAW
LISA M. NEAL
DEFENDANTS : MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
To: Patrick J. Neal
Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT
TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO
INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN
BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO
FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE.
Your house (real estate) at 82 Keefer Way, Mechanicsburg, PA 17055, as more
particularly set forth and described on Exhibit "A" attached hereto and made part
hereof, is scheduled to be sold at Sheriff's Sale on September 3, 2014 at 10:00 a.m.
in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street,
Carlisle, PA 17013 to enforce the court judgment in the principal amount of
$26,174.70 plus interest at the rate of $4.4320 per day from May 19, 2014 to May 21,
2014 and at the legal rate thereafter until the date of payment, additional legal fees
ALL THAT CERTAIN PIECE OR PARCEL of ground situate in Upper Allen Township, Cumberland
County, Pennsylvania, being Lot No. 86 as shown on a Plan entitled "Phase II, Bowman's Village,
more properly known as Bowman's Village, Upper Allen Township, Cumberland County,
Pennsylvania" recorded December 14, 2000 in Plan Book 82, Page 63 and re-recorded on
January 3, 2001 in Plan Book 82, Page 85, prepared by Dawood Engineering, Inc. more
particularly bounded and described as follows:
BEGINNING at a 5/8" rebar to be set, said rebar being on the dividing line between Lot No. 86
and Lot No. 87 where said line intersects with the southern right-of-way line of Keefer Way (50'
right-of-way); thence along Lot No. 87 South 46 degrees 27 minutes 15 seconds East, a distance
of 110.00 feet to a 5/8" rebar to be set at the common corner of Lot No. 54, Lot No. 55, Lot No.
86 and Lot No. 87; thence along Lot No. 55, South 43 degrees 32 minutes 45 seconds West, a
distance of 37.00 feet to a 5/8" rebar to be set at the common corner of Lot No. 55, Lot No. 56,
Lot No. 85 and Lot No. 86; thence along Lot No. 85, North 46 degrees 27 minutes 15 seconds
West, a distance of 110.00 feet to a 5/8" rebar to be set on the southern right-of-way line of
Keefer Way; thence along the southern right-of-way of Keefer Way, North 43 degrees 32
minutes 45 seconds East, a distance of 37.00 feet to a 5/8" rebar to be set on the lot line of Lot
No. 85 and Lot No. 86, THE POINT OF BEGINNING.
CONTAINING 4,070 square feet, more or less.
UNDER AND SUBJECT to a 10' access easement along the western side of the lot and all
covenants and agreements of record.
ALSO UNDER AND SUBJECT to Declaration of Protective Covenants, Restrictions and Conditions
as set forth in Miscellaneous Book 664, Page 882.
HAVING thereon erected a two-story townhouse known as 82 Keefer Way, Mechanicsburg, PA
17055.
BEING the same premises which Fine Line Homes, Inc., Pennsylvania Corporation, by its deed
dated July 26, 2004 and recorded on July 30, 2004 in the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book 264, Page 2143, granted and conveyed unto
Patrick J. Neal and Lisa M. Neal, husband and wife.
TAX PARCEL NO. 42-29-2456-202
EXHIBIT 'A'
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.cepa.net
MEMBERS 1ST FEDERAL CREDIT UNION
Vs. NO 14-809 Civil Term
CIVIL ACTION — LAW
PATRICK J. NEAL AND LISA M. NEAL
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $26,174.70 L.L.: .50
Interest FROM 5/1.9/14 TO 5/21/14 AT THE RATE OF $4.4320 PER DAY AND AT THE LEGAL
RATE THEREAFTER TO BE ADDED
Atty's Comm:
Atty Paid: $229.54
Plaintiff Paid:
Date: 5/30/14
(Seal)
REQUESTING PARTY:
Name: KARL M. LEDEBOHM, ESQUIRE
Address: P.O. BOX 173
NEW CUMBERLAND, PA 17070
Attorney for: PLAINTIFF
Telephone: 717-938-6929
Supreme Court ID No. 59012
Due Prothy: $2.25
Other Costs: $.50
uell, Prothon
pi J/ '
2014 j 24
Karl M.Ledebohm,Esquire PE/04 AND 440
P.O.Box 173 Cumberland,PA 17070-0173 ���� N1A COU iy �'
New
(717)938-6929
MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
: PENNSYLVANIA
PLAINTIFF :
Vs. : NO.: 14-809 Civil Term
PATRICK J.NEAL and : CIVIL ACTION—LAW
LISA M.NEAL
DEFENDANTS : MORTGAGE FORECLOSURE
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Members Pt Federal Credit Union,plaintiff, in the above action, sets forth as of
the date the praecipe for the writ of execution was filed the following information
concerning the real property located in Upper Allen Township, Cumberland County,
Pennsylvania,known and numbered as 82 Keefer Way, Mechanicsburg, PA 17055.
