HomeMy WebLinkAbout14-1452 Supreme Court of Pennsylvania
Courts C011lm0 leas For Prothonotary Use Only:
Gi�il'C;overS,heett ;
3t Docket No:
CUMBRLAND County
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 required by law or rules of court.
Commencement of Action:
S El Complaint OA Writ of Summons J Petition
Transfer from Another Jurisdiction Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
Metro Bank f /k/a Commerce Bank / Harrisburg, N.A. Kenneth W. Heiser and M. Lucinda Heiser, Individually
T Dollar Amount Requested: Ow in arbitration limits
L Are money damages requested? Q -'es 0 No (check one) utside arbitration limits
O
N Is this a Class Action Suit? F71 Yes ER No Is this an MDJAppeal? 1 3 Yes El No
A Name of Plaintiff /Appellant's Attorney: Marc A. Hess, Esquire
Check here if you have no attorney (are a Self - Represented JPro 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
.+ Intentional 3 Buyer Plaintiff Administrative Agencies
Malicious Prosecution rr- Debt Collection: Credit Card 0 Board of Assessment
Motor Vehicle ❑ Debt Collection: Other 0 Board of Elections
Nuisance U Dept. of Transportation
® Premises Liability Statutory Appeal: Other
S Product Liability (does not include
Employment Dispute:
mass tort)
E : Discrimination
m � Slander/Libel/ Defamation J Employment Dispute: Other J Zoning Board
C Other:
IJ Other:
,
I U Other:
O MASS TORT
i=l Asbestos
N Li Tobacco
Toxic Tort - DES.
Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
u Toxic Waste J Ejectment El Common Law /Statutory Arbitration
B Other: =1 Eminent Domain /Condemnation Q Declaratory Judgment
J Ground Rent 0 Mandamus
0 Landlord/Tenant Dispute Q Non - Domestic Relations
- Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial El Quo Warranto
0 Dental El Partition , -3 R�PLevin
Legal +al Quiet Title L4" � r.
I- Medical E, Other:
E+ Other Professional:
Updated 1/1/2011
(t'1:1�� It'iG..y
HENRY & BEAVER LLP
By: Marc A. Hess
Identification No. 55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042 -1140
(717) 274 -3644
METRO BANK f /k/a COMMERCE IN THE COURT OF COMMON PLEAS
BANK / HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
vs. No.
(
1 - ' `l s c bv;
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually
and Jointly, and KENNETH W. HEISER
d /b /a YELLOW BREACHES BOX
COMPANY,
Defendants
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
I D
Ck-I�3asg
12-# W3&6
claimed in the Complaint or for any other claim or relief requested by the plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249 -3166 or (800) 990 -9108
AVISO
Le han demandado a usted en el tibunal. Si usted quiere defenderse de las demandas
expuestas en las paginas siguientes, usted debe tomar accion en el plazo de veinte
(20) dias a partir de la fecha en que se le hizo entrega de la demanda y la notificacion,
al interponer una comparecencia escrita, en persona o por un abogado y registrando
por escrito en el tribunal sus defensas o sus objeciones a las demandas en contra de
su persona. Se le advierte que si usted no to hace, el caso puede proceder sin usted y
podria dictarse un fallo por el juez en contra suya sin notificacion adicional y podria ser
por cualquier dinero reclamado en la demanda o por cualquier otro reclamo o
desagravio en la demanda solicitado por el demandante. Usted puede perder dinero o
sus propiedades u otros derechos importantes para usted.
USTED DEBE LLEVARLE ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE.
SI NO TIENE ABOGADO O NO PUEDE CORRER CON LOS GASTOS DE UNO,
VAYA O LLAME POR TELEFONE A LA OFICINA EXPUESTA ABAJO. ESTA
OFICINA PUEDE POVEERLE INFORMACION RESPECTO A COMO CONTRATAR A
UN ABOGADO.
2 -
SI NO PUEDE CORRER CON LOS GASTOS PARA CONTRA TAR A UN ABOGADO,
ESTA OFICINA PUDIERA PROVEERLE INFORMACION RESPECTO A
INSTITUCIONES QUE PUEDA OFRECER SERVICIOS LEGALES A PERONAS QUE
CALIFICAN PAR LA REDUCCION DE HONORARIOS O QUE NO TENGAN QUE
PAGAR HONORARIOS.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249 -3166 or (800) 990 -9108
ARC E S
- 3 -
HENRY & BEAVER LLP
By: Marc A. Hess
Identification No. 55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042 -1140
(717) 274 -3644
METRO BANK f /k/a COMMERCE IN THE COURT OF COMMON PLEAS
BANK / HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
vs. No.
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually
and Jointly, and KENNETH W. HEISER
d /b /a YELLOW BREACHES BOX
COMPANY,
Defendants
COMPLAINT TO CONFORM CONFESSED JUDGMENT
1. This is an action pursuant to Pennsylvania Rule of Civil Procedure Rule 2981,
et seq., to conform a confessed judgment.
2. The Plaintiff is Metro Bank f /k/a Commerce Bank / Harrisburg, N.A., with an
office located 3801 Paxton Street, Harrisburg, Pennsylvania 17111.
3. The Defendants Kenneth W. Heiser and M. Lucinda Heiser, individually and
jointly, and Kenneth W. Heiser d /b /a Yellow Breaches Box Company, are adult
s
individuals last known to reside at 1000 Sandbank Road, Mount Holly Springs,
Cumberland County, Pennsylvania 17035.
4. On or about February 17, 2006, Plaintiff loaned to the Defendants the sum of
Two Hundred Forty Thousand Dollars ($240,000.00) evidenced by a Promissory Note
and Commercial Guaranty executed and delivered to Plaintiff by Defendants on or
about February 17, 2006 (collectively the "Note and Guaranty ") upon which judgment
was confessed to No. 14 -843 Civil in the Court of Common Pleas of Cumberland
County, Pennsylvania on February 14, 2014 (the "Confessed Judgment ").
5. The Confessed Judgment was entered in the amount of:
Principal Sum Due - $ 158,871.32
Interest to 1/8/2014 - 8,619.96
Late Fees to 1/8/2014 - 2,721.20
Attorney's Commission (10% of unpaid
principal and interest) - 16,749.13
Total - $ 186,961.61
Together with interest which continues to accrue at the contract rate after January 8,
2014 and after entry of judgment and until paid in full ($26.478553 per diem), additional
late fees as may accrue at the contract rate, additional and reasonable attorney's fees
as may be incurred, all amounts expended or advanced by Plaintiff relating to the
collateral, together with costs of suit, execution and levy.
