HomeMy WebLinkAbout14-1197 Supreme Courfiif of Pennsylvania
F
Cour iof�Common Pleas For Prothonotary Use Only:
. 45 I'
civivCnvef�Sheet
r w Docket No:
Cu County (l ✓ (� / / J�
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as rewired by lain or rules of court.
Commencement of Action:
S E Complaint El Writ of Summons Petition
E Q Transfer from Another Jurisdiction -7 Declaration of Taking
C Lead Plaintiff's Name: Lead Defendant's Name:
T Members 1st Federal Credit Union Tammy I. Myers
I Are money damages requested? p Yes 0 No Dollar Amount Requested: Qwithin arbitration limits
(check one) Doutside arbitration limits
N Is this a ClassAction Suit? M Yes CE No Is this an MDJAppeal? [3 Yes fx, No
A Name of Plaintiff /Appellant's Attorney: Christopher E. Rice, Esquire /Martson Law Offices
El Check here ifyou have no attorney (are a Self IPro Sel Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
0 Intentional Buyer Plaintiff Administrative Agencies
El Malicious Prosecution Debt Collection: Credit Card 0 Board of Assessment
0 Motor Vehicle Debt Collection: Other F] Board of Elections
® Nuisance 0 Dept. of Transportation
Q Premises Liability ED Statutory Appeal: Other
S ® Product Liability (does not include
E mass tort) Employment Dispute:
Q Slander/Libel/ Defamation Discrimination
C El Other: 0 Employment Dispute: Other El Zoning Board
T ❑ Other:
I L — i Other:
O MASS TORT
Asbestos
N Tobacco
Toxic Tort -DES
Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS
E] Toxic Waste
Other: � Ejectment [] Common Law /Statutory Arbitration
B Eminent Domain /Condemnation E] Declaratory Judgment
Ground Rent E] Mandamus
Landlord/Tenant Dispute E] Non- Domestic Relations
Ix Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY gag Quo Warranto
Mortgage Foreclosure: Commercial
El Dental El Partition El Replevin
El Legal 0 Quiet Title Other:
E Medical 0 Other:
M11 Other Professional:
Updated 1/1/2011
i
Christopher E. Rice, Esquire L` I �'�� E H�"��` "�
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire 2914 � +
Attorney I.D. No. 307746 CUM BERLAND COUNTY
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLEI ENNSYLVANiA
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243 -3341
Attorneys for Plaintiff
MEMBERS 1 ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 14 - CIVIL TERM
TAMMY I. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so, the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiffs. 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 REDUCE FEE OR NO FEE:
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAWYER
Contact:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249 -3166 5 & 3�
J36,,i�73
NOTICE REQUIRED UNDER THE FAIR
DEBT COLLECTION PRACTICES ACT,
15 U.S.C. §1601 (AS AMENDED) AND
THE PENNSYLVANIA UNFAIR TRADE PRACTICES
ACT AND CONSUMER PROTECTION LAW,
73 PA. CON. STAT. ANN. §201, ET SEQ. ( "THE ACTS ")
To the extent the Acts may apply, please be advised of the following:
1. The amount of the original debt is stated in the Complaint attached hereto.
2. The Plaintiff who is named in the attached Complaint is a Creditor to whom the debt is
owed. The Creditor's law firm, Martson Deardorff Williams Otto Gilroy & Faller, is
filing this Complaint on behalf of the Creditor.
3. The debt described in the Complaint attached hereto and evidenced by the copies of the
note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within
thirty (30) days after receipt of this notice, disputes the validity of the debt or some
portion thereof.
4. If the Debtor(s) notifies the Creditor's law firm within thirty (30) days of the receipt of
this notice that the debt or any portion thereof is disputed, the Creditor's law firm will
obtain verification of the debt and a copy of the verification will be mailed to the
Debtor(s) by the Creditor's law firm.
5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original
Creditor, and if the Debtor(s) makes a request to the Creditor's law firm within thirty
days from the receipt of this notice, the name and address of the original Creditor will be
mailed to the Debtor(s) by the Creditor's law firm.