1. Name and address of owner(s) or reputed owner(s):
Patrick J.Neal
Lisa M.Neal
82 Keefer Way
Mechanicsburg, PA 17055
2. Name and address of defendant(s) in the judgment:
Patrick J.Neal
Lisa M.Neal
82 Keefer Way
Mechanicsburg,PA 17055
3. Name and address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Members 1St Federal Credit Union
Attn.: Jennifer Perry, Collateral Liquidation Specialist
5000 Louise Drive
Mechanicsburg,PA 17055
4 4,
4. Name and address of the last recorded holder of every mortgage of record:
Members 1St Federal Credit Union
Attn.: Jennifer Perry, Collateral Liquidation Specialist
5000 Louise Drive
Mechanicsburg, PA 17055
BAC Home Loans Servicing, LP
c/o Bank of America
16001 North Dallas Parkway, 3rd Floor
Addison,TX 75006
Federal National Mortgage Association
14523 SW Millikan Way#200
Beaverton, OR 97005
5. Name and address of every other person who has any record lien on the property:
Upper Allen Township
100 Gettysburg Pike
Mechanicsburg,PA 17055
Upper Allen Township
do J. Stephen Feinour, Township Solicitor
Upper Allen Township
100 Gettysburg Pike
Mechanicsburg, PA 17055
6. Name and address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
7. Name and address of every other person of whom the plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
to
P.O. Box 2675
Harrisburg, PA 17105-2675
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
P.O. Box 8486
Willow Oak Building
Harrisburg,PA 17105-8486
Inheritance Tax Bureau
Commonwealth of PA
Department of Revenue
Bureau of Individual Taxes
Dept. 280601
Harrisburg, PA 17128-0601
Occupant
82 Keefer Way
Mechanicsburg, PA 17055
U.S.A
U.S. Dept. of Justice
U.S. Attorney,Federal Building
228 Walnut Street, P.O. Box 11754
Harrisburg, PA 17108-1754
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: June 23, 2014 Res• • ly mi d,
or
arl M. Ledebohm, Esq.
Supreme Court ID#: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
/i/ 1JL 15r
011: 19
Ai?
ClifIBERL AND CoUNTY
PENNS Yl. VA /A
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANTS
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 14-809 Civil Term
: CIVIL ACTION — LAW
: MORTGAGE FORECLOSURE
AFFIDAVIT OF SERVICE OF NOTICE TO LIEN HOLDERS PURSUANT TO
Pa. R.C.P. 3129.2 (c)
I, Karl M. Ledebohm, Esquire, hereby swear and affirm that on the 25th day of
June, 2014, I served the attached NOTICE OF SHERIFF'S SALE OF REAL
PROPERTY pursuant to Pa. R.C.P. 3129.2(c) in the above captioned matter upon the
individuals/entities by first class mail, postage prepaid as set forth on the PS Form
3817, copies of which are attached as Exhibit "1" and made part hereof.
I verify that the statements made in this affidavit are true and correct to the best of
my personal knowledge or information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: July 14, 2014
. Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
: NO.: 14-809 Civil Term
: CIVIL ACTION — LAW
: MORTGAGE FORECLOSURE
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
Owner(s): Patrick J. Neal & Lisa M. Neal
Property: 82 Keefer Way
Mechanicsburg, PA 17055 (Legal description attached)
Judgment Amount: $26,174.70
The above -captioned property is scheduled to be sold at the Cumberland County
Sheriff Sale on September 3, 2014 at 10:00 a.m in the Office of the Sheriff,
Cumberland County Courthouse, One Courthouse Square, South Hanover Street,
Carlisle, PA 17013.