6. The Note is secured by Mortgages in and upon the Defendants real
properties commonly known as:
a. 1000 Sandbank Road, Mount Holly Springs, Cumberland County,
Pennsylvania 17065;
2 -
b. 830 North West Street, Carlisle, Cumberland County, Pennsylvania
17013.
c. 220 -231 East York Road, Carlisle, Cumberland County, Pennsylvania
17013.
7. With respect to the real properties, combined notices were given to
Defendants in accordance with Section 403 -C of Pennsylvania Act No. 91 of 1983 (35
P.S. §1680.403(c)) and Act 6 of 1974 (41 P.S. §403), copies of which are attached
hereto collectively as Exhibit "A" and incorporated herein by reference. Said notices
were mailed on or about October 11, 2013 and October 15, 2013.
8. The current amount due on said obligation is as follows:
Principal Sum Due - $ 158,871.32
Force Placed Insurance - 189.00
Interest to 2/28/2014 - 9,971.73
Late Fees to 2/28/2014 - 2,930.60
Attorney's Commission (10% of unpaid
principal and interest) - 16.903.20
Total - $ 188,865.85
Together with interest which continues to accrue at the contract rate after February 28,
2014, 2014 and after entry of judgment and until paid in full ($26.510053 per diem),
additional late fees as may accrue at the contract rate, additional and reasonable
attorney's fees as may be incurred, all amounts expended or advanced by Plaintiff
relating to the collateral, together with costs of suit, execution and levy.
WHEREFORE, the Plaintiff, Metro Bank f /k/a Commerce Bank / Harrisburg, N.A.,
requests your Honorable Court to enter judgment in its favor and against the
- 3 -
Defendants, Kenneth W. Heiser and M. Lucinda Heiser, individually and jointly, and
Kenneth W. Heiser d /b /a Yellow Breaches Box Company, in the amount of:
Principal Sum Due - $ 158,871.32
Force Placed Insurance - 189.00
Interest to 2/28/2014 - 9,971.73
Late Fees to 2/28/2014 - 2,930.60
Attorney's Commission (10% of unpaid
principal and interest) - 16.903.20
Total - $ 188,865.85
Together with interest which continues to accrue at the contract rate after February 28,
2014, 2014 and after entry of judgment and until paid in. full ($26.510053 per diem),
additional late fees as may accrue at the contract rate, additional and reasonable
attorney's fees as may be incurred, all amounts expended or advanced by Plaintiff
relating to the collateral, together with costs of suit, execution and levy, and further, to
conform the Confessed Judgment entered to No. 14 -843 in the Court of Common Pleas
of Cumberland County, Pennsylvania to the amount of the judgment entered in this
action and to merge the judgment in this action with the Confessed Judgment.
HENMARA R LLP
By:
S
. D. #55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042 -1140
(717) 274 -3644
Attorney for Plaintiff
- 4 -
i
METRO BANK f /k/a COMMERCE IN THE COURT OF COMMON PLEAS
BANK / HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
vs. No.
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually
and Jointly, and KENNETH W. HEISER
d /b /a YELLOW BREACHES BOX
COMPANY,
Defendants
VERIFICATION
I, David M. Chajkowski, being duly affirmed according to law, depose and say
that I am a Vice President - Asset Recovery Supervisor of Metro Bank, and that I am
authorized to make this Verification on its behalf and that the facts set forth in the
foregoing Complaint to Conform Confessed Judgment are true and correct to the best of
my knowledge, information and belief.
To the extent that any of the averments in the foregoing document are based
upon the understanding or application of law, I have relied upon counsel in making this
Verification.
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.
METRO BANK
By: !/
David M. Chajkowski
Vice President
Asset Recovery Supervisor
T
METRO BANK f /k/a COMMERCE IN THE COURT OF COMMON PLEAS
BANK / HARRISBURG, N.A., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
vs. No.
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually
and Jointly, and KENNETH W. HEISER
d /b /a YELLOW BREACHES BOX
COMPANY,
Defendants
AFFIDAVIT AS TO NON - MILITARY SERVICE AND CERTIFICATION
OF LAST KNOWN ADDRESS OF DEFENDANTS AND PLAINTIFF
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF DAUPHIN
Before me the undersigned authority, personally appeared Marc A. Hess of
Henry & Beaver LLP, who being duly sworn according to law, deposes and says that
upon reasonable investigation to the best of his knowledge and belief the Defendants
are not in the active Military or Naval Service of the United States of America and that
the last known address of said Defendants is as follows: 1000 Sandbank Road, Mount
Holly Springs, Pennsylvania 17035. The address of the above Plaintiff is 3801 Paxton
Street, Harrisburg, Pennsylvania 17111.
HE P
By:
AR . HES
I.D. #55774
Attorney for Plaintiff
Sworn t�oand subscribed to before me
iI 01 Is 4 ,, � day of
,
4. __4
Notary Public
NOTARIAL SEAL
PATRICIA LYOUNG, NOTARY PUBLIC
CITY OF LEBANON, LEBANON COUNTY
MY COMMISSION EXPIRES DECEMBER 17, 2017
7012 30150 0001 4112 2012
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Certified Mail Receipt 47012 3050 0001 4112 2012
October 10 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may
be able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your County
are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housing
Finance Agency toll free at 1- 800 - 342 -2397. (Persons with impaired hearing can call (717) 780 -1869.
This Notice contains important Iegal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a h,vyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
f
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address –1000 Sandbank Rd., Mt. Holly Springs, PA 17065
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE A HEMAP APPLICA TION AS SOON AS POSSIBLE IF YO U HA VE A
MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 30 DAYS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STARTING A
FORECL OSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STA Y OF FORECLOSURE'
YOU HA VE THE RIGHT TO FILE A HEMAP APPLICA TION EVEN BEYOND THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED AT
ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 1000 Sandbank Rd., Mt. Holly Springs, PA 17065
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, 52,094.00; April 17, 2013,
4
u
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10110113.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check,
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. `;'ou
may do so by paying the total amount then past due, plus any late or other charges then due, reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
4
a
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717 - 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriff s Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You may or _X_may not 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. -
E
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
' CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 -511 -2227 717- 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717- 762 -3285
717- 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717- 264 -5913
717- 234 -6616
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717- 334 -1518 800 - 342 -2397
V
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7012 3050 0001 4112 2005
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3801 Paxton Street
A K Harrisburg, 17111 9, 7012 3050 0001 4112 20 p 5 y � 111;1 g.9
PF1 NI. Lucinda Heiser
I'V 1000 Sandbank Rd.