6. Requests can be made to:
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
Attn: Christopher E. Rice, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243 -3341
* THIS DOCUMENT MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A
DEBT FOR THE PLAINTIFF AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
Christopher E. Rice, Esquire Q��Y
Attorney I.D. No. 90916 4 �( �r ; 3
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746 CUMUR' A0 C16.OXY
MARTSON DEARDORFF WILLIAMS OTTO GILROY &FALLER
�PENNS'l
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243 -3341
Attorneys for Plaintiff
MEMBERS 1 FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 14 - I �� CIVIL TERM
TAMMY I. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
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 Services for
the appointment of a legal representative. However, you must provide your lawyer with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60)
days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work
out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date: C
Christopher E. Rice, Esquire
I.D. No. 90916
Aaron S. Haynes, Esquire
I.D. No. 307746
Ten East High Street
Carlisle, PA 17013 -3093
(717) 243 -3341
Date: f c� , 2014 Attorneys for Plaintiff
• 7
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 APPLICAN'r
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 0 No
Mailing Address (if different):
City: State Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
Mailing Address:
City: State Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
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. motorcvcles� Model:
Year Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2fl utilities
Car Pa ens Condo/Nei . Fees
Auto Insurance Med. not covers
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Mone
Da /Child Care(ruit. 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 Ioan 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:
jAUTHOR1 J10
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. IAVe
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
lender's counsel:
Proof of income
-Vl Past 2 bank statements
Y Proof of any expected income for the Iast 45 days
Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
J (hardship letter)
V Listing agreement (if property is currently on the market)
3
FILED
HL
Christopher E. Rice, Esquire
Attorney I.D. No. 90916 2614 FEB 28 At
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746 CUM- ERi_AND C f)U?,Ty
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER PENNSYLVANIA
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243 -3341
Attorneys for Plaintiff
MEMBERS 1 sT FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 14 - 181 CIVIL TERM
TAMMY 1. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
COMPLAINT
AND NOW, comes the Plaintiff, MEMBERS 1St FEDERAL CREDIT UNION, by and
through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and
files this Complaint in Mortgage Foreclosure upon the following:
1. Plaintiff, Members I` Federal Credit Union ("Plaintiff'), is a federally chartered
credit union located at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055.
2. Defendant, Tammy 1. Myers ( "Defendant "), is an adult individual residing at 147
North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. Defendant is the owner of the real property located at 147 North Bedford Street,
Carlisle, Cumberland County, Pennsylvania 17013 ( "Real Property "), and more fully described in
a certain deed recorded in the Recorder of Deeds Office of Cumberland County, Instrument Number
200826204, which is encumbered by the Mortgage described below.
4. On or about July 18, 2008, Defendant executed a Promissory Note (the "Note ") with
Plaintiff in the amount of $22,000.00. A true and correct copy of the Note is attached hereto as
Exhibit "A" and is incorporated herein by reference.
5. As security for the performance of his /her obligations under the Note, Defendant, as
Mortgagor, made, executed and delivered to Plaintiff, as Mortgagee, a mortgage upon the Real
Property (the "Mortgage "). A true and correct copy of the Mortgage containing a complete legal
description of the Real Property is attached hereto and incorporated as Exhibit `B."
6. The Mortgage has not been assigned.
7. Defendant is the owner of the Real Property, and Plaintiff knows of no other persons
holding an ownership interest in the Real Property.
8. Plaintiff has made demand for payment of all sums due and owing thereunder, but
payment has been refused.
9. Plaintiff provided Defendant with notice of the period in which Defendant's default
may be cured, but Defendant has failed to cure her default.
10. As authorized under the Mortgage, the loan obligation to Plaintiff from Defendant
has been accelerated.
11. The total sum due and owing from Defendant under the Note, as of January 31, 2014,
is itemized as follows:
Principal: $15,777.44
Late Fees: $191.75
Interest as of January 31, 2014: $1,617.13
Court Costs and Fees (estimated): $500.00*
Attorney Fees: $2,000.00
Total as of January 31, 2014: $20,086.32
Plus interest accruing at $3.73 per day from January 31, 2014, until paid in full.
*To be determined by the Cumberland County Sheriff.
12. Plaintiff specifically reserves the right to increase the Court Costs and Fees, and
Attorney Fees listed above should additional services be requested and /or costs /charges /fees be
incurred as a result of the collection of the money owed and foreclosure of the Real Property.
13. Pursuant to the notice provision of Act 6, 41 P.S. § 403, and Act 91, 35 P.S. §
1680.403 (c) (collectively, the "Notice "), Plaintiff sent notices of intention to foreclose mortgage and
of the mortgage assistance program dated December 2, 2013, to Defendant by certified mail, return
receipt requested.
WHEREFORE, Plaintiff demands judgment against Defendant under the Mortgage in the
amount of $20,086.32, plus interest from January 31, 2014, at the rate of $3.73 per day until the debt
is paid in full.
MARTSON LAW OFFICES
By:
Chr i stopher E. Rice, Esquire
I.D. No. 90916
Aaron S. Haynes, Esquire
I.D. No. 307746
Ten East High Street
Carlisle, PA 17013 -3093
(717) 243 -3341
Date: r&V � Zp Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Members ls` Federal Credit
Union. Any information received will be used for that purpose.
EXHIBIT "A"
St CLOSED- NCTE DISCLOSURE
CL C RESS ECa1HD Al3 BEFE8EML{
8000 Louise Orhm, P.O, Box 40 TAMMY M NAME A WAOOREee
Mechanksbtug, PA 17066 AMt YERS
yt@ABERS 1e a�IP73tP H _1 3F11 ST
RMa1lg01 wee
TA
PpINCWALAMOUNT " CO•BORgONER'8 ANE
We
7 r r FIXeG VARUBta
ANNUAL PERCENTAGE FINANCE CHARGE Anvurvinnence&TtalOMO nloi T
RATE: The cost of your credit as a The dolor amount the Orodit wit credit provided to you or On your you wll have pa star you have
yearly rate. a coat you. behalf, mode all payments as echeduled.