Our records indicate that you may hold a mortgage, judgment, or other interest
with respect to the property which may be extinguished by the sale. You may wish to
attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date specified by the
Sheriff not later than 30 days after the sale. Distribution will be made in accordance
with the schedule unless exceptions are filed thereto within 10 days after the filing of
the schedule.
If you have any questions regarding the type of lien or the effect of the Sheriff
Sale upon your lien,, I urge you to CONTACT YOUR OWN ATTORNEY as I am
not permitted to give you legal advice.
Date: June 23, 2014 Resp
. Ledebohm, Esq.
Supre e Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN PIECE OR PARCEL of ground situate in Upper Allen Township, Cumberland
County, Pennsylvania, being Lot No. 86 as shown on a Plan entitled "Phase II, Bowman's Village,
more properly known as Bowman's Village, Upper Allen Township, Cumberland County,
Pennsylvania" recorded December 14, 2000 in Plan Book 82, Page 63 and re-recorded on
January 3, 2001 in Plan Book 82, Page 85, prepared by Dawood Engineering, Inc. more
particularly bounded and described as follows:
BEGINNING at a 5/8" rebar to be set, said rebar being on the dividing line between Lot No. 86
and Lot No. 87 where said line intersects with the southern right-of-way line of Keefer Way (50'
right-of-way); thence along Lot No. 87 South 46 degrees 27 minutes 15 seconds East, a distance
of 110.00 feet to a 5/8" rebar to be set at the common corner of Lot No. 54, Lot No. 55, Lot No.
86 and Lot No. 87; thence along Lot No. 55, South 43 degrees 32 minutes 45 seconds West, a
distance of 37.00 feet to a 5/8" rebar to be set at the common corner of Lot No. 55, Lot No. 56,
Lot No. 85 and Lot No. 86; thence along Lot No. 85, North 46 degrees 27 minutes 15 seconds
West, a distance of 110.00 feet to a 5/8" rebar to be set on the southern right-of-way line of
Keefer Way; thence along the southern right-of-way of Keefer Way, North 43 degrees 32
minutes 45 seconds East, a distance of 37.00 feet to a 5/8" rebar to be set on the lot line of Lot
No. 85 and Lot No. 86, THE POINT OF BEGINNING.
CONTAINING 4,070 square feet, more or less.
UNDER AND SUBJECT to a 10' access easement along the western side of the lot and all
covenants and agreements of record.
ALSO UNDER AND SUBJECT to Declaration of Protective Covenants, Restrictions and Conditions
as set forth in Miscellaneous Book 664, Page 882.
HAVING thereon erected a two-story townhouse known as 82 Keefer Way, Mechanicsburg, PA
17055.
BEING the same premises which Fine Line Homes, Inc., Pennsylvania Corporation, by its deed
dated July 26, 2004 and recorded on July 30, 2004 in the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book 264, Page 2143, granted and conveyed unto
Patrick J. Neal and Lisa M. Neal, husband and wife.
TAX PARCEL NO. 42-29-2456-202
EXHIBIT 'A'
i
Exhibit "1"
UNITED STATES Certificate C
rad/ /505 T/31 SER/ICE _ - Mailini
Certificate of Mailing provides erdertt.e mat ma• nas beeo fxesented to USPS ® tor M:.a3,F1''0
tr
tts form may be used for domestic and inter -1.360,a; /mil
_ Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
BAC Home Loans Servicing, LP
co Bank of America
— 16001 North Dallas Parkway, Yd Floor
Addison, TX 75006
Form 3817, April 2007 PSN 7530-02-000-9065
f--577, UNITED STATES
POSTAL SERVICE,
Certificate of Mailing provides evidence Ma' r -or. oat. been presented to US for for ma rftt
form may be used for domestic and tmernatior, rmri
In f • ctr
•
flI
m
tfl - r) •
4z_a(/)
on),loo3)
coorri,-.73
b(J. • r2 E?)
3) -1
C:3 z
• m
Certificate -;;37—,
_ Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
0.
Inheritance Tax Bureau
Commonwealth of PA
Department of Revenue
Bureau of Individual Taxes
— Dept. 280601
Harrisburg, PA 17128-0601
-•. ••
'En
CT)
o.