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Certified Mail Receipt #7012 3050 0001 4112 2005
October 10, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may
be able to help to save your home. This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITH_ IN_ _33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you
when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your C( - .,Mly
are listed at the end of the Notice. If you have any questions you may call the Pennsylvania Housing
Finance Agency toll free at 1- 800 - 342 -2397. (Persons with impaired hearing can call (717) 780 -1869
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINA'N'CE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO `HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd,
Mt. Holly Springs, PA 17065
Property Address –1000 Sandbank Rd., Mt. Holly Springs, PA 17065
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE `FACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
*IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE HEMAPAPPLICATION IFYOUHAVEA
MEETING WITH A COUNSELING A GENCY WITHIN 33 DA YS OF THE POSTMARK DA TE OF
THIS NOTICE AND FILE AN APPLICA TION WITH PHFA WITHIN 30 DA YS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSUREAGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED , TEMPORARY STA Y OF FORECLOSURE':
YO U HA VE THE RIGHT TO FILE A HEMAP APPLICA TION EVEN BEYOND THESE TIME
PERIODS. ALA TE APPLICA TION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECL OSURE A CTION, BUT IF YOUR APPLICATION IS EVENTUALL YAPPRO VED AT
ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (BrinLr it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 1000 Sandbank Rd., Mt. Holly Springs, PA 17065
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
' $2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10/10/13.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You
may do so by paying the total amount then past due plus any late or other charges then due reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff's Sale asspecified in writing by the lender and by erformin any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
i •
T
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that
Sheriff's Sale of the mortgaged property could be held would be approximately six monthsfr such a
date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to Y e the you before the sale.
the
Of course, the amount needed to cure the default will increase the longer you wait. You ma
any time exactly what the required payment or action will be by contacting the lender. Y find out at
HOW TO CONTACT THE tE NDER :
Name of Lender. ro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717 - 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriff's Sale will end our owne rship of
the mortgaged property and your right to occupy it. If you continue to live in the property after t
Y
Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started e
the lender at any time. by
ASSUMPTION OF MORTGAGE —You _may or _X may not sell or transfer your home to
or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges
buyer
g
and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
i
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO DEBT
THIS DEBT. O PAY OFF
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING
BEHALF. ON YOUR
• TO HAVE THE MORTGAGE RESTORED TO THE SAME P O
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER DO NOT
O DEFAULT
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN AHAVE
N
CALENDAR YEAR.) y
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSU
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MO
DOCUMENTS. RTGAGE
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO
ACTION BY THE LENDER. SUCH
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of
Western PA Commission of Capital
2000 Linglestown Road Region
Harrisburg, PA 17102 1514 Derry Street
888 -511 -2227 Harrisburg, PA 17104
717- 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717 - 762 -3285
717- 885 -2752
PathStone Corporation PathStone Corporation
1625 North Front Street 450 Cleveland Avenue
Chambersburg, PA 17201
Harrisburg, PA 17102 7
717- 234 -6616 17 - 264 -5913
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717-334-1518 800 - 342 -2397
1 '
n 4 1 6 1 Oil 512013 f! Mad er FIRMCLASS ML AN 3801 Paxton Street - 5`0 K Harrisburg, PA 17111
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7012
3050 0001 4112 2241 ����T° � r,1 ; :12r,,;99g
}) Kenneth W. Heiser
830 North West St.,
Carlisle, PA 17013
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Kenneth W. Heiser
830 North West St.,
Carlisle, PA 17013
NIXIE 17::x..: FE._1
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Certified Mail Receipt 47012 3050 0001 4112 2241
October 11, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on vour home is in default and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HEMAP ma
be able to help to save your home This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving our Count
are listed at the end of the Notice. If you have any questions, you may call the Penns lvania Housin
Finance Agency toll free at 1 -800- 342 -2397 (Persons with impaired hearing can call (717 ) 780-1869.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 830 North West Street, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF F ORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE 33 DAYS OF THE DATE
E OF THIS NOTICE. G IF YOU
N O T APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRIN YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the If
may NOT take action against you for
thirty (30) days after the date of this meeting. The names addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise our
lender immediate] of your intentions. y
APPLICATION FOR MORTGAGE ASSISTANCE —yon mortg
forth later in this Notice (see following g pages for specific informatio about the natwef default.)
of def reasons set
You have the right to apply for financial assistance from the Homeowne '
. To do so, you must fill out, sign and file a completed lete Homeowner's Emergency
s Emergency Mortgage
Assistance Program
Assistance Program Application with one of the designated consumer cre
at the end of this Notice. Only consumer credit counseling d
i
and they will assist you in submitting a complete a nselin agencies have applications for the program
dt counseling agencies listed
Agency. To temporarily stop the lender from filing alforeclosureha P Pennsylvania Housing Finance
forwarded to the PHFA and received within thirty (30) days of our fa -
your application MUST be
counseling agency. Y ce to -face meeting with the
YOUSHOULD FILE HEMAP APPLICA TIONAS SOONASPOS
MEETING WITH CO UNSELING AGENCY WI THIN 33 DAYS OF IF YOU HA VEA
THIS NOTICE FILEANAPPLICATION SIBLE.
MEETING, THEN THE LENDER WILL T I TEMP THE POSTMARK DATE OF
WITHPHFA WITHIN30 DAYS OF THAT
FORECLOSUREAGAINST YOUR PROPERTY, A EXPLA YPI ?E NTED FROMSTARTINGA
CALLED "TEMPORARYSTAY OF F ORECLOSURE': BOA' IN THE SECTION
YOU HA VE THE RIGHT TO FILE A HEMAPAPPLICATION EVE
I 'E—�• A LATEAPPLICATION WILL NOT PREVEIVT THELE BEYOND THESE TIME
FORECLOSUREACTION, BUT IF YOUR APPLICATIONIS EVEN DER FROMSTARTINGA
ANY TIME BEFORE SHERIFF'S SALE, THE FORECLOSURE WILL AT
AGENCY ACTION— ILL BE STOPPED.
Available funds for emergency mortgage assistance are very limited. The
t
Housing Finance Agency has sixty (60) days to make a decision after it r Y well
be disbursed by the Agency under the eligibility criteria established b
During that time, no foreclosure Proceedings will Y he Act. The Pennsylvania ecei You your application.
requirements set forth above. You will be notified directly by h Pennsylvania Housing Finance
e Penns Iv you have met the time
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FO ATION
PURPOSES ONLY AND SHOULD NOT BE CO OF A PETITION IN
THE DEBT.
AN PTRT
CONSIDERED AS AS T M
O COLLECT
(If you have filed bankruptc
P y you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Brin '
NATURE OF THE DEFAULT —The MORTGAGE it u to date .
located at: 830 North West Street, Carlisle, PA 17013 debt held by the above lender on your property
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for
and the following amounts are now past due: March 17, 2013, $2,094.00 the 7 g months
p r to il 17, 2013,
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10/10/13.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check,
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon Your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will b e sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. You
may do so by paying the total amount then past due, plus any late or other charges then due, reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
s
a
l
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717- 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriff s 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
Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You may or _X_may not 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.
J A
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 -511 -2227 717 - 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717- 762 -3285
717- 885 -2752
PathStone Corporation PathStone Corporation
1625 North Front Street 450 Cleveland Avenue
Chambersburg, PA 17201
Harrisburg, PA 17102 7
717- 234 -6616 17 - 264 -5913
PA Interfaith Community PIMA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717 - 334 -1518 800 - 342 -2397
t
a
Y
7012 3050 1 - 0001 4112 2043
FIRST-CLASS MAIL
FRO i 10115;21:1113
ANK 3801 Paxton Street Harrisburg, PA 17111 G -� F��..��� -
` azz ZIP 1 111
7012 3050 0001 4112 2043° ;111! 26C'11 999
Kenneth W. Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
:_ p ;.
..
RETURN T S E:tj.DE -R
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UNIABL r 0,R WAR D
171111 41801 *85.3- 04069- 15 -.4.3
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Certified Mail Receipt 47012 3050 0001 4112 2043
October 10, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mort age on your home is in default and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HEMAP ma
be able to help to save vour home This Notice explains how the program works
To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN. 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name address and hone number of Consumer Credit Counseling Agencies serving our Count
are listed at the end of the Notice. If you have any questionsyou may call the Pennsylvania Housin
Finance Agency toll free at 1- 800 - 342 -2397. Persons with impaired hearing can call 717 780 -1869.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGidLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 830 North West Street, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE `FACT "), YOU MAY BE ELIGIBLE FOP.
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located ar set
forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOONAS POSSIBLE IF YO U HAVE A
MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE ANAPPLICA TION WITH PHFA WITHIN30 DAYS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED , TEMPORARY STAY OF FORECLOSURE'
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICA TION EVEN BEYOND THESE TIME
PERIODS. ALA TE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSUREACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVEDAT
ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 830 North West Street, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10110113.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You
may do so by paying the total amount then past due plus any late or other charges then due reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
f
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717- 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriff's 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
Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You _may or _X_may not sell or transfer your home to a buyer
or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges
and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
i
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888-511-2227 717- 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717 - 762 -3285
717 - 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717- 264 -5913
717- 234 -6616
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717 -334 -1518 800- 342 -2397
Isla 0 --n I e
BANK 3801 Paxton Street - r �6.f `"�
Harrisburg, PA 17111 " ;._._ ..F
7012 3050 0001 4112 2258
M. Lucinda Heiser
830 North West St.,
Carlisle, PA 17013
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Certified Mail Receipt #7012 3050 0001 41 12 2258
October 11, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may
be able to help to save your home. This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name, address and uhone number of Consumer Credit Counseling Agencies serving your County
are listed at the end of the Notice. If you have any questions you may call the Pennsylvania Housing
Finance Agency toll free at 1 -800- 342 -2397 (Persons with impaired hearing can call (717) 780-1869.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 830 North West Street, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF TH NOTICE. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE,
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
�
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE HEMAPAPPLICATION SOONAS POSSIBLE IF YOUHAVEA
MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DA TE OF
THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 30 DAYS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSUREAGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STA Y OF FORECLOSURE'
YOU HAVE THE RIGHT TO FILEA HEMAPAPPLICA TION EVEN BEYOND THESE TIME
P E R I O D S . A L A TEAPPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED AT
ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (BrinIZ it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 830 North West Street, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10110113.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You
may do so by paying the total amount then past due, plus any late or other charges then due reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717 - 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You _may or _X not sell or transfer your home to a buyer
or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges
and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 - 511 -2227 717- 232 -9757
Housing Alliance of YorW Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717 - 762 -3285
717- 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717- 264 -5913
717 - 234 -6616
PA Interfaith Community pHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717 - 334 -1518 800 - 342 -2397
"7012 305❑ 00 4112 2 036
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1VI. Lucincla Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
3
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17 111 (41 4 18
Certified Mail Receipt #7012 3050 0001 41 12 2036
October 10, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HEMAP ma
be able to help to save your home. This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency
The name address and phone number of Consumer Credit Counseling Agencies serving our Coant
are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housin
Finance Agency toll free at 1- 800 - 342 -2397 (Persons with impaired hearing can call (717 ) 780-1869.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINA°: CE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
• 0
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 830 North West Street, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
1
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOUSHOULD FILEA HEMAPAPPLICATION IFYOUHAVEA
MEETING WITHA COUNSELING AGENCY WITHIN 33 DA YS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE AN APPLICA TION WITH PHFA WITHIN 30 DA YS OF THA T
MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STARTING A
FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STA Y OF FORECLOSURE'
YOU HA VE THE RIGHT TO FILEA HEMAP APPLICA TION EVEN BEYOND THESE TIME
PERIODS. ALA TE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT
ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 830 North West Street, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10110113.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent'
revent the sale at any time up to one hour before the Sheriff's Sale You
may do so by paying the total amount then past due plus any late or other charges then due reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff's Sale as specified in writing by the lender and by performinany other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717- 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started �y
the lender at any time.
ASSUMPTION OF MORTGAGE —You _may or _X_may not 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.
w
v
e
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY -LAW. -
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 -511 -2227 717- 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717- 762 -3285
717 - 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717- 264 -5913
717- 234 -6616
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717- 334 -1518 800 - 342 -2397
-
• SECTION 7Signaht'
• .
■ Complete items 1, 2, and 3. Also complete item 4 if Restricte d Delivery is desired. 13 Agent ■ Print your name and address on the reverse 13 Addressee so that we can return, the card to you. Printed Name) C. D e of Delivery
■ Attach this card to the back of the mailpiece, 1
or on the front if space permits.
1. Article Addressed to: D. Is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: ❑ No
Kenneth W. Heiser
220 and 231 E. York Road
Carlisle, PA. 17013
3. ice Type
S 7ertified Mail 13 Express Mail
❑ Registered ❑ Return Receipt for Merohandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
2 '' .7012 3050 0001 4112 2234
�S Form, 381.1,, February 2004 ' Domestic Return Receipt 102595 - 02 -M -1540
M
ru
ru
ruts
r-a tage
Certiti ee
r q Postmark-
C3 , , Here =
C (Endor e s _. Required)
C3 A
Restrict very Fee
p (Endor equired)
U1
C3 Tr-' ' - - Kenneth W. Heiser
nu Se 220 and 231 E. York Road
r-1 Carlisle, PA 17013
p "si
(�- or -------- - - - - --
C
Certified Mail Receipt 47012 3050 0001 4112 2234
October 11, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the len intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRA (HEMAP) may
be able to help to save your home This Notice explains how the p w orks.
To see if_HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this N otice with you
when you meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving y our County
are listed at the end of the Notice If you have any questions you may call the Pennsylvania Housing
Finance Agency toll free at 1- 800 - 342 -2397 (Persons with impaired hearing can call (71 780 -1869.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 220 and 231 E. York Road, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE A HEMAP APPLICA TION AS SOON AS POSSIBLE IF YO U HA VE A
MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PRE VENTED FR OM STAR TING A
FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STAY OF FORECLOSURE"
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSUREACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED AT
ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 220 and 231 E. York Rd., Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
f
J
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10/10/13.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check,
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111-0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within - THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgalzed property.
IF THE MORTGAGE IS FORECLOSED UPON —Thd mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You
may do so by paying the total amount then past due plus any late or other charges then due, reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFFS SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717 - 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriff's 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
Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You may or _X_may not 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.
c
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. 1
-
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 -511 -2227 717- 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717 - 762 -3285
717- 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717 -264 -5913
717- 234 -6616
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717 - 780 -3940
717 -334 -1518 800- 342 -2397
7012 3050 0001 4112 2074
Fast C— ..
�� ,,,,{,� X06
i 6
i
BANK Harrisburg, PA 17111 _ 1 Eta
ZIP 1
7012 3050 0001 4112 2074 ''���''``"
Kenneth W. Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065 v
i
X1 'c 17 I) E 1021% fF a i' 4111.1
RETURN TO SENDER
SC: 17113141301 *0519-04054-15-43
o_
�
Certified Mail Receipt #7012 3050 0001 4112 2074
October 10, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default and the lender intends to
foreclose Specific information about the nature of the default i s p rovided in the at tached pages.
The HOME OWNER'S EMERGENCY MORTGAGE ASSISTAN PROGRAM ( HEMAP) may
be able to help to save your home This Notice explains ho the progr works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUN
_AGENC WITHIN 33 DAYS OF THE DATE OF THIS NOTIC Take this Not ice with you
when you meet with the Counseling Agency.
The name ad dress and phone number of Consumer Credit Counseling Ag encies serving your County
are listed at the end of the Notice If you have any questions You may c all the Pennsylvan Housing
Finance Atoll free at 1-800-342-2397. (Persons with impaired hea ring can call (717) 780 -1869.
This Notice contains important legal information. If you have any questions, representati) :.s at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 230 and 231 E. York Road, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT ' YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
. IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
�ENNSYLVANIA IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCC WITHIN THIRTY -THREE (33) DAYS OF TH DAT OF THIS NOTICE. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOL,Z
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names addresses and telephone numbers of
designate consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Ad vise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasc is 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 Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE HEMAP APPLICA TION SOONAS POSSIBLE IF YOUHAVE,'.
MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 30 DAYS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED , TEMPORARY STAY OF FORECLOSURE
YO U HA VE THE RIGHT TO FILE A HEMAP APPLICA TION EVEN BEYOND THESE TIME
PERIODS. A L A TEAPPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL Y APPROVED AT
ANYTIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 230 and 231 E. York Road, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
Y
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10/10/13.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICI : IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check,
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30;
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the len:'er
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorne fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time U to one hour before the Sheriff's Sale. You
may do so by paying the total amount then past due plus any late or other charges then due, reaso r-ible
at torney's fees and costs connected with the foreclosure sale and any other costs connec with the
Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717 - 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriff's 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
Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You may or _X_may not 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.
J
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 -511 -2227 717- 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717- 762 -3285
717- 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717- 264 -5913
717 - 234 -6616
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717 - 334 -1518 800 - 342 -2397
�. • SECTIO
• Complete items 1, 2, and 3. Also complete A. Sign ure I
Item 4 If Restricted Delivery is desired, ❑ Agent I
• Print your name and address orl the reverse X ❑ Addressee
so that we can return the Card to you. B. Received. (Printed Name) C. Date of Delivery
• Attach this card to the back, of the malipiece,
or on the front if space permits. ` 6
D. Is delivery address different from item 1? O Yes
1 t Article Addressed to: If YES, enter delivery address below, ❑ No
}
M. Lucinda Heiser
220 and 231 E. York Road J
Carlisle, PA 17013 3. Service Type
4 Certified Mail ❑ Express Mail
❑ Registered O Return Receipt for Merchandise
El Insured Mail E3 C.O.D.
- 4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article N-
(Transfer 7012 3050 0001 4112 2227
I PS Form 3811, February 2004 DoMestic Return Receipt 102595-02-M-1540,
rnu-j .. •
ru _
ru
ru u AL 11
Po ge $ i
rq iked Fee • st
C3 Pomark
Recei Fee J ' Here
( :Jent Required)
/.
Restricted Delivery Fee
O (Endorsement Required) /
U1
o Total M- Lucinda Heiser
M
ru Sent7 220 and 231 E. York Road
r Carlisle, PA 17013 °-- ----..
C3 Street
r� or PO
--- ----°
City, b
Certified Mail Receipt 47012 3050 0001 41 12 2227
October 11, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may
be able to help to save your home. This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you
when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your County
are listed at the end of the Notice. If you have any questions you may call the Pennsylvania Housing
Finance Agency toll free at 1- 800 - 342 -2397. (Persons with impaired hearing can call (717 ) 780 -1869
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 220 and 231 E. York Road, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE HEMAP APPLICA TION SOONAS POSSIBLE IF YOUHAVEA
MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE ANAPPLICA TION WITH PHFA WITHIN 30 DAYS OF THAT
MEETING, THEN THELENDER WILL BE TEMPORARILYPREVENTED FROMSTARTINGA
FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED ,, TEMPORARY STA Y OF FORECLOSURE'
YO U HA VE THE RIGHT TO FILEA HEMAP APPLICATION EVEN BEYOND THESE TIME
P E R I O D S . A L A TEAPPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED AT
ANYTIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 220 and 231 E. York Rd., Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
i
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10/10/13.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You
may do so by Raying the total amount then past due plus any late or other charges then due reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: 717 - 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA AUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You _may or _X_may not sell or transfer your home to a buyer
or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges
and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 -511 -2227 717 - 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717- 762 -3285
717- 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717- 264 -5913
717- 234 -6616
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717 - 334 -1518 800 - 342 -2397
° b
�1 F °S,..r.L_
F 1 )ii5
BA3801 NK Paxton Street
Harrisburg, PA 17111 ° � ZIP
1
7012 3050 0001 4112 2067 �� c� '' '1`
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
�;
R = u R N 0 .S E N D E rN
?" 17111141'801 *0519-04063-15-43
1.7111 @141
s .
Certified Mail Receipt #7012 3050 0001 4112 2067
October 10, 2013
ACT 6/91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may
be able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving your County
are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housing
Finance Agency toll free at 1- 800 - 342 -2397. (Persons with impaired hearing can call (717) 780 -1869.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a la,vyer.
LA NOTIFICACION EN AD.IUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Kenneth W. Heiser
M. Lucinda Heiser
1000 Sandbank Rd.
Mt. Holly Springs, PA 17065
Property Address – 230 and 231 E. York Road, Carlisle, PA 17013
Loan account number – 3308150
Original lender – Metro Bank
Current Lender /Servicer – Metro Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
•IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
�ENNSYLVANIA IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
_OCC WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES —If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for
thirty (30) days after the date of this meeting. The names addresses and telephone numbers of
designat consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advis your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed
at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be
forwarded to the PHFA and received within thirty (30) days of your face -to -face meeting with the
counseling agency.
YOU SHOULD FILE A HEMAP APPLICA TION AS SOON AS POSSIBLE IF YO U HA VE A
MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STAY OF FORECLOSURE".
YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS. ALA TE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL YAPPROVEDA T
ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT —The MORTGAGE debt held by the above lender on your property
located at: 230 and 231 E. York Road, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: March 17, 2013, $2,094.00; April 17, 2013,
$2,094.00; May 17, 2013, $2,094.00; June 17, 2013, $2,094.00; July 17, 2013, $2,094.00;
August 17, 2013, $2,094.00; and September 17, 2013, $2,094.00, plus Late Fees of $2,407.10.
TOTAL AMOUNT PAST DUE: $ 17,065.10, due $ 10110113.
HOW TO CURE THE DEFAULT —You may cure the default within THIRTY (30) DAYS of we date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$17,065.10 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check
certified check or money order made payable and sent to:
Metro Bank
3801 Paxton Street
P.O. Box 4999
Harrisburg, PA 17111 -0999
IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys
to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE —If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale 'Vou
may do so by paying the total amount then past due plus any late or other charges then due reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs connected with the
Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately six months from the
date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Metro Bank
Address: 3801 Paxton Street, P.O. Box 4999
Harrisburg, PA 17111 -0999
Phone Number: .717- 412 -6317
Fax Number: (717) 909 -0589
Contact Person: MELISSA HUMAN
EFFECT OF SHERIFF'S SALE —You should realize that a Sheriff s 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
Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE —You may or _X_may not 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.
w
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES
For Cumberland County
Advantage Credit Community Action
Counseling Service /CCCS of Commission of Capital
Western PA Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888-511-2227 717- 232 -9757
Housing Alliance of York/ Y Maranatha
Housing Resources 43 Philadelphia Avenue
290 West Market Street Waynesboro, PA 17268
York, PA 17401 717- 762 -3285
717- 885 -2752
PathStone Corporation
PathStone Corporation 450 Cleveland Avenue
1625 North Front Street Chambersburg, PA 17201
Harrisburg, PA 17102 717 - 264 -5913
717- 234 -6616
PA Interfaith Community PHFA
Programs Inc. 211 North Front Street
40 E. High Street Harrisburg, PA 17110
Gettysburg, PA 17325 717- 780 -3940
717- 334 -1518 800 - 342 -2397
40 Lt('4`0� fz
Z'14 FEAR 12 47 0
PEN14s yL.VA NIAN I .
HENRY & BEAVER LLP
By: Marc A. Hess
Identification No. 55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042 -1140
(717) 274 -3644
BANK f /k/a COMMERCE IN THE COURT OF COMMON PLE LVANIA
AS
METRO : CUMBERLAND COUNTY, BANK /HARRISBURG, N.A.,
Plaintiff :CIVIL ACTION -LAW - Z
vs.
No. , �� % Gut
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually
and Jointly, and KENNETH W. HEISER
d /b /a YELLOW BREACHES BOX
COMPANY,
Defendants
PRAECIPE FOR ENTRY OF APPEARANCE
Sir, please enter the appearance of Marc A. Hess, of the law firm of Henry &
Beaver LLP, 937 Willow Street, P.O. Box 1140, Lebanon, Pennsylvania 17042 -1140, on
behalf of Metro Bank.
HE ER LP
Date: ^N��u , 2014 By
A. HE S
I.D. #55774
SHERIFF'S OFFICE OF CUMBERLAND ��o�����
~�" "^—"�"" " ~° ="" " "~�~~ ~°" ~°~°"°"����"~°~"�"�=° COUNTY
"
FI LO UFHL
Ronny R Anderson 1:,i7 THE PROTHONOTAR'
Sheriff
��m��,
Jody SSm�h ~ �~�+ 2014NMR 1 9 PNb 06
Chief Deputy
CUMBERLAND COUNTY
Solicitor orP)uOFnHEwVE«iFF PENNSYLVANIA
Metro Bank f/k/a Commerce , N.A.
vs.
Kenneth Heiser (et al.)
Case Number
2014-1452
SHERIFF'S RETURN OF SERVICE
03/13/2014 05:46 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint &
Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Kenneth Heiser at 1000 Sandbank Rd., Dickinson Twp., Mt. Holly Springs, PA 17065.
04A0-1
DAWN KELL, DEPUTY
03/13/2014 05:46 PM Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint &
Notice by handing a true copy to a person representing themselves to be Ken Heiser, Husband, who
accepted as "Adult Person in Charge" for M. Lucinda Heiser at 1000 Sandbank Road, Dickinson
Township, Mt. Holly Springs, PA 17085.
DAWN KELL, DEPUTY
SHERIFF COST: $51.91 SO ANSWERS,
i6,12_Q_
March 14, 2014 RONN1Y R ANDERSON, SHERIFF
(0. CountySuits Sheriff: Theosoft.
HENRY & BEAVER LLP
By: Marc A. Hess
Identification No. 55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042 -1140
(717) 274 -3644
METRO BANK -f /k/a COMMERCE
BANK / HARRISBURG, N.A.,
Plaintiff
FILED - OFFICE
OF THE PROTHONOTARY
2014 APR 25 A O
CUMBERLAND COUNTY
PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
vs. : No. 14 -1452 Civil
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually :
and Jointly, and KENNETH W. HEISER :
d /b /a YELLOW BREECHES BOX
COMPANY,
Defendants
PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
TO THE PROTHONOTARY:
Please enter judgment by default in favor of Plaintiff, Metro Bank f /k/a Commerce
Bank / Harrisburg, N.A., and against Defendants, Kenneth W. Heiser and M. Lucinda
Heiser, individually and jointly,. and Kenneth W. Heiser d /b /a Yellow Breeches Box
Company, for their failure to plead to the Complaint in this action within the time
required. The Complaint contains a Notice to Defend within twenty (20) days from the
134//v
AV' '309191f
Lgettie, /made,
date of service thereof. Defendants were served with the Complaint on March 13, 2014,
and their answer was due to be filed on April 2, 2014.
Attached as Exhibit "A" is a copy of Plaintiffs written Notice of Intention to File
Praecipe for Entry of Default Judgment which I certify was given in accordance with
Pa.R.C.P. 237.1 by regular mail to the Defendants at their last known address on April
7, 2014, which is at least ten (10) days prior to the filing of this Praecipe. To the best of
the undersigned's knowledge and belief Defendants are not represented by counsel of
record in the within matter.
Please enter judgment by default in favor of Plaintiff and against Defendants in
the amount of:
Principal Sum Due -
Force Placed Insurance -
Interest to 2/28/2014 -
Late Fees to 2/28/2014 -
Attorney's Commission (10% of unpaid
principal and interest) -
Total -
$ 158,871.32
189.00
9,971.73
2,930.60
16,903.20
$ 188,865.85
Together with interest which continues to accrue at the contract rate after February 28,
2014, 2014 and after entry of judgment and until paid in full ($26.510053 per diem),
additional late fees as may accrue at the contract rate, additional and reasonable
attorney's fees as may be incurred, all amounts expended or advanced by Plaintiff
relating to the collateral, together with costs of suit, execution and levy, and further, and
please conform the Confessed Judgment entered to No„14-843 in the Court of
2
Common Pleas of Cumberland County, Pennsylvania to the amount of the judgment
entered in this action and merge the judgment in this action with the Confessed
Judgment.
HENR°it"- LLP rillarcV
By:
M'RC ESS
1.D. #55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042 -1140
(717) 274 -3644
Attorney for Plaintiff
HENRY & BEAVER LLP
By: Marc A. Hess
Identification No. 55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042-1140
(717) 274-3644
METRO BANK f/k/a COMMERCE : IN THE COURT OF COMMON PLEAS
BANK / HARRISBURG, N.A., : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff : CIVIL ACTION - LAW
VS.
: No. 14-1452 Civil
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually :
and Jointly, and KENNETH W. HEISER :
d/b/a YELLOW BREACHES BOX
COMPANY,
Defendants
To: Kenneth W. Heiser
1000 Sandbank Road
Mount Holly Springs, PA 17035
M. Lucinda Heiser
1000 Sandbank Road
Mount Holly Springs, PA 17035
Kenneth W. Heiser
d/b/a Yellow Breaches Box Company
1000 Sandbank Road
Mount Holly Springs, PA 17035
Date of Notice: April 7, 2014
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY A I I ORNEY 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, PA 17013
(717) 249 -3166 or (800) 990 -9108
HENR -`AV R LLP
AWAINTAIAAlr
AR�1'.HES
I.D. #55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042 -1140
(717) 274 -3644
Attorney for Plaintiff
By:
Name and Address of Sender
Marc A. Hess, Esquire ES
4
Henry & Beaver LLP
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042-1140
Certificates of Mailing
Check type of mail or service: Cer
❑ Adult Signature Required ❑ Adult Signature Restricted Delivery
❑ Certified Mail ❑ Recorded Delivery (International]
❑ COD ❑ Registered
❑ Delivery Confirmation ❑ Return Receipt for Merchandise
❑ Express Mail ❑ Signature Confirmation
Affix Stamp Here
(If issued asa
certificate of mailing
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1.
Kenneth W. Heiser
-1000 Sandbank Road
Mount Holly Springs, PA -1"7035
2.
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1000 Sandbank Road
3.
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dlbla Yellow Breaches Box
4.
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1000 Sandbank Road
.Mount. Holly Springs, PA 17035...
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HENRY & BEAVER LLP
By: Marc A. Hess
Identification No. 55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042-1140
(717) 274-3644
METRO BANK f/k/a COMMERCE
BANK / HARRISBURG,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
vs. No. 14-1452 Civil
KENNETH W. HEISER and •
M. LUCINDA HEISER, Individually :
and Jointly, and KENNETH W. HEISER :
d/b/a YELLOW BREECHES BOX
COMPANY,
Defendants
To: Kenneth W. Heiser
1000 Sandbank Road
Mount Holly Springs, PA 17035
M. Lucinda Heiser
1000 Sandbank Road
Mount Holly Springs, PA 17035
Kenneth W. Heiser
d/b/a Yellow Breeches Box Company
1000 Sandbank Road
Mount Holly Springs, PA 17035
NOTICE OF ENTRY OF JUDGMENT
Pursuant to Pa.R.C.P. Rule 236 please be advised that judgment by default in
the above proceeding was entered against you on 4,/..71 , 2014, in the
amount of:
Principal Sum Due -
Force Placed Insurance -
Interest to 2/28/2014 -
Late Fees to 2/28/2014 -
Attorney's Commission (10% of unpaid
principal and interest) -
Total -
$ 158,871.32
189.00
9,971.73
2,930.60
16,903.20
$ 188,865.85
Together with interest which continues to accrue at the contract rate after February 28,
2014, 2014 and after entry of judgment and until paid in full ($26.510053 per diem),
additional late fees as may accrue at the contract rate, additional and reasonable
attorney's fees as may be incurred, all amounts expended or advanced by Plaintiff
relating to the collateral, together with costs of suit, execution and levy, and further, and
conform the Confessed Judgment entered to No. 14-843 in the Court of Common Pleas
of Cumberland County, Pennsylvania to the amount of the judgment entered in this
action and merge the judgment in this action with the Confessed Judgment. A copy of
the Praecipe for Entry of Judgment by Defqiult is attached hereto.
PkOTHONb RY
Date:
, 2014
C1.111136.-.RI.
1 RI.A/
PENNSYLVANIA
ES,u
S YL VA NIAt� i` y'
HENRY & BEAVER LLP
By: Marc A. Hess
Identification No. 55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042-1140
(717) 274-3644
METRO BANK f/k/a COMMERCE : IN THE COURT OF COMMON PLEAS
BANK / HARRISBURG, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff : CIVIL ACTION - LAW
vs. : No. 14-1452 Civil
KENNETH W. HEISER and
M. LUCINDA HEISER, Individually :
and Jointly, and KENNETH W. HEISER :
d/b/a YELLOW BREECHES BOX
COMPANY,
Defendants
MOTION FOR ORDER PURSUANT TO
NO. 407 OF ACT 6 OF 1974 AND Pa.R.C.P. 2981 et seq.
COMES NOW, the Plaintiff, Metro Bank f/k/a Commerce Bank / Harrisburg, N.A.,
by and through its attorneys, Henry & Beaver LLP, and respectfully represents as
follows:
1. On February 14, 2014, pursuant to Pa.R.C.P. 2951(b) Plaintiff entered
judgment by confession against Defendants in the Court of Common Pleas of
Cumberland County, Pennsylvania, docketed at number 14-843 Civil (the "Confessed
Judgment") in a sum itemized as follows:
Principal Sum Due -
Interest to 1/8/2014 -
Late Fees to 1/8/2014 -
Attorney's Commission (10% of unpaid
principal and interest) -
Total -
$ 158, 871.32
8,619.96
2,721.20
16,749.13
$ 186, 961.61
Together with interest which continues to accrue at the contract rate after January 8,
2014 and after entry of judgment and until paid in full ($26.478553 per diem), additional
late fees as may accrue at the contract rate, additional and reasonable attorney's fees
as may be incurred, all amounts expended or advanced by Plaintiff relating to the
collateral, together with costs of suit, execution and levy.
2. On March 13, 2014, Plaintiff filed a Complaint required by No. 407 of the Act
of January 30, 1974, P.L. 13, 41 P.S. §101, et seq., as last amended, and Pa.R.C.P.
2981, et seq. against the Defendants which had attached to the front thereof a Notice to
Plead within twenty (20) days and which was docketed to action number 14-1452 Civil
(the "Conforming Action").
3. Defendants were served with the Conforming Action by the Sheriff of
Cumberland County on March 13, 2014, and Defendants' answer was due to be filed on
or before April 2, 2014.
4. Defendants did not answer the Conforming Action and on April 7, 2014,
Defendants were mailed by regular United States mail, postage prepaid, written Notices
of Intention to File a Praecipe for Entry of Default Judgment.
5. On April 25, 2014, upon Praecipe of Plaintiff, a default judgment was entered
in the Conforming Action against Defendants at Action No. 14-1452 Civil in the Court of
Common Pleas of Cumberland County, Pennsylvania in the following amount:
Principal Sum Due -
Force Placed Insurance -
Interest to 2/28/2014 -
Late Fees to 2/28/2014 -
Attorney's Commission (10% of unpaid
principal and interest) -
Total -
$ 158,871.32
189.00
9,971.73
2,930.60
16,903.20
$ 188,865.85
Together with interest which continues to accrue at the contract rate after February 28,
2014, 2014 and after entry of judgment and until paid in full ($26.510053 per diem),
additional late fees as may accrue at the contract rate, additional and reasonable
attorney's fees as may be incurred, all amounts expended or advanced by Plaintiff
relating to the collateral, together with costs of suit, execution and levy.
6. Pursuant to No. 407 of the Act of January 30, 1974, P.L. 13, 41 P.S., as last
amended, and Pa.R.C.P. 2986(a) the Confessed Judgment and the judgment in the
Conforming Action shall merge and the Court shall enter an appropriate Order
conforming the Confessed Judgment to the Conforming Action judgment.
7. Movant does not believe that any judge of the Court of Common Pleas of
Cumberland County, Pennsylvania has previously ruled upon an issue in this matter nor
has any judge been assigned hereto.
8. Concurrence of counsel has not been sought as Defendants do not have
counsel of record in the within matter.
9. Movant believes and therefore avers that no argument or briefing is
necessary in the within matter as the relief requested herein is required by Pa.R.C.P.
2986(a).
WHEREFORE, Plaintiff respectfully moves that this Honorable Court conform the
Confessed Judgment entered to No. 14-843 Civil in the Court of Common Pleas of
Cumberland County, Pennsylvania to the judgment in this Conforming Action with which
it has merged pursuant to Pa.R.C.P. 2986(a) so that execution can be had on the
conformed confessed judgment and that an Order directing as such be entered in each
action.
HENRY & BEAVER LLP
By:
M ° RC A. HESS
I.D. #55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042
(717) 274-3644
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in this Motion for Order Pursuant to Pa.R.C.P.
2986 are true and correct. 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.
HENRY ::EAVERLLP
ClAw441.
By: il��l �1`
►...��
M'RCA.HE S
I.D. #55774
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Lisa I. Fox, of the firm of Henry and Beaver, LLP, do hereby certify that I have
forwarded a certified true and correct copy of the within Motion For Order Pursuant To
No. 407 Of Act 6 Of 1974 and Pa.R.C.P. 2981 et seq. by regular United States mail,
postage prepaid, on
a04
Kenneth W. Heiser
1000 Sandbank Road
Mount Holly Springs, PA 17035
M. Lucinda Heiser
1000 Sandbank Road
Mount Holly Springs, PA 17035
, 2014, to the following:
Kenneth W. Heiser
d/b/a Yellow Breaches Box Company
1000 Sandbank Road
Mount Holly Springs, PA 17035
LISA I. FOX