i
8.84 % • f 11,40014 • $ 22,000.00 e $ 90,481.82
crad4 v e Rata a your Wsn Pas a valabte Ma as habeted above Ow Artnua PerwMepe Rate may heraos♦ 0urmg the arm a nth Vansecam 11M tlndvx) Ntanlpe. Ths
credit ales roll odtl a mugln of to tea lntlex vnlue. The tale wIN rtrantie monlhty ea the fW dq or in month. The two wit serer Iw hkhtc Into IM maximum rare allowed by
low, 0.+d N ve'U rtevA he has tlbn , Arry inereel rate Increases vAb resin in more payments of the sane arawnt. For Example, It yaw toe^ w0► for 44000 at tr% for 41
months and the Arvwal Percentage Rate hbrease0 by 2% a ter ene yev, die teen V yqa bon wevid hcrepse by We months
Ifrnsd RaU: N ruNlrAad, Ise f0lowhq gopllaa l0 your ban:
your Y Autemallo Pa mast WwounLd RW: Beoauw you Iraw a trod a maim your dry tnonatry aYmenla ltudugh sn wtomalW deductlon aamyour Chackhl(EaNngs
ccorrnL yew ANNUAL PERCENTAGE RATE Iwe been dlaarMed M 209:, The ANNUAL. PERCENTAGE RATE dlsdoxed above M 1hs ANNl1Al pERCENTA00 RATR Dox h
tae AutomatW Peymem Ohoounted Rate. Thh tale roll Inaaeas by .20% II You cease tea sAOnatq Payment ertangemenl 0.r fait to moinMh eur•ctent funds In your aeooud to
rover We aUtbmallo ppaymeNs. m such a oaae, Ida vaoel of lha banal Yda (� b attend M qRn olyyaut IWn. Far exenPla,1 yyeow AutonNle Paymoq daoourdea Rata 7s 1096
en a 13,000.00 Wan for !b mvrUa and you ceeu 0.r eutomath paynsm enenpeaad, year nts vM)nnaese h t0.2tTt, reaukuq M 1 odtlilloaal paymeN.
Ventbla Bete Preloned Loma, I }Yar toen b e varfeble tae loan and you anrelYy Wr a prdamd nte, your prelenetl dlscoud b lakes at the Ilona lahe out year toes. This
WlglPrtlerredANNUAIPERCENTAOFRATEwIItlnAVay�000rdkpbaam /a�NUA @ spCENTAGeISPdATpvllbiNYwrhm (vNened�/rWt7aNUL�PERNCE�NTAOE
pERCENTA01l MTE N 12M a Iha Tyne you take Iho baL w htlM preTam
RATE roll Jaen vary aoaordkp ro the IrMex, a. di W used In Ihe'VSnebb Rime" provhpn ebeva.
Fbled Rab Pnfernd LOeM. d yaw f»n la a (1x10 raU Ian end yw W aIy fora prMam4 nit, year ANNUAL PERCENTAGE NAT! Ml Z>4 pnfMee ANNUAL
PORCENTAOC RATE dlscipsed shave for as u rebrtsd ShLS remake h etleol,
Number of Payments Amoustof Peymonb Payment Fraqusnoy WRM Payments AA Due a I m 89yo Yau may obtainDro etty
P a 119 ;289.44 MonfhlY 8a91malg 001182008 dft N' l the i t he t w O adteela to
4w 1 $204.20 Final Due • On 08I1 8R018 s WA rdtyn you pay ni th
eocunty: Collater see g Omer WASWth Oteexeda union ihagaedsorprypary Olhtt
W Brio;Sere p;h loan. You a olvine a secuO
n r Inleran In belrp pWr e - �(Oasa6e):
yew Maenrgs andfor W OSP In lire are0n un anC: x Q
a aANg/a a (sit (ea ilr OI l at e ell ebnedln� paytnen4 u will ^ X take hila�aa Yar�raQU p�bia nal I, any. dent S map Feea: !S N
Insannar,
eS p ,you WE not hrm 1* Ply 0. mrpla r a Parolee %e u nanpaYa try o 'Puyll. n .1
tMIZ-ATION Of
AMOUNT FINANCED $ 22,000.00 Amount Paid to others on your beheM (oescrlbe)
taooaao To CHAa! ; To
AMOUNT GIVEN TO YOU DIRECTLY $ 6,120.00 Ss,arLW _. To gaCOvWFtq S To
TO
$ To 3 To
S To $ To
j AMOUNT PAID ON YOUR ACCOUNT$ $ To ; To
S 70 $ To
To ; TO
To To
PREPAID FINANCE CHARGE 3 0.00 5 To 10.00 To Feed
To Arid e,AAhne $ To Aead3dusona
MAKE MODEL YEAR LO, NUMBER TYPE VAWE
OTHER ( 09ger bo): 147 N BEDFORD STREET CARLISLE PA 17013
OU Pledge StKte/ AMOLJITT ACCOUNT NUMBER AMOUNT ACCOUNT NUMBER
and/or Deposits of It 3
You agree chat the t•mta and conditions M the dacbsum statement and rim ben 0.M Stoutly agmaurd, turykd on page 2 u( ask document shag apply to INS loan a aron Is more
than one 0orrawar, we Done that e0 the condbMns or the loan and aocumy agrasnlsnd oo Int; 11e is snarl ap to bdn )oinvy am savmly . ns
, You ado that you he
recorM a copy of
ft ben and security ograemema and Lila dwits mammem, Coalgner; IN you are alpnha as co r, you eokrrowlodge nralpt of the notice tom s.grrr
contained on page 2.