7Orm 3817, April 2007 PSN 7530-02-000-9065
m
C-
C C) •
MrZ C
r-3-0•
ON -JOU])
Z. -.47:100
—4 •c:rt— Cr)
•— —I
Z
Cf GI
• m
73
0
UNITED STATES
POSTAL SERVICE,
Certificate Of
Mailing Topay lee, affix stamps or
meter postage here
This Certificate of Mailing provides evidence that mail has been presented to USPS® for mailing.
This form may be used for domestic and international r4041
From:
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0p
To" Commonwealth of Pennsylvania
Department of Welfare
c.P.O. Box 2675
Harrisburg, PA 17105-2675
PS Form 3817, April 2007 PSN 7530-02-000-9065
"71 WV! tu 1/.11LS Certificate 0
POSTAL SERVICE Ma
z
cp •
fg• •fil v)
ors.),ico3)
cn ccricnm.-co
ItA.)
— 3)
z 3),
o
. m
- o
3)
fn.: Certificate of Mailing provides extdertr,e illa, ma- naS bee, presented to. USPS to:rhilriv:-.., • ,.-..„.,•-•• p
This form may be used for domestic and inlernatre,..lir riZli),-,
From. 4.'
. —..._-
• "is A' • .1 r'''-'71,
!
\ :"
l
\:
:
'' ' •,,
_ Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
To Upper Allen Township
— c/o J. Stephen Feinour, Township Solicitor
Upper Allen Township
100 Gettysburg Pike
- Mechanicsburg, PA 17055
m
E
C-
2•EF1
PS Form 3817, April 2007 PSN 753002-000-9065
UNITED STATES
POSTAL SERVICE
This Certificate of Mailing provides evidence that mail has been presented to USPS® for mail'
This form may be used for domestic and international cselit.
Certificate Of
Mailing
from
Karl M. Ledebolun, Esq.
P.O. Box 173
New Cumberland, PA 17070..
To pay lee. affix stamps or
meter postage her.
073
Federal National Mortgage Association
14523 SW Millikan Way #200
- Beaverton, OR 97005
PS Form 3817, April 2007 PSN 7530-02-0t.K.yduo
J
z
m
r
L c
c n •
o rz c cr)
Ca ON -JW'
ca. ccriorrh---o
CD
LA)
-b. --I •or- cf)
. frt
71
M
iiNITED STATES Certificate Of
Mafli
POSTAL SERVICE
This Certificate of Mailing provides evidence that mail has been presented to USPS® for
This form may be used for domestic and international it
0
ifv)
From:
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
To
Occupant
82 Keefer Way
Mechanicsburg, PA 17055
PS Form 3817, April 2007 PSN 7530-02-000-9065
To pay tee, affix stamPs or
uNi I ED STATES Certificate Of
POSTII.L SERVICEq, Mailinc
This Certificate of Mailing provides evidence that mail has been presented to USPS® for mailing
This form may be used for domestic and international ri
From:
Karl M. Ledebohrn, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
•
To:
- Department of Public Welfare
TPL Casualty Unit
— Estate Recovery Program
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
To pay fee affix stamps or
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
0
in
rn
c cl •
c 0.)
-m-u•
orv-4col>
zcoorri-.-0
• --.170 0 0
—I -orVt
-
-
Z
0 0)
•ii
-u
Certificate Of
To pay tee affix stamps oi
This Certificate of Mailing provides evidence that mail has been presenled to USPS® for marli
This form may be used for domestic and international malt.
From:
Karl M. Ledebohm, Esq.
P.O. Box 173
!! ,
New Cumberland, PA 17070-0173,3'' 1
r-- ,
To:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
PS Form 3817. April 2007 PSN 7530-02.000-9065
LaUNITED STATES
POSTAL SERVICE
his Certificate of Mailing provides evidence that mail has been presented to USPSO for mailing.
his form may be used for domestic and international retail
Certificate Of
To pay tee, affix stamps or
Mailin • meter postage here
ram:
To:
Karl M. Ledebohm, Esq. if
P.O. Box 173
New Cumberland, PA 17070-0173
•
a
Members lot Federal Credit Union
Attn.: Jennifer Perry, Collateral
-
Liquidation Specialist
— 5000 Louise Drive
Mechanicsburg, PA 17055
PS Form 3817, Apnl 2007 PSN 7530-02-000- 065
UNITED STATES
POST/IL SERVICE
This Certificate of Mailing provides evidence that mail has been presented to USPS O for mai
This form may be used for domestic and international rulail.