BORR v+,ER'S SIGNATURE d. OAre CO.16AKER Q "OTHER OWNER 13 "CO-SIGNER DATE
1 ( X (SEAL)
U CO.MAKFR 'OTHER OWNE ❑ "COS)GNER DATE 0 C04AAKER C) 'OTHER OWNER Q "COSIONER GATE
x (am) X (SEAL)
CO•M OTHER OWNER 0 - 'COSIGNER DATE 0 CO -MAKER D'O1NER O%yNERp 'TO- SIGNSt DATE
(BEAL) X (SEAL)
j • OINUIEWIearAMaaaan �r,"r,r "rryarn hlrrwllae, aaeraaa• m1, rw Mead In e,aaMra d,arM soMnal ayna M.0. Tea W.rp hf.Y,d bpy l,. rN, Y.r,nrnr./. wH
araN,adanY"a aaaPrgt.MMa.ewaala4aru r/IJ Ole 0.r er,vlb AMa.raL ^aeapN[14elrgO,rk lMNxrMr�7 art 4a„'eararNr,A harFa P'rraaF alert barrwNaFTha
I ewmrr.dar w,wegr Akat.r.pw4ww,Ara.,Arru nr raw.
i
NOTICE TO COSIGNER
a"
YOU re DetnC Baked to U$rMe thla dobt. "n' catMulN balore you da' It the ba[rowar doeant pay the dobL you will Ova t0. Be sure you can afford l0
P_
I�you h�8a to, and tngl you wan(ro accept 1hW tasporiNMnly,
You cosy hayQ to pay up to the MI amount o! the debt ' the DorrOw.1 doe. trot Pay. You may ale. have to pay tale isos Or 00111 Bon costa which Increase this
a-- t
Tha _"' r cps collLct this debt fro m You w0hout Nei IryIn to colact from the bdnower, The uedilof can use the semis collection methods against you that
can b/ uatd o�Es the b0sower, I., se suing yrlu, ntshtnq yourwages, eta I! this debt Is over In default, that fact moy become a part of your dred8
race Th s n0. toe is nwi the contraq that makes you IClo for the debt.
Page 1 of 2
i
t WMBfiR ACC%WNUMBER CATE Of LOAN
TAMMY MYERS 07AS/200$
Itt 1 E i+�O MENTfi� WORD8 "MEDR UNION' MEAN$ MEMBERS IBT FEDERAL CREDIT UWOM THE WORDS "Ypu," YOUR' AND'YOURW MEAN THOBt:
LOAN AGREEMENT SECURITYAGRE.EINENJ
aY 1 n•0 A Oi: For eltre reyQ yaU pr to pay at 1. To •acute ■ rat of thh Iwrt ■IM a 9x dlture9 moor If the aMR
ratItt ��op n on e o p, amou v dw AU a a(y�emnt■ 4 You al rrteda p uNa p IIn�n a° n rll thla ton r In rat f4I on a tadu f ore■
p n� garb f dketoeura � t a o at b 1 oatcm`n4 r(tutldnsu+d un e r •eur�p �nraroae ht I r parr 7e W a you
u aro al Ihs onto Margo ot�l Z on page 1 • ■ do s B m o � t t a s Ima 1 ■ In
el fro ttldttl0 t° In ■� n6 rt m0 It 1ny
Of Ut16 moot aro b ed e a UmpAOn 81# MStD
u haw R40 R4e 0n9 llAad aeoutvd paYmctdS (tau on te atrrad an aU �ipr'r�c �rom i�tr
wYl ee mp eon IUe a ,p d n u t l k rr ,ve ya ateR ar�p Kyo ror w property.
pmtarrod eta 1 ou r UfataA to saHaN thrt CondNona of thal prelerr•d croaroolla nIk ■a n: Pr rb alyo� a a°ett for thin lan or 1%any
rate If you faA o yy aar y UutsAAmont byy OOttee Uma It la due, you VAN pay m.r roan t r� ■ v�� 6ro t o a•c 43 amour
add�lonal Intrtn on pfe ova due anroUnt �orrO raraw a �rOd un�n now °r n 6 uWr��ie wov propery
Aflosallon olDaymarts and Addlttonei paymonts PA ante ynd "ono d° w ar ■ a�n the roan arc �.. rl l
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ar fi canoe the 93;0 u3atendMO rMfdpeL Paynarte made in addlUon t =• M°V �� a n •nlbn of fella vanatartM o xWnN unhn you Mw
pp t c lrn s4etw V%n
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thledoameato+l asnpar�aattl44g0�rop'a reteddarrl�atlum, farOnO (owner a uxa1 a"i}p�e� on din ea
that ou mopt mee� the oon no Isdosad tp y k and r t qve roc fha �.
pfafl 9efd orb muss continue to mael lttoe9 eomfil]ons In order o keep s. yor ell t n aennmont■, and pam d oral ro the rourDretarred role, If y fpU to mael th�sa eondid e, your rite w9f daee„a�'�nd Nn ro k••th� o aorta r d a
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y OUfname8digress coralpyment .YQUprOfrlke�attoe roraloanif g roM rhh%ab■ne to you di ,uaytOrtMpraanbnaiM
you know lhma k a toasDnsbb pprrooDaDlpty Iha yw vA ba Ot� to repay or un an.
our oblgetlon clog to efe lsrma of Ota uedil extalnlon. You proMsa a dt^a a urnon sal at an ■ Y ara
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Statutory Llon; (( 9'ay�ttdha ', «el the cradl
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he
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bo AAy �spgnNhb w101 Ufa borrower, bW Ore aod4 Un(opp Iliay su0
eithe�or both W TTte orbit union does rrol have to noU7 oU Imat thb
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pa �a �cp ryvMhnulrtoU tpareleaaltrayoUhom eto01/aa
I •
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cred,lunfoo. IteJudtap fuhav Rc dm °xa, So sanrrly, for this loan. In ease you aft r aft iurw. dw atIM �dtMfaml%ttncluddmcostaol«'c t ns the mart ,
taalortabla ttwmay■ feet, m■r the cr•dh uniml may Amur, up to Nett al tee
unpaid pnf ;era and kuaosr. No nos or rtaht to tmprns a am on shares and
dea0sh6 a!, apply to any Myear Shares Wch maybe held In an - mdMdutt
Rataemsnt Aeeounr• er Weph (tent,"
Page 2 of 2
EXHIBIT "B"
Prepared By: Members ist FCU
5000 Louise Drive
Mechanicsburg, PA 17055
WHEN RECORDED, RZ17UM 1'0:
AQUlTYL0A1VSFXV10E4, !'NC.
1100 SUPEVIOR A VFNUE, 3=9200
01 VF:IAND, 0100 44114
NATIONAL RECOADEVC -FACT
MORTGAGE
Made 07 /18/2008
Between
TAMMY MYERS
Fercl called "Mortgagor"
And
MEMBERS 1� FEDERAL CREDIT UNION (hereinafter called "Mortgagee )
Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter
called the "Note ") of even date herewith, payable to the order of Mortgagee in the principal sum of
S 22,000,00 , lawfil money of the United States of America, and has provided therein
for payment of any a�ditio� moneys loaned or advanced thereunder by Mortgagee, together with
interest thereon at the rate provided in the Note, in the wanner and at tht times therein set forth, and
containing certain other terms and conditions, all of which are specifically Incorporated herein by
rc%rence;
Now,'l'herefore, 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 hereunder or under
the terms of the Note, does grant and convey unto Mortgagee,
All that certain property of the Mortgagor located In BOROUGH
CARLISLE
Cumberl County, Pennsylvania
SEE EXHIBIT "A"
which currently has the address of 147 N BEDFORD ST
[street]
Carlisle Pennsylvania 17013
[City] [zip Code]
Acct N. Page 1 of 4
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, Issues and profits thereof.
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 princi al 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,
This Mortgage is executed and delivered subject to the following covenants, oonditions and
agreements:
(1) The Note 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 time or times hereafter and
intended by Mortgagor 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 some shall became 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) ayy all ground roots reserved from the mortgaged premises and pay and discharge all
mechanics' lions wh�ch maybe filed against sold 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 parable on the Note
evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time
require upon rho buildings end improF ments now or hereafter erected upon the mortgaged premises,
with loss payable
at to favor ofrtgagor and Mortgagee as their respective Intorcsts may appear,
and (e) promptly submit to Mortgagevidence of the due and punctual payment of all the foregotrrg
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.
ACCT No Page 2 of 4
t
(4) In the event Mortgagor neglects or refuses to ay 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 ptemises, 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, of 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 tears of the Note or this
Mortgage, together with unpaid interest thoroon, shall at the option of Mortgagee and without notice
become immediately due and payable, and foreclosure proceedings may be brought forthwith on this
Mortgaagge and prosecuted to Judgment, 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 0 19) of the total indebtedness or
$200, wbichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said
proceedings, waives stay of execution, the right o € Inquisition and extension of time of payment, 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
MortF,age, but only if the fee is paid to a third party £or services rendered and the charging of the fee is
permitted under Applicable Law.
The covenants, conditions and agreements comained 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 morn than one party, the undertakings and liability of each
shall be joint and several.
Aon No AppID Page 3 of 4
Witness the due execution hereof the day and year first above written.
TAMMY M S
Commonwealth of Pennsylvania }
} ss:
i County of }
n this, the / 0 day of_ 2008 , before me,
tfio un erstgn a cer, personally appeared
TAMMY MYERB
satisfactorily proven to me to a persons) whose names stare su scn ed to wHin Mortgage, and
acknowledged that he/she executed the same for the purposes therein contained.
In Witness Whereof, I hereunto set my hand and official seal, , p
My cam OF
Notaftso
_D L I tMffl%mN NotaN f 9
����
Member, pemaf mia AaWdatlon of Notadea
C:erttfleate— of Residence of MortV gee
I
Members 1 Federal Credit Union, Mortgagee within named, hereby certifies its residence
is 5000 Louisa Drive, Mechanicsburg, PA 17055. By
Aon No Page 4 of 4
e .
EXHIBIT A
ALL THE FOLLOWING DESCRIBED REAL ESTATE LYING AND BEING
SITUATE IN THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY,
PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: ON TIM
NORTH BY LOT NOW OR FORMERLY OF C. H. SIPE; ON THE EAST BY
LOT NOW OR FORMERLY OF BEND THOMPSON; ON THE SOUTH BY THE LOT
NOW OR FORMERLY OF A. W. P. SIPE; ON THE WEST BY NORTH
BEDFORD STREET, CONTAINING IN FRONT ON BEDFORD STREET 18
FEET, IN DEPTH 90 FEET, MORE OR LESS. THE ABOVE- DESCRIBED
RRAL ESTATB IS THFs SAME WHICH MERRIE LEE PRICE, FORMERLY
MERRIE LEE WESSELS, AND COLE B. PRICE, III, HER HUSBAND, BY
DEBI) DATED MARCH 8, 1982, RECORDED IN CUMBERLAND COUNTY, PA.,
DEED BOOK S, VOL. 29, PAGE 220, CONVEYED TO TERRENCE A.
DRACHBAR AND CAROL A. DRACHBAR, HIS WIFE, THE GRANTORS
HEREIN. BOROUGH OF CARLISLE
Permanent Parcel Number: 21- 0318 -0194- 0000000 -02
TAMMY I. MYERS
147 NORTH BEDFORD STREET, CARLISLE PA 17013
Loan Reference Number 272665
Firet American Order No: 38072485
identifier: FIRST AMERICAN LENDERS ADVANTAGE
ll I1111i111l111(1N�! MYERS
38072483 PA
FIRST AMERICAN MS
MORTGAGE
lll(itllllt llEil�flllt8l(1(l1)111Ilia
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013 3
717 - 240 -6370 r
Instrument Number - 200826204
Recorded On 811/2008 Ai 10:32:16 AM * Total Pages - 6
• instrument Type - MORTGAGE
Invoice Number - 26271 User ID - KW
' Mortgagor - MYERS, TAMMY
* Mortgagee - MEMBERS 1ST FEDERAL CR UN
*Customer - FIRST AMERICAN
* FEES
STATE WRIT TAX $0.50 Certifications Page
STATE JCS /ACCESS TO $10.00
allSTICE DO NOT DETA
RECORDING FEES - $13.50
RECORDER OF DEEDS
AFFORDABLE HOUSING $11 .50 This page is now part
COUNTY ARC HIVES FEE $2.00 of this legal document.
ROD ARCHIVES rZE $3.00
TOT PM PAID $10.50
I Certify this to be recorded
in Cumberland County PA
��
RECORDER " a D DS
" - Information denoted by an asterisk may change daring
the verification process and may not be reflected on this page.
WDY3L
11,1111NI11�I1�11 {II Ii li{
VERIFICATION
I, JIM , as an employee ofMembers 1 Federal Credit Union, acknowledge
I have the authority to execute this Verification on behalf of Members 1 51 Federal Credit Union and
certify that the foregoing Complaint in Mortgage Foreclosure is based upon information which has
been gathered by my counsel in the preparation of the lawsuit. The language of this document is that
of counsel and not my own. I have read the document and to the extent the Complaint is based upon
information which I have given to my counsel, it is true and convect to the best of my knowledge,
information and belief. To the extent the content of the Complaint is that of counsel, I have relied
upon counsel in making this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904
relating to unsworn falsification to authorities, which provides that if I knowingly make false
averments, I may be subject to criminal penalties.
MEMBERS 1 1T FEDERAL CREDIT UNION
sy:
F :\FILFS\Cknts \11470 Membws 13011470 Current \I 1470.324 Myers \11470.324.Myers.CompWrit.wpd
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson :. .J ,:,s-E ,,
Sheriff kH r'krii I i.iC'i : , ,•,
Jody S Smith
Chief Deputy . ;,, 2014 MAR 12 PM 2: 142
Richard W Stewart CUMBERLAND COUNT'':'
Solicitor E 3=,
PENNSYLVANIA
Members 1st FCU Case Number
vs.
Tammy I. Myers 2014-1197
SHERIFF'S RETURN OF SERVICE
03/05/2014 03:07 PM - Deputy William Cline, being duly sworn according to law, served the reque ted Complaint&
Notice by"personally" handing a true copy to a person representing themselves to •/the Defendant, to
wit: Tammy I. Myers at 147 N. Bedford Street, Carlisle Borough, Carlisle, PA 01,
//'
W il"FrAM CLINE, DEPUTY
SHERIFF COST: $34.78 SO ANSWERS,
w-a--,...,,,,,....____________
March 10, 2014 RONF R ANDERSON, SHERIFF
Michael J. Pykosh, Esquire
ID # 58851
Dethlefs - Pykosh Law Group, LLC
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone — (717) 975 -9446
Fax — (717) 975 -2309
mpvkosh @dplglaw.com
;LEO-OFFICE
(..jF THE PROTHONOTARY
2014 APR 28 PM 1: 20
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney for Defendant
MEMBERS 1sT FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
TAMMY I. MYERS
Defendant
: No.14 -1197
: CIVIL TERM
: IN MORTGAGE FORECLOSURE
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012 governing the
Cumberland County Residential Mortgage Foreclosure Diversion Program, the
undersigned hereby certifies as follows:
1. Defendant is the owner of the real property which is the subject of this
mortgage foreclosure action;
2. Defendant lives in the subject real property, which is Defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage
Foreclosure Diversion Program: and has taken all of the steps required in that Notice to
be eligible to participate in a court- supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct.
understand that statements are made subject to the penalties of 18 Pa.C.S. §4904
relating to unsworn falsification to authorities.
ichael J. Pykosh, Esquire
Defendant's Counsel / Legal Representative
Tammy I. rs
Defendant
ate
Date 1/Z%//q
Michael J. Pykosh, Esquire
ID # 58851
Dethlefs- Pykosh Law Group, LLC
2132 Market Street
Camp 11111, Pennsylvania 17011
Telephone — (717) 975 -9446
Fax — (717) 975 -2309
mpykosh(atdplolaw.com
Attorney for Defendant
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : No. 14-1197
TAMMY I. MYERS : CIVIL TERM
Defendant : IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICES
I hereby certify that a copy of the foregoing DEFENDANT'S REQUEST FOR
CONCILIATION CONFERENCE, was hereby served by depositing the same within the
custody of the United States Postal Service, First Class, postage prepaid, addressed as
follows:
Member's 1st Federal Credit Union
c/o Christopher E. Rice, Esquire
Martson Deardorff Williams Otto Gilroy & Faller
Martson Law OfficesPhelan Hallinan, LLC
10 East High Street
Carlisle, PA 17013
Date: P-5 l if By:
Respectfully Submitted,
Michael J. Py osh, Esquire
ID # 58851
Dethlefs - Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
717- 975 -9446
Attorney for Defendant
1
MEMBERS 1 ST FEDERAL IN THE COURT OF COMMON PLEAS OF
CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff C')
VS. CIVIL ACTIONA - ;
NO. 14-1197 CIVIL
TAMMY I. MYERS, z� c
Defendant
C-0
W.
CASE MANAGEMENT ORDER
AND NOW, this 130 day of April, 2014, the parties having agreed to a
conciliation conference, it is hereby ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
Conciliation Conference on � AT old/y , at //gym. in
Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (2 1) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court,the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
R r
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
4�---� ' /-11
Kev' A. Hess, P.J.
stopher Rice, Esquire
McCabe, Weisberg& Conway, P.C.
10 East High Street
Carlisle, PA 17013
For the Plaintiff
�chael J. Pykosh, Esquire
2132 Market Street
Camp Hill, PA 17011
For the Defendant
:rlm
MEMBERS 1ST FEDERAL
CREDIT UNION,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION
: NO. 14-1197 CIVIL
TAMMY I. MYERS,
Defendant
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 27th day of June, 2014, in order to give the defendant the opportunity to
resolve this matter in the context of modification discussions with the first mortgage holder,
Wells Fargo, conciliation in this case is continued and a conference is set for Thursday, July 31,
2014, at 10:45 a.m.
t/Aaron Haynes, Esquire
10 East High Street
Carlisle, PA 17013
For the Plaintiff
✓Michael J. Pykosh, Esquire
2132 Market Street
Camp Hill, PA 17011
For the Defendant
:rim
(Ex fila;
Igs1a�y
BY THE COURT,
Kevin . Hess, P.
•
MEMBERS 1ST FEDERAL
CREDIT UNION,
Plaintiff
vs.
TAMMY I. MYERS,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION
: NO. 14-1197 CIVIL
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 31 day of July, 2014, following conciliation conference, this
matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion
Program and the stay in this case is lifted.
BY THE COURT,
Kevin Hess, P.
✓Aaron Haynes, Esquire
10 East High Street
Carlisle, PA 17013
For the Plaintiff
Xlichael J. Pykosh, Esquire
2132 Market Street
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Camp Hill, PA 17011 �c c.�71
For the Defendant z • z - rn
:rlm r—= —+`
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F:\FILES\Clients\11470 Members 1st \I 1470 Current \11470.324 Myers\I 1470.324.Myers.Praecipe for default.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
1 ;LEi-0 1=i0
THE PiR0TH0NOTAR
2011i AUG i 9 PH 3: 52
CUMBERLAND COUNTY
PENNSYLVANIA
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 14 - 1197 CIVIL TERM
TAMMY I. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
PRAECIPE
TO THE PROTHONOTARY:
Please enter default judgment in the above -captioned action in favor of Plaintiff and against
Defendant Tammy I. Myers in the amount of $20,086.32, plus interest from January 31, 2014, at the
rate of $3.73 per day until the debt is paid in full, along with any additional costs or attorney fees
incurred thereafter, for failure to file an Answer to Plaintiffs Complaint.
I do hereby certify that written notice of intention to file this Praecipe was mailed to
Defendant on August 5, 2014, which date is subsequent to the date default occurred and at least ten
(10) days prior to the date of the Praecipe.
Dated: ?MO.
MARTSON LAW OFFICES
By: 4 S'
Christopher E. Rice, Esquire
I.D. Number 90916
Aaron S. Haynes, Esquire
I.D. No. 307746
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
F:\FILES\Clients\ 11470 Members I st\ 11470 Current\ 11470.324 Myers\ 11470.324.10daynoti ce. wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA :
Plaintiff
v.
: NO. 14 - 1197 CIVIL TERM
TAMMY I. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
TO: Tammy I. Myers
147 North Bedford Street
Carlisle, PA 17013
IMPORTANT NOTICE
DATE OF NOTICE: August / , 2014
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MARTSON LAW OFFICES
By: 4
Christopher E. Rice, Esquire
I.D. No. 90916
Aaron S. Haynes, Esquire
I.D. No. 307746
This is a debt collecting firm attempting to collect a debt for Members 1` Federal Credit Union.
Any information obtained will be used for that purpose.
Christopher E. Rice, Esquire
Attorney I.D. No, 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 14 1 1*97 CIVIL TERM
TAMMY I. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
AFFIDAVIT AS TO MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
:SS.
COUNTY OF CUMBERLAND
Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has
authority to make this affidavit on behalf of his client, and to the best of his knowledge, information
and belief, Defendant Tammy I. Myers, above named is not in the military service of the United
States of America, that he has knowledge that the said Defendant's last known address is: 147 North
Bedford Street, Carlisle, Pennsylvania 17013. Said Defendant's place of employment is unknown.
Sworn to and subscribed before me
this I,iday of August, 2014.
11( .A40 -e"9
otarv/Public
Christopher E. Rice, Esquire
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary M. Price, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Aug. 18, 2015
MeHafg, pkVsYi—ruirPA ASSOCIATION OF NOT
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 14 - 1197 CIVIL TERM
TAMMY I. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
: SS
Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is
an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for
the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania
Rules of Civil Procedure, a notice of intention to enter default judgment against Defendant was given
to her by mail on August 5, 2014.
Sworn to and subscribed before me
this day of August, 2014.
Neta Public
Christopher E. Rice, Esquire
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary M. Price, Notary Public
Carlisle i3oro, Cumberland County
My Commission Expires Aug. 18, 2015
MEMBER, PENNSY'_'ANIA ASSOaATION OF NOTARIES
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by
depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as
follows:
Tammy L Myers
147 North Bedford Street
Carlisle, Pennsylvania 17013
MARTSON LAW OFFICES
By
ryA . Price
10 E. st High Street
Carlisle, PA 17013
Dated: 51%%//�
This is a debt collecting firm attempting to collect a debt for Orrstown Bank. Any
information obtained will be used for that purpose.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 14 - 1197 CIVIL TERM
TAMMY I. MYERS,
: IN MORTGAGE FORECLOSURE
Defendant
TO TAMMY I. MYERS:
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on the /9 `'` `day of
, 2014, the following
Judgment was entered against you in the above -captioned action: judgment in the amount of
$20,086.32, plus interest from January 31, 2014, at the rate of $3.73 per day until the debt is paid in
full, along with any additional costs or attorney fees incurred thereafter, for failure to file an Answer
to Plaintiffs Complaint.
Date: G% _ /9. /1/
Prothonotary
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
Tammy I. Myers
147 North Bedford Street
Carlisle, Pennsylvania 17013.
—
FAFILES \Clients\ 11470 Members 1st 11470 Current\IM70.324 Myers \ 11470.324.pra.discontinue.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
:LE- F ;CL'
THE PROTHONTrai-:;
ti SEP 2 3 PM 12: 3
CUMBERLAND COUNTY
PENNSYLVANIA
MEMBERS lsf FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA :
Plaintiff
V.
: NO. 14 - 1197 CIVIL TERM
TAMMY I. MYERS, : IN MORTGAGE FORECLOSURE
Defendant
PRAECIPE
To the Prothonotary:
Please mark the judgment in the above -referenced matter satisfied and the action discontinued.
MARTSON LAW OFFICES
Date:
By: <
Christopher E. Rice, Esquire
I.D. No. 90916
Aaron S. Haynes, Esquire
I.D. No. 307746
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Members it Federal Credit Union.
Any information obtained will be used for that purpose.
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date
by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed
as follows:
Tammy I. Myers
147 North Bedford Street
Carlisle, PA 17013
MARTSON LAW OFFICES
By
. Price
10 East High Street
Carlisle, PA 17013
Dated:
This is a debt collecting firm attempting to collect a debt for Members Federal Credit
Union. Any information obtained will be used for that purpose.