From:
Certificate r
Maili
To:
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
Upper Allen Township
100 Gettysburg Pike
— Mechanicsburg, PA 17055
PS Form 3817. April 2007 PSN 7530-02-000-9065
C3
(3)
cm..•
UNITED STATES Certificate Of
Mailinc
resented to USPS® for marling -
This Certificate of Mailing provides evidence that mail has been
This form may be used for domestic and international rola],
From:
Karl M. Ledebohm, Esq.
— .
New Cumberland, PA 170704173 '
1
P.O. Box 173
To: Domestic Relations
Cumberland County Courthouse
- One Courthouse Square
_ Carlisle, PA 17013
P Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES Certificate Of
POST/IL SERVICE1,
Mailing
This Certificate of Mailing provides evidence that mail has been presented to USPS S for mailing.
This forte may be used for domestic and international ,ii
from:
Karl M. Ledebohm, Esq.
P.O. Box 173
et!
New Cumberland, PA 17070-0173
To:
- U.S.A
U.S. Dept. of Justice
U.S. Attorney, Federal Building
- 228 Walnut Street, P.O. Box 11754
Harrisburg, PA 17108-1754
OF,
00
-,111momm=11
OCD
A
PS Form 3817. April 2007 PSN 7530-02-000-9065
3D
rn
L
.
3)z C vi
—m -D,
ONJVCOM)
CUlcDM.-.7)
Z• -,0300
•c:Dr- v,
-
Z
0000
• m
Karl M.Ledebohm,Esquire
P.O.Box 173
New Cumberland,PA 17070-0173
(717)938-929
MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
: PENNSYLVANIA
PLAINTIFF C) CZ‘
Vs. : NO.: 2014-809 Civil rnrrl
C �`'�
PATRICK J. NEAL and : ,� ;
LISA M. NEAL • r- "J y
• C-5 -r-' Y
.• D� CS)
DEFENDANT(S) : CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
PLAINTIFF'S MOTION TO VACATE JUDGMENT IN FORECLOSURE
WITHOUT PREJUDICE, DEFENDANT HAVING BROUGHT THE
MORTGAGE OBLIGAITON CURRENT UNDER ACT 6
Plaintiff, by its attorney, Karl M. Ledebohm, Esquire, moves the Court to vacate
the judgment in foreclosure in the above captioned matter, the Defendant having brought
the obligation current under Act 6, and in support thereof avers the following:
1. Pursuant to Local Rule 208.3(a)(2), no judge has ruled upon any other
issue in the same or related matter.
2. No attorney has entered an appearance in this matter on behalf of
Defendant and; therefore, Local Rule 208.2(d) does not apply in seeking
the concurrence of opposing counsel is not possible.
3. No judge has been assigned or ruled on any issue in this matter.
1
4. Plaintiff commenced this foreclosure action by filing a Complaint in
Mortgage Foreclosure (the "Complaint in Foreclosure") on February 12,
2014, to the above captioned matter.
5. Judgment was entered on May 21, 2014 (the "Judgment").
6. Since the date of the Judgment, Defendant(s) has(have) brought the
mortgage loan which is the subject of the Complaint in Foreclosure (the
"Mortgage Obligation") current Pursuant to the Act of January 30, 1974,
P.L. 13, No. 6, 41 P.S. section 101, et. seq., ("Act 6").
7. Pursuant to Act 6, Plaintiff has reinstated the Mortgage Obligation and is
required to now vacate the Judgment without prejudice to the filing of a
complaint in mortgage foreclosure or otherwise exercising its rights under
the Mortgage Obligation as to any future default.
WHEREFORE,Plaintiff respectfully requests this Honorable Court enter
an order vacating the Judgment without prejudice, the Defendant having brought
the Mortgage Obligation current under Act 6.
Respect . ly submitted,
Date: August , 2014 _
Carl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
2
08/05/2014 08:49 7179320317 KARLLEDEBOHM PAGE 02/02
MEMBERS 151'FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
: PENNSYLVANIA
PLAINTIFF
Vs. : NO.: 2014-809 Civil
PATRICK.T. NEAL and
LISA M. NEAL
DEFENDANT(S) : CIVIL ACTION-LAV
: MORTGAGE FORECLOSURE
VERIFICATION
I,Jennifer Perry, Collateral Liquidation.Specialist for Members 1st Federal Credit
Union, being authorized to do so on behalf of Members 1st Federal Credit Union,hereby
verify that the statements made in the foregoing pleading are true and correct to the best
of my information knowledge and belief. I understand that false statements are made
subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to
authorities.
Members 1st Federal Credit Union
Date:August , 2014
B
Jen if= Pc . , Collate ;1 Liquidation
Spe iali.,t
3
Karl M.Ledebohm,Esquire
P.O.Box 173
New Cumberland,PA 17070
(717)938-6929
MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
: PENNSYLVANIA
PLAINTIFF
Vs. : NO.: 14-809 Civil Term
PATRICK J.NEAL and : CIVIL ACTION—LAW
LISA M.NEAL
DEFENDANTS : MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 7th day of August, 2014,
I served a true and correct copy of the foregoing Plaintiff's Motion to Vacate Judgment in
Foreclosure, Without Prejudice, Defendants Having Brought the Mortgage Obligation
Current Under Act 6 and corresponding order upon the following individuals by first
class mail,postage prepaid, addressed as follows:
Patrick J.Neal
Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
Respect ly /omitted,
fi
Date: August 7, 2014
. T M. 1,edebohm, Esq.
Attorney for Plaintiff
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
1=1L.ED-0 F10E
CF THE PROTHONOTARY
2 14 BUG l 2 AM II: 57
CUMBERLAND COUNTY
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Vs. : NO.: 2014-809 Civil
PATRICK J. NEAL and
LISA M. NEAL
DEFENDANT(S) : CIVIL ACTION -LAW
: MORTGAGE FORECLOSURE
ORDER
AND NOW, this / Z day of
, 2014, upon
consideration of Members 1st Federal Credit Union's Motion to Vacate The Judgment in
Foreclosure, Without Prejudice, in the above captioned matter, the Defendant(s) having
brought the obligation current under Act 6, it is hereby ORDERED THAT the Judgment
entered in the above captioned matter is hereby vacated, WITHOUT PREJUDICE.
1
Notice addresses:
Defendant:
,/Patrick J. Neal
✓Lisa M. Neal
82 Keefer Way
Mechanicsburg, PA 17055
Attorney for Plaintiff:
� -Karl M.Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
fa./1v
2
By the Court:
A' A
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
THE PR u-Jf F1 'TE
THE i'THONOI i', 1"
1/14
OFF= OFT1 R RIF
20RAUG 29 PQM 2:U1
CUMBERLAND COUNTY
PENNSYLVANIA
Members 1st Federal Credit Union
vs.
Patrick J. Neal (et al.)
Case Number
2014-809
SHERIFF'S RETURN OF SERVICE
06/16/2014 03:42 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 82 Keefer Way, Upper Allen Township, Mechanicsburg,
PA 17055, Cumberland County.
06/19/2014 11:38 AM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Real
Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the
same time personally handing a true copy to a person representing themselves to be the Defendant, to
wit: Lisa M. Neal at 82 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland
County.
06/19/2014 11:38 AM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Real
Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the
same time personally handing a true copy to a person representing themselves to be Lisa M. Neal, Wife,
who accepted as "Adult Person in Charge" for Patrick J. Neal at 82 Keefer Way, Upper Allen Township,
Mechanicsburg, PA 17055, Cumberland County.
08/05/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $1,437.64 SO ANSWERS,
August 28, 2014
=ountvSiuts Sheriff. Teleost1ft. inc.
RONR ANDERSON, SHERIFF
-sd •le-
r Sv F✓v'
i ii
4_ Q7
�1°3iD95 -
On June 10, 2014 the Sheriff levied upon the
defendant's interest in the real property situated in
Upper Allen Township, Known and numbered as,
82 Keefer Way, Mechanicsburg, as Exhibit "A"
filed with this Writ and by this Reference
incorporated herein.
Date: June 10, 2014
By:
"r, n
Real Estate Coordinator
/ 1 :Q/ E- 4101
31-1.1 JO +'31J J0
LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14
Writ No. 2014-809 Civil
MEMBERS 1ST FEDERAL
CREDIT UNION
vs.
PATRICK J. NEAL
Lisa M. Neal
Atty.: Karl M. Ledebohm
ALL THAT CERTAIN PIECE OR
PARCEL of ground situate in Up-
per Allen Township, Cumberland
County, Pennsylvania, being Lot No.
86 as shown on a Plan entitled "Phase
II, Bowman's Village, more properly
known as Bowman's Village, Upper
Allen Township, Cumberland Coun-
ty, Pennsylvania" recorded December
14, 2000 in Plan Book 82, Page 63
and re-recorded on January 3, 2001
in Plan Book 82, Page 85, prepared
by Dawood Engineering, Inc. more
particularly bounded and described
as follows:
BEGINNING at a 5/8" rebar to be
set, said rebar being on the dividing
line between Lot No. 86 and Lot No.
87 where said line intersects with the
southern right-of-way line of Keefer
Way (50' right-of-way); thence along
Lot No. 87 South 46 degrees 27 min-
utes 15 seconds East, a distance of
110.00 feet to a 5/8" rebar to be set
at the common corner of Lot No. 54,
Lot No, 55, Lot No. 86 and Lot No.
87; thence along Lot No. 55, South
43 degrees 32 minutes 45 seconds
West, a distance of 37.00 feet to a
5/8" rebar to be set at the common
corner of Lot No. 55, Lot No. 56, Lot
No. 85 and Lot No. 86; thence along
Lot No. 85, North 46 degrees 27 min-
utes 15 seconds West, a distance of
110.00 feet to a 5/8" rebar to be set
on the southern right-of-way line of
Keefer Way; thence along the south-
ern right-of-way of Keefer Way, North
43 degrees 32 minutes 45 seconds
East, a distance of 37.00 feet to a
5/8" rebar to be set on the lot line of
Lot No. 85 and Lot No. 86, THE POINT
OF BEGINNING.
CONTAINING 4,070 square feet,
more or less.
UNDERAND SUBJECT to a 10'
access easement along the western
side of the lot and all covenants and
agreements of record.
ALSO UNDERAND SUBJECT to
Declaration of Protective Covenants,
Restrictions and Conditions as set
forth in Miscellaneous Book 664,
Page 882.
HAVING thereon erected a two-
story townhouse known as 82 Keefer
Way, Mechanicsburg, PA 17055.
BEING the same premises which
Fine Line Homes, Inc., Pennsylvania
Corporation, by its deed dated July
26, 2004 and recorded on July 30,
2004 in the Recorder of Deeds in and
for Cumberland County, Pennsylva-
nia, in Deed Book 264, Page 2143,
granted and conveyed unto Patrick
J. Neal and Lisa M. Neal, husband
and wife.
TAX PARCELNO.
202,
77
42-29-2456-
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
July 11, July 18 and July 25, 2014
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Marie Coyne, Ed tor
SWORN TO AND SUBSCRIBED before me this
25 da of Jul 2014
COMMONWEALTH Of PENNSYLV* MA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO., CUMBERLAND CNTY
My Commission Expires Apr 28, 2018
The Patriot -News Co.
,1900 Patriot Drive
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
he atriotNews
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Amy Kotula, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of
Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
• 201 -809 Civil Ter
MEMS RS 1ST FEDE AL
C EDIT UNION
vs.
PATRICK J. NEAL
Lisa M. Neal
Atty: Karl M. Ledebohm
ALL THAT CERTAIN PIECE OR
PARCEL of ground situate in Upper
Allen Township, Cumberland County,
Pennsylvania, being Lot No. 86 as
shown on a Plan entitled "Phase II,
Bowman's Village. more properly
known as Bowman's Village, Upper
Allen Township, Cumberland County,
Pennsylvania" recorded December
14, 2000 in Plan Book 82, Page 63
and re-recor&i✓u=tm- Ruary, 3, 2001
in Plan Book 82, Page 85, prepared
by Dawood Engineering, Inc. more
particularly bounded and described as 1
follows:
This ad ran on the date(s) shown below:
07/13/14
07/20/14
07/27114
Sworn to . d , ubscribed before me this 20 day of August, 2014 A.D.
aryPub_
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Sheryl Marie Leggore, Notary Public
Hampden Twp., Cumberland County
My Commission Expires July 16, 2018
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES