Loading...
HomeMy WebLinkAbout14-1496nnsylvania County For Prothonotary Use Only: rq fisr�. Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. S T I '0 N A Commencement of Action: Petition Declaration of Taking o Complaint 0 Writ of Summons 0 El Transfer from Another Jurisdiction as Lead Plaintiff's Name: Fulton Bank, N.A., formerly known as Fulton Bank Lead Defendant's Name: Unknown Heirs, Successors, Assigns and all Persons, Firms, or Associations claiming Right, Title or Interest from or under Viola R. Limric, Deceased Are money damages requested? 0 Yes 0 No Dollar Amount Requested: within arbitration limits (check one) i outside arbitration limits Is this a Class Action Suit? 0 Yes ® No Is this an MDJ Appeal? ® Yes 0 No Name of Plaintiff/Appellant's Attorney: Shawn M. Long, Esquire 0 Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) S E C T I 0 N 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) ® Intentional ® Malicious Prosecution ® Motor Vehicle O Nuisance O Premises Liability ® Product Liability (does not include mass tor O Slander/Libel/ Defamation O Other: MASS TORT Asbestos ® Tobacco ® Toxic Tort - DES O Toxic Tort - Implant O Toxic Waste O Other: PROFESSIONAL LIABLITY O Dental O Legal ® Medical ▪ Other Professional: 4219548 CONTRACT (do not include Judgments) O Buyer Plaintiff O Debt Collection: Credit Card O Debt Collection: Other O Employment Dispute: Discrimination O Employment Dispute: Other O Other: REAL PROPERTY O Ejectment O Eminent Domain/Condemnation O Ground Rent ® Landlord/Tenant Dispute O Mortgage Foreclosure: Residential O Mortgage Foreclosure: Commercial O Partition O Quiet Title 0 Other: CIVIL APPEALS Administrative Agencies Board of Assessment ® Board of Elections O Dept. of Transportation ® Statutory Appeal: Other • O Zoning Board ® Other: MISCELLANEOUS ▪ Common Law /Statutory Arbitration O Declaratory Judgment ® Mandamus 0 Non- Domestic Relations ® Restraining Order Quo Warranto ® Replevin O Other: Updated 1/1/2011 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 F FICE C`F PRO IHOOFARY 20V1 MAR R 11: 53 CUMBERLAND COUNTY PENNSYLVAWA Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No /xi Pi9(0 a it. NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 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 to you for any money claimed in the Compla /0 3. 7,S" ?ci_ight ckszt S+747 3a2 958 or for any other claim or relief requested by Plaintiff(s). 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 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249 -3166 Effective September 1, 2003 4216798 -1 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Fulton Bank, 1V.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes, usted debe tomar la accion en el plazo de veinte (20) dias despues de esta queja y el aviso es servido, incorporando un aspecto escrito personalmente o por el abogado y archivando en escribir con la corte sus defensas u objeciones a las demandas dispuestas contra usted. Le advierten que si usted no puede hacer asi que el caso puede proceder sin usted y un juicio se puede incorporar contra usted por la carte sin aviso adicional a usted para cualquier dinero demandado en la queja o para cualquier otra demanda o relevacion pedida por Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza importante a usted. USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A 0 LLAME FOR TELEFONO La OFICINA DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACION SOBRE EMPLEAR A un ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE LOS SERVICIOS JURiDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES EN Un HONORARIO REDUCIDO 0 NINGON HONORARIO. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 Efectivo 1 de Septiembre, 2003 Queja 4216798-1 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Fulton Bank, NA., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - MORTGAGE FORECLOSURE No. COMPLAINT 1 Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank ("Fulton"), is a national banking association having an office at One Penn Square, P.O. Box 4887, Lancaster, Pennsylvania 17604. 2. Defendant, Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title, or interest from or under Viola R. Limric, deceased, is an adult individual with a last known address of 317 Third Street, Summerdale, Pennsylvania 17093. 3. On or about November 17, 1999, Defendant executed and delivered to Fulton a Note (the "Note ") in the original principal sum of $41,000.00. A true and correct copy of the Note is attached hereto as Exhibit "A" and incorporated herein by reference. 4. The Note carries interest at the initial rate of 8.240% per annum and requires Defendant to make monthly payments of principal and interest in the initial amount of $398.72, beginning January 5, 2000 and continuing thereafter on the fifth (5th) day of every month until all outstanding principal and all accrued interest are paid in full. 5. The Note requires Defendant to pay a late charge of five percent (5 %) of the overdue payment of principal and interest or $5.00, whichever is greater, when Fulton does not receive Defendant's monthly payment within ten (10) days of the date that the payment is due. 6. The Note is secured and accompanied by a Mortgage (the "Mortgage ") dated November 17, 1999 and recorded in the Office of the Recorder of Deeds of and for Cumberland County, Pennsylvania, on December 2, 1999, on Defendant's property being located at 317 Third Street, Summerdale, Cumberland County, Pennsylvania (the "Premises "). A true and correct copy of the Mortgage is attached hereto as Exhibit "B" and incorporated herein by reference. 7. Defendant is in default under the Note and Mortgage for failure to make monthly payments which were due beginning September 5, 2013 and each month thereafter. 8. Notice as required by the Homeowner's Emergency Mortgage Assistance Act of 1983 (Pennsylvania Act 91) was sent to Defendant by Certified Mail, Return Receipt Requested on December 16, 2013. A true and correct copy of this notice is attached hereto as Exhibit "C" and incorporated herein by reference. 4216798 -1 9. Pursuant to the Note, in the event of Default, Fulton may, and hereby does, declare all amounts owed under the Note, including principal, accrued interest, late charges, and all other charges, including reasonable attorneys' fees, to be immediately due and payable. 10. Pursuant to the Note, in the event of Default, Fulton is entitled to be reimbursed for all costs and expenses, including reasonable attorneys' fees incurred in bringing any action to enforce the Note. 11. For purposes of this action, Fulton believes, and therefore avers, that $3,000.00 constitutes reasonable attorneys' fees for enforcing the Note. However, Fulton recognizes that it is restricted by law to those attorneys' fees that are actually incurred. If those fees are less than $3,000.00, Fulton agrees to adjust its demand for attorneys' fees, if applicable, at the time payment on any judgment is made. 12. As of February 12, 2014, the amount due on the Note and the Mortgage is as follows: Principal Balance Interest through 02/12/14 at a rate of $1.53 per diem Late Charges Attorneys' Fees $6,779.95 168.37 219.27 3,000.00 Total $10,167.59 plus continuing interest after February 12, 2014 at a rate of $1.53 per diem, plus continuing late charges, attorneys' fees and costs. 13. Fulton has demanded payment of the amount owed from Defendant but Defendant has failed and /or has refused to pay the same. 4216798 -1 14. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant the name and address of the original creditor if different from the above. WHEREFORE, Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank demands judgment against Defendant, Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title, or interest from or under Viola R. Limric, deceased, in the amount of $10,167.59, plus continuing interest after February 12, 2014 at a rate of $1.53 per diem, plus continuing late charges, attorneys' fees and costs. Date: 4216798 -1 BARLEY S f ER By: hawn M. Lon-, Esquire Attorneys for ° laintiff, Fulton Bank, .A., formerly known as Fulton Bank Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 VERIFICATION FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED I, MICHELE HECK, being duly affirmed according to law, depose and say that I am Authorized Representative for Fulton Bank, N.A., formerly known as Fulton Bank; that I am authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint 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. This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: Michele Heck Fulton Bank 1695 State Street East Petersburg, PA 17520 You LENDER'S NAME AND ADDRESS moans the Lender its successors and asst VIOLA R LIMRIC 317 THIRD STREET Summerdale, PA 17093 BORROWER'S NAME AND ADDRESS TERMS FOLLOWING A I I APPLY ONLY tF CHECKED I includes Bach Borrower above Ioontty end severally TOTE For value recoived, I promo to pay to you, or your order at your address above the principal sum of Forty One Thousand and No /100 Loan Number 0491363665 Date Malumy Date Loan Amount $ 41,000 00 Renewal OI 1/17/1999 2/05/2014 Mrs interest itom November 22, 1999 auhereteot 8 240 �7 ADDITIONAL RNANCE CHARGE - I also agree to pay a nonrefundable lee of S and it will be I 1pad to cash I- - over the loan term I 1 withheld imm the proceeds ill this he is withheld from the proceeds the amount is included in me principal sum ) tAYMENT I will pay this note as follows DvIlatss 41,000 00 nperyearumn December 5, 2014 (a) I I Interest due Principal due 0 pad pm rata (b) I xJ Thrs note has 180 payments The first payment will be in the amount of $ will be due on the 5th day of each A payment of$ 398 72 The trial payment of the entire unpaid balance at pnnapal and interest will be due NTEREST - Interest accrues on a Simple Interest basis 1.7 MINIMUM FINANCE CHARGE - I agree to pay a minimum finance charge of d i pay this loan off before you have earned that much in finance charges IA 1 LATE CHARGE I agree to pay a late charge on any installment or payment lade more than 10 days after it is due equal to S 000 % of the 5 00 ,whichavarts greater nixed amount, or 398 72 month andwritbedue 01/05/2000 December 5, 2014 thereafter i I RETURNED CHECK CHARGE - I agree to pay a fee of S for each check negotiable order of withdrawal or draft I Issue In connection with this loan that is returned because it has been dishonored I I POST- MATURITY INTEREST - Interest mull accrue at the rata of per year on the balance of this note not peed at maturity Including ma unty y arceterevon THE PURPOSE OF THIS LOAN IS - Home Improvement IECURITY You have certain nphts that may affect my property as eyplemed on page 2 This loan t X1 is is not further secured (a) n This loan is secured by ivI ( dated (b) Security Agreement - I rove you a security interest in the Property descnbod below The rights I am giving you in Iles Properly and the obttgaons agreement secures am deemed on page 2 of this agreement #1 Real Estate 317 THIRD STREET, EAST PENNSHORO TOWNSHIP, Summerdale, PA 17093 This Property wall be used for loan collateral parks% this ANNUAL PERCENTAGE RATE The cost at my Credit as a yearly rate 08 240 v, FlNANC£ CHARGE The darter amount the credit null cost me $ 20,769 60 AMOUNT FINANCED The amount of credo provided to ma or on my behalf $ 41,000 00 TOTAL OF PAYMENTS The amount I well have paid when i have made all scheduled payments $ 71,769 60 i have the nqN to re olve ai thus tens an itaflirtation of the Amount Financed YES !want XX an nemtiaten NO Ido not wain an Itemization My Payment Schedule wd3 be Number of Payments Amount of Payments When Payments Am Due 180 $ 398 72 Beginning January 5, 2000 o•meansar,esornate $ $ Filing Fees 5 $ Nonbkn$ insurance 0 This note has a demand feature I 1 Thus note is payable �o'nY demand and all disclosures are based on an assumed matunty of one year Security I am giving a secunty interest in CZ] (brief doscnption of other propeny) #1 317 THIRD 1STREET, Summmerdale, PA 17093 `U the goods or property being purchased U cot aterat securing othet loans with you may also secure true loan t 7 Required Deposit The annual pamentage rate does rat take into account my requited I_I my deposit accounts and other ngtrrt'o to are payment of money from you deposit Prepayment It t pay off this note early I f 7 may t X 1 suit not have to papa minimum finance charge 7 It I pay oft this note early, l en not be steeled to a rotund of pan of the additional finance charge tin Late Charge I will be charged a late charge on any payment made more than 10 days ater it is due equal to 5 00 0 % of the unpaid amount, or s 5 00 , whichever is greater ��--ll L._) Assumption • Someone buying the property securing this obhgabsn cannot assume the mmalndet of the obligation on the anginal terms I can see my contract documents for any additional information about nonpayment default any required repayment balers the scheduled date, and prepayment refunds and penautes REDIT INSURANCE Credit fife insurance and credit disability msuraoce are not reared to obtain credit, and writ not be provided uniasa I sign and agree to pay the ddittonai costs See Notice of Proposed Insurance on page 2 ITEMIZATION OF AMOUNT FINANCED AMOUNT GIVEN TO ME DIRECTLY $ 41, 000 00 AMOUNT PAID ON MY (LOAN) ACCOUNT $ ype Premium Term $ :tedd Life AMOUNTS PAID TO OTHERS ON MY BEHALF to Insurance Companies $ :resin Disabibty NM Credit Life to Public Officials $ lame of Insurer S do XX do not want credit Ide insurance I i d0 IXXI do not want credit disabdtty insurance I I do IXX) do not want Joint credit tile insurance do I I do not want Insurance $ $ - (teas) PREPAID FINANCE CHARGE(S) $ 0 00 Amount Financed $ 41,000 00 DOB 10/20/1935 (Add all gems franc ed and subtract prepaid finance charges ) DOB ROPERTY INSURANCE I may obtain properly insurance from anyone I want that is iceptatrta to you tt t get the insurance hem or through you I wet pay $ SIGNATURES - I AGREE E TERMS SET OUT ON PAGE 1 AND PAGE 2 OF THIS AGREEMENT I HAVE RE EIVED A COPY OF THIS DOCUM TON TODAY'S DATE COSIG 'S - SE: NOTICE ON PAGE 2 uE r,E SIGNING Signature .fir ,T r of coverage INGLE INTEREST INSURANCE - I may oblale singe. interest insurance from anyone I ant that is acceptable to you if I gat the insurance from or through you I writ pay for of coverage VIOLA R LIMRIC Or - Stenatura (Oeuona0 Signed For Lender Tiele IMPLE INTEREST NOTE DISCLOSURE, AND SECURITY AGREEMENT 91581. 198E1 Bankers Systems, Inc , It Cloud MN Form NDaS-5I PA 61699 A- C167(PA) (9812) VMP MORTGAGE FORMS 000)521 7291 APPLICATION NO 9910280674 CONSUMER LOAN • NOT FOR OPEN ENO CREDIT (page I 012) ADDITIONAL TERMS OF THE NOTE DEFINITIONS -'1, 'me' or my moans each Borrower who signs this note and each other person or legal entity (Including guarantors, endorsers end sureties) who agrees to pay this note (together referred to as us') 'You' or 'your moans the Lender and its successors and assigns APPLICABLE LAW This note and any agreement securing this note will be governed by the laws of the state of Pennsylvania The federal Truth in Lending disclosures on page 1 are disclosures only and are not intended to be terms of this agreement The fact that any part of this note cannot be enforced will not ailed the rest of Ns note Any change to this note or any agreement secunng this note must be in wnting and signed by you and me PAYMENTS • Each payment I make on this loan will be applied first to any charges I owe other than pnnppal and interest than to Interest that is due and finally to principal that is due No late charge wit be assessed on any payment when the only delinquency is due to late fees assessed on earlier payments and the payment is othervase a full payment The actual amount of my final payment will depend on my payment record PREPAYMENT • I may prepay this loan m whole or In part at any time 11 I prepay in pad I must still make each laser payment in the ongmal amount as it becomes due until this note is paid in toll USURY • The interest rate and other charges on this loan will never exceed the highest rata or charge allowed by law for this loan ACCRUAL METHOD The amount of interest that I will pay on this loan will be calculated using the Interest rata and accrual method stated on p80e 1 For interest calculation the accrual method will detennne the number of days m a year It no accrual method is stated then you may use any reasonable accrual method for calculating interest POST- MATURITY INTEREST Interest will accrue on the principal balance remaining unpaid aher final maturity at the rate specified on page 1 For purposes of this section final maturity occurs • (a) Ir this loan is payable on demand, on the date you make demand for payment (b) II this loan is payable on demand with altercate payment date(s), on the data you make demand far payment or on the final altercate payment date whichever is earner (c) On the data of the last scheduled payment of principal or (d) On the date you accelerate the due date of this loan (demand immediate payment) ADVANCE PROCEDURE AND MEANS You mil advance the loan proceeds by way of check cash wire trensler credit to an account or any combination as you and I agree The advance(s) roll occur upon consummation of the loan and as You and I agree except that no advances) will occur until after three business days from the date of consummation it the loan is rescindable pursuant to Regulation Z (12 C F R 226) REAL ESTATE OR RESIDENCE SECURITY - If this loan is secured by real estate or a residence that is personal property the sentence of a default and your remedies for such a default will be detenrlined by applicable law, by the terms Of any separate instrument creating the secunty interest and to the extent not prohibited by law and not contrary to the teens r the separate security insirumenl, by this agreement DEFAULT Sabred to any limitations in the 'REAL ESTATE OR RESIDENCE SECURITY' paragraph above I mil be in default on Ors loan and any agreement socunng this loan if any one or more of the following occurs (a) I fail to make a payment in full when due (e) I Me, am declared incompetent or become insolvent (c) 1 tad to keep any promise I have made in connection with this loan (a) I fail to pay or keep any other promise on any other loan or agreement I have with you (a) I make any wnben statement or provide any financial infoneabon that is untrue or inaccumto at the time it is provided, (T) Any creditor of mine attempts to collect any debt I owe through mat proceedings, set off or sell help repossession (9) The Properly is damaged, destroyed or stolen, (Ti) I fan to provide any additional security that you may require 01 Any legal entity (such as a partnership or corporation) that has agreed to pay this note merges dissolves, reorganizes, ends its business or existence. ore partner or metonty stockholder dies or is doctored incompetent or 0) Anything else happens that causes you to believe that you will have difficulty collecting the amount I owe you II any of us ere in default on this note or any security agreement you may exercise your remedies against any Or all 01 us REMEDIES Subject to any limitation in the 'REAL ESTATE OR RESIDENCE SECURITY' paragraph above if I am in default on this loan or any agreement setting this loan you may (a) Make unpaid principal earned interest and all other agreed charges I owe you under this loan immediately due (b) Use the right of set off as explained below (c) Demand more security or new padres obligated to pay this lean (or bath) in return for net using any other remedy (d) Make a claim for any and all insurance benefits or refunds that may be available on my default, (a) Use any remedy you have under state or federal law and (I) Use any remedy given to you in any agreement socunng this loan By choosing any one or mere of these remedies you do not give up your right to use another remedy later By deciding not to use any remedy .should I be in default, you do not give up your right to considerthe event a default t n happens again COSTS OF COLLECTION AND ATTORNEYS' FEES - I agree to pay you all reasonable costs you incur to collect this debt or malize on any uecunty This includes unless prohibited by law, reasonable aeomeys lees This provision also shall apply if I file a petition or any other claim for reliel under any bankruptcy rile or law at the United States or d such pebhon or other claim for relief is bled against me by another SET -OFF I agree that you may set on any amount due and payable under this rote against any nght I have to receive money from you Right to receive money from you means (a) Any deposit account balance I have mth you (b) Any money owed to me on en item presented to you or in your possession for collection or exchange and (c) Any repurchase agreement or other nondeposit obligation 'Any amount due and payable under this note' means the total amount of which you are entitled to demand payment under the terns of this note at the time you sot oh This total includes any balance the Can date for winch you properly accelerate under this note If my right to receive money from you is also owned by someone who has not agreed to pay this note, your nght of set-off will apply to my interest in the obligation and to any other amounts I could withdraw on my sole request or endorsement Your right of not off does not apply to an account or other obligation where my nghts anse only in a representative capacity It also does not apply to any Individual Retirement Account or other tax deferred retirement account You mil net be liable for the dishonor of any check when the dishonor occurs because you set on this debt against any of my accounts I agree to hold you harmless from any such deans ansing as a result of your exercise of your right of set-off OTHER SECURITY Any present or future agreement secunng any other debt 1 owe you also will secure the payment of this loan Property secunng another debt will not senate this loan II such property is my ennnpal dwelling and you fail to provide any remind notice of nght o1 rescission Also properly sealing another debt will not secure this loan to the extent such property is in household goods OBLIGATONS INDEPENDENT I understand That my obligation to pay this loan is independent of the obligation of any other parson who has also agreed to pay it You may without notice release me or any of us give up any nom you may have against any of us, extent! new 'credit to any of us or renew or change this note one or re times and for any term, and 1 will still ha obligated to pay this loan You may without notice tail to perfect your secunly interest in, impair, or release any secunty and I ma still be obligated to pay this loan WAIVER I waive (to the extent permitted by law) demand presentment protest, notice of dishonor and notice of protest PRIVACY I agree that from time to time you may receive credit information about one from others including other lenders and credit rooming agencies I agree that you may furnish on a regular basis credit and expemence information regarding my loan to others seeking such Information To the extent {manned by law, I agree that you will not be bible for any claim ansing from the use of Information provided to you by • others or tar providing such intomlation to others FINANCIAL STATEMENTS I will give you any (trammel statements or infonnabon that you feel Is necessary All financial statements and mtonnation I give you will be collect and complete PURCHASE MONEY LOAN If this is a Purchase Money Loan you may include the name of the sailer on the check or draft for this loan NOTICE OF PROPOSED INSURANCE • II no indicated on the front or this note, credit life insurance coverage and/or credit accident and health insurance coverage Will apply to this note The insurance company named on the front of this note mil ante the insurance The Insurance covers only the person(s) signing ma request for insurance The charge Q 1901 1988 Bankers Systems Inc St Cloud MN Form NOaS SI PA 8/8/98 11 -C167(PA) (9812) APPLICATION NO 9910280674 ACCOUNT NO 0000000491363665 for each type of credit insurance to be purchased is as Indicated on the front of this note The term al thsumnce will begin as of the date of this note and van end on the tinging due data of this note Subject to acceptance by the Insurance company end mlhin 30 days a certificate of Insurance yell be given to the insured It this note is prepaid before it is due a refund of insurance charges mil be made when due ADDITIONAL TERMS OF THE SECURITY AGREEMENT SECURED OBLIGATIONS This security agreement secures this loan (incrudmg all exterlsroflu renewals refinenoings and moddicatlons) and any other debt I have with you now or later Property descnbed in this security agreement yell not secure other such debts d you fail to give any required notice of the right o1 rescission with respect to the Property Also this seeunty agreement viii not secure other debts if this security interest is in household goods and the other debt to a consumer loon -taus secunty agreement will last until d is discharged in writing For the sots purpose or detemmntnp the extent of a Purchase Money Secunly mtarest ansing under this security agreement (a) Payments on any nonpurchase money loan also secured by this agreement will not be deemed to apply to the Purchase Money Loan, and (h) Payments on the Purchase Money Loan will be deemed to apply first to the nonpumhase money portion of the loan it any, and then to the Purchase Money obhgaoons in the order in which the items were acquired No security interest will be terminated by application of this formula 'Purchase Money Loan means any loan the proceeds of which, in whole or in pad, are used to acquire any property securing the loan and all extensions renewals consolidations and rebnancmgs of such loan PROPERTY - The word 'Properly ' as used here isolates an property that is listed in the secunhy agreement on page 1 It a general descnptlnn Is used the word Property includes all my property hnmg the general descnpbon Property also means all benefits that ease from the descnbed Property (including all proceeds, insurance benefits, payments nom others interest, dividends stock splits and voting rights) It also means property that now or later is attached to is a pan of or results from the Property OWNERSHIP AND DUTIES TOWARD PROPERTY • Unless a ce owners) of the Pmpeny signed a third Party agreement. I represent that I own all the Property I roll defend the Properly against any other claim I agree to do whatever you require to perfect your intorect and keep your priority 1 wall not do anything to harm your position 1 mil keep the Property In my possession (except d pledged and delivered to you) I yell keep It In good repair and use It oNy for Os intended purposes I will keep It at my address unless we agree otherwise in writing I will not try to sell or transfer the Property or permit the Properly to become attached to any real estate, vathout your wnten consent I will pay all taxes and charges on the Property as they become due I will inferno you of any loss or damage to the Properly You have the right of reasonable access in order to Inspect the Property INSURANCE I agree to buy morocco on the Property against the asks and for the amounts you require I will name you as loss payee on any such policy You may require added security on this loan II you agree that Insurance proceeds may be used to repair or replace the Property I agree that d the insurance proceeds do not cover the amounts I still owe you, I wilt pay the difference I will buy the insurance from a lain authonzed to do busrnness in Pennsylvania The term roll oo reasonably acceptable to you I mg keep the insurance until all debts secured by this agreement are paid DEFAULT AND REMEDIES It I am in default In addition to the remedies listed in the note potion of this document and subject to any of the Ilnatehons in the 'REAL ESTATE OR RESIDENCE SECURITY' paragraph, you may (after giving notice and waiting a penod of time, it required by law) (a) Pay taxes or other charges of purchase any required insurance, d f fan to do these things (bul you are not required to do so) You may add the amount you pay to this loan and accrue Interest on that amount et the interest rate disclosed on page 1 until pad in lull, (b) Require me to gather the Property and any related records and make It available to you in a reasonable fashion (c) Take Immediate possession of the Property but in doing so you may not breach the peace or unlawfully enter onto my premises You may sell lease or dispose of the Property as provided by law (11 the Property Includes a manufactured home, you will begin the repossession by giving me notice and an opportunity to cure my default, if required by law) You may ripely what you receive from the sale of the Property to your expenses and then to the debt It what you receive from the sale of the Property is less than what I owe you, you may take me to court to recover the ddfemnce (to the extent pertained by law), and (d) Keep the Property to sassy the debt I spree that when you must give notice to me at your intended sale or disposition or the Property, the notice as reasonable d d is sent to me at my last known address by first class mad 10 days before the intended sale or disposition I agree to inform you In meting of any change in my address RUNG - A copy of this secunty agreement may be used as a financing statement when allowed by law THIRD PARTY AGREEMENT For the purposes a1 the provisions within this enclosure I me' or 'my' means the person signing below and you means the Lender Identified on page 1 I agree to give you a secunty Interest in the Property thol is download on page 1 I agree to the leans of this note and security agreement but I am in no way personally liable for payment of the debt This means that d the Borrower defaults, my interest in the secured Property may be used tO satisfy the Borrower's debt I agree that' you may, without releasing me or the Property from this Third Party Agreement and without notice or demand upon me extend new credit to any Borrower, renew or change this note or security agreement one or more times and for any tear, or fail to perfect your security interest ma impair, or release any security (mche:hag guaranties) Ior the obagations of any Bonower I HAVE RECEIVED A COMPLETED COPY OF THIS NOTE AND SECURITY AGREEMENT NAME X NOTICE TO COSIGNER You (the cosigner) are being asked to guaranty this debt Think carefully before you do It the borrower doesn't pay the debt, you will have to On sure you can afford to pay If have lo, and that you want to accept this responsibility You may have to pay up to the full amount of the debt B the borrower does not pay You also may have to pay late fees or collection costs, which increase this amount The creditor con collect this debt from you without first trying to collect from the borrower The creditor can use the satire collection methods against you that can be used against the borrower, such as suing you, etc If this debt Is ever hi default, that fact may become pan of your credit record This notice la not the contract that makes you liable for the debt Attach FTC 'Preservation of Consumer Claims and Defenses' Notice it Applicable (page 2 of 2) EXHIBIT "B" ROBERT P ZIEGL'ER RECORDERS Or DEEDS CUMBERLAND) COUN f - PA '99 DEC 2 RA 10 27 Commonwealth of Pennsylvania Space Above This Line For Recording Data MORTGAGE I. DATE AND PARTIES. The date of this Mortgage (Security Instrument) is November 17, 1999 and the parties, their addresses and tax identification numbers, if required, are as follows MORTGAGOR VIOLA R LIMRIC 317 THIRD STREET Summerdale, PA 17093 If checked, refer to the attached Addendum incorporated herein, for additional Mortgagors, their signatures and 'acknowledgments LENDER r Fulton Bank �-' 1695 State Street "East Petersburg, PA 17520 . I 'I CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which is acknowledged, and to secure '- the Secured Debt (defined below) and Mortgagor's performance under this Security Instrument, Mortgagor grants, bargains, conveys and mortgages to Lender the following described property Tax Key /Parcel No 09 -12- 2994 -045 gatied 03/11/19$8 nd recorded 04/23/1998 in recorder of deeds record book o ume pagge The property is located in Cumberland (County) at 317 THIRD STREET EAST PENNSBORO TOWNSHIP Summerdale , Pennsylvania 17093 (Address) (City) (ZIP Code) Together with all rights, easements, appurtenances, royalties, mineral rights, oil and gas rights, all water and riparian rights, ditches, and water stock and all existing and future improvements, structures, fixtures, and replacements that may now, or'at any tune in the future, be part of the real estate described above (all referred to as "Property") 3. MAXIMUM OBLIGATION LIMIT. The total principal amount secured by ttus Security Instrument at any one time shall not exceed $ 41, 000 00 This limitation of amount does not include interest and other fees and charges validly made pursuant to this Security Instrument 4. SECURED DEBT. The term "Secured Debt" is defined as follows A Debt incurred under the terms of all promissory note(s), contract(s), guaranty(s) or other evidence of debt described below and all their extensions, renewals, modifications or substitutions (When referencing the debts below it is suggested that you Include items such as borrowers' names, note amounts, interest rates, maturity dates, etc ) Note dated 11/17/1999 In the amount of 41,000 00 between mortgagor(s) and lender B All obligations Mortgagor owes to Lender, which may later arise, to the extent not prohibited by law, inducting, b.it not limited to, liabilities for overdrafts relating to any deposit account agreement between Mortgagor and Lender C All additional scans advanced and expenses incurred by Lender tor insuring, preserving or otherwise protecting the Property and its value and any other sums advanced and expenses incurred by Lender under the terms of this Security Instrument This Security Instrument will not secure any other debt if Lender fails to give any required notice of the right of rescission S. PAYMENTS. Mortgagor agrees that all payments under the Secured Debt will be paid when due and in accordance with the terms of the Secured Debt and this Security Instrument 6 WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be lawfully seized of the estate conveyed by this Security Instrument and has the right to grant, bargain, convey, sell, and mortgage the Property Mortgagor also warrants that the Property is unencumbered, except for encumbrances of record , 7. CLAIMS AGAINST TITLE. Mortgagor will pay all taxes, assessments, liens, encumbrances, lease payments, ground rents, utilities, and other charges relating to the Property when due, and provide to Lender copies 'of all're:eipts un,,demand Mortgagor agrees to make all payments when due and comply with all covenants of any prior security Interest on the P.up;erty 8. DUE ON SALE OR ENCUMBRANCE. Lender may, at its option, declare the entire balance, oft the Sedired,Debt to be immediately due and payable upon the creation of, or contract for the creation of, any lien, encumbrance transfer or :_ale of the Property This right is subject to the restrictions imposed by federal law (12 C F R 591), as applicable r 9. PROPERTY CONDITION. Mortgagor will keep the Property in good condition and make all repairs that 'are reasonably. necessary % PENNSYLVANIA - SHORT FORM MORTGAGE - CLOSED END (NOT FOR FNMA, FHLMC, FHA OR VA USE) '-! } ' (P '. " . 7 of 2),--1,..* 01995 Rankers Systems Inc , SI Cloud, MN (1 800 397 2341) Form SFMC MTG PA 3/15/95 ' 1' :` A.rl l% i, ' �� c) •C392(PA) (9812) VMP MORTGAGE FORMS - (800 21 7291 ' • ',;' APPLICATION NO: 9910280674 BQU�1585PACE, 26B LOAN NO. 0491363665 10. AUTHORITY TO PERFORM. If Mortgagor fails to perform any duty or any of the covenants contamedr,in this ESecurity Instrument, Lender may, without notice, perform or cause them to be performed 11. ASSIGNMENT OF LEASES AND RENTS. Mortgagor irrevocably grants, bargains, conveys and mortgages to Lender as T, additional security all the right, title and interest in and to any and all existing or future leases, subleases, and any other written or verbal', agreements for the use and occupancy of any portion of the Property, including any extensions, renewals, modifications or substitutions of such agreements and rents, issues and profits Mortgagor may collect, receive, enjoy and use the Rents so long as Mortgagor is not in default under the terms of this Security Instrument 12 DEFAULT AND REMEDIES. Mortgagor will be in default if any party obligated on the Secured Debt fails to make payment when due Mortgagor will be in default if a breach occurs under the terms of this Security Instrument or any other document executed for the purpose of creating, securing or guarantying the Secured Debt A good faith belief by Lender that Lender at any time is insecure with respect to any person or entity obligated on the Secured Debt or that the prospect of any payment or the value of the Property is impaired shall also constitute an event of default Lender may accelerate the Secured Debt subject to any notice requirements of Lender to provide notice to Mortgagor as required by law Lender shall be entitled to all the remedies provided by law, the terms of the Secured Debt, this Security Instrument and any related documents All remedies are distinct, cumulative and not exclusive, and the Lender is entitled to all remedies provided at law or equity, whether or not expressly set forth 13. EXPENSES; ADVANCES ON COVENANTS. Except when prohibited by law, Mortgagor agrees to pay all of Lender's expenses if Mortgagor breaches any covenant in this Security Instrument Mortgagor will also pay on demand any amount incurred by Lender for insuring, inspecting, preserving or otherwise protecting the Property and Lender's security interest These expenses will bear interest from the date of the payment until paid in full at the highest interest rate in effect as provided in the terms of the Secured Debt Mortgagor agrees to pay all costs and expenses incurred by Lender in collecting, enforcing or protecting Lender's rights and remedies under this Security Instrument This Security Instrument shall remain in effect until released 14. INSURANCE. Mortgagor shall keep Property insured against loss by fire, flood, theft and other hazards and risks reasonably associated with the Property due to its type and location This insurance shall be maintained m the amounts and for the periods that Lender requires and shall include a standard mortgage clause in favor of Lender The insurance carrier providing the insurance shall be chosen by Mortgagor subject to Lender's approval, which shall not be unreasonably withheld 15. SEVERABILITY, INTERPRETATION. If any section of this Security Instrument cannot be enforced according to its terms, that section will be severed and will not affect the enforceability of the remainder of this Security Instrument Whenever used, the singular shall include the plural and the plural the singular 16. JOINT AND INDIVIDUAL LIABILITY; CO- SIGNERS; SUCCESSORS AND ASSIGNS BOUND. All duties under this Security Instrument are joint and individual If Mortgagor signs this Security Instrument but does not sign an evidence of debt, Mortgagor does so only to mortgage Mortgagor's interest in the Property to secure payment of the Secured Debt and Mortgagor does not agree to be personally liable on the Secured Debt If this Security Instrument secures a guaranty between Lender and Mortgagor, Mortgagor agrees to waive any rights that may prevent Lender from bringing any action or claim against Mortgagor or any party indebted under the obligation Mortgagor agrees that Lender and any party to this Security Instrument may extend, modify or make any change in the terms of this Security Instrument or any evidence of debt without Mortgagor's consent The duties and benefits of this Security Instrument shall bind and benefit the successors and assigns of Mortgagor and Lender 17. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any right to appraisement relating to the Property NOTICE TO BORROWER: THIS DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE INTEREST RATE. SIGNATURES: By signing below, Mortgagor, intending to be legally bound hereby, agrees to the terms and covenants contained in this Secur . trument and to an j. ttachments Mortgagor also acknowledges receipt of a copy of this Security Instrument on the date ge 1 ' (Signature) VIOLA R LIMRI (Witness) ACKNOWLEDGMENT: COMMONWEALTH OF On this, the (individual) (Signature) (Date (Witness Pennsylvania ,CO► TY OF ancaster 17th day of November, 1999 , before me officer, personally appeared VIOLA R LIMRIC known to me (or satisfactorily proven) to be the person(s) whose name(s) is subscribed to the within instrument, and acknowledged that he /she executed the same for the purposes therein contained a Notary } ss , the undersigned In witness w My cgmniivibti cipres {��.. {Et 21) ;'t 4j '- yip` =fC) r 1 $,r1:a t'J6- ^s • � • • Notarial Seal Corey D Craver, Notary Public East Petersburg Boro, Lancaster County t My Commission Expires Nov 3, 2003 f'iEs!<lla tie address of the Lender within named is rti 11 � ' + 8 kit vtgos ?iplw_ _ktdoud MN (1 500 397 2341) Form SFMC MTG -PA 3/15/95 a U +lit iii�t�k'r�� 'al seal Boas 1585 PAGE. 269 t c.� Title of Officer Fulton Bank One Penn Square Lancaster, PA 17604 Application No. Loan No. (page 2 of 2) 9910280674 0491363665 State of Pennsylvania County of Cumberland 86 Paco,ded in the office for the recording of Deeds and erland County, Bo �� �! Vol= Pag salofoffi day T «C" VIOLA R LIMRIC 317 3RD ST SUMMERDALE, PA 17093 Page 1 of 7 532.LN- 0491363665 December 16, 2013 ACT 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 MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1 (800) 342 -2397 (Persons with impaired hearing can call (717) 780- 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO (1 -800- 342- 2397). 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. Page 3 of 7 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Viola R Limric 317 3rd St Summerdale, PA 17093 LN- 0491363665 Fulton Bank, NA Fulton Bank, NA 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 fmancial 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 PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS FO THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETINGS THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Page 4 of 7 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 INFORMATIONAL 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: 317 3rd St, Summerdale, PA 17093 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS FROM 09/05/13 THROUGH 12/05/13 and are currently past due for the following amounts: Total Payment Amount: $1,594.88 Late Charges: $199.33 Other Fees: 0.00\ TOTAL AMOUNT PAST DUE: $1,794.21 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 $1,794.21, 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: ATTN: Jeffrey Sigle Fulton Bank, NA PO Box 4887 Lancaster, PA 17604 -4887 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. Page 5 of 7 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 6 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: Address: Phone Number: Fax Number: Contact Person: Fulton Bank, NA PO Box 4887 Lancaster, PA 17604 -4887 (800) 521 -8617 x18579 (717) 391-2908 Jeffrey Sigle Senior Loan Adjustor EFFECT OF SHERIFF'S SALE — You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and you 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 — If permitted by your mortgage documents, you may be able to 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. Sincerely, Jeffrey Sigle Authorized Representative Fulton Bank, NA Certified and Regular Mail Consumer Credit Counseling Agencies CUMBERLAND COUNTY Pathstone Corporation PA 1625 North Second Street Harrisburg, PA 17102 717.234.6616 CCCS of Western PA 55 Clover Hill Road Dallastown, PA 17313 888.511.2227 Page 6 of 7 Community Action Commission Capital Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Harrisburg Fair Housing Council 2100 N. 6t. Street Harrisburg, PA 17110 717.238.9540 Housing & Redevelopment Authority — Cumberland Cnty 114 N. Hanover Street; Ste. 104 Carlisle, PA 17013 886.683.5907 / 717.249.0789 The Pennsylvania housing Finance Agency can be reached TOLL FREE at 1 -800- 342 -2397 Page 7 of 7 ci Complete item 4 if your r name so that we can retur a Attach this card to the b or on the front if space per 1. Article Addressed to 1, 2, and 3. Also complete ed Delivery is desired. address on the reverse e card to you. of the mailpiece- VIOLA R.0 317 3RD ST P SUMMERDALE c le Number Pansferfrom.svnece Ibe9 PS Form 3811,july 2613 93 L XCOMPLETETHISSECTION ON 'DELIVERY •-• • • r. A. Signature X • gent 0 Addressee C. Date of Delivery n item 17 0 Yes eds below:. 0 No Type Certified Mal 0 Registered CI Insured Mall 3. Priority Mail Express'" Receipt for Merchandise Delivery 0 Coll 4. Restricted Delivery? (atm Fee) 7013 2250 0002 3860 8771 Domestic Retum Receipt Fulton Bank LISTENING IS JUST THE lilEGINNING.0 P.O. BOX 4887 LANCASTER, PENNSYLVANIA 17/ 7013 2250 0002 3860 8771 -=.„t•Otr-,7-1',fp.T . 1-7604 6. 70 2250 0002 3860 8771 RETURN TO NO SUCH N UNABLE. TO BC: 1760,4488787 02.24-013 (10/10) ° U N To) SENDER UMBER F OR WARD *V973 00323— la H.1.31.1.11dmjin1 lidNpvi BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 •I iR 17 AM e, 54 LBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - MORTGAGE FORECLOSURE No. /1j/- 1x/9k NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Date Respectfully�it -d: Shawn M. Lon : Esquire Troy B. Rid- , squire Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMERIPR1MARY APPLICATION Borrower name (s): Property Address: City: Is the property for sale? Yes [ ND [ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes Pb Mailing Address (if different) City: Phone Numbers: Erna # of people in household: Home: State: State: Office: Other: Zp: How long? CO BORROWER Mailing Address: City: Phone Numbers: Home: Cell: Emal: # of people in household: State: Office: Other: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Date You Closed Your Loan: Included Taxes and Insurance: Is the loan in Bankruptcy? Yes ND If yes, provide names, location of court, case number & attorney: Assets Other Rea Estate: Retirement Funds: Investments: Checking: Automobile #1: Model: Amount owed: Automobile #2: Model: Amount Owed: Value: Year: Value: Amount owed: Value: Other transDortation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1 Monthly Gross Monthly Net 2 Monthly Gross Monthly Net 3 Monthly Gross Monthly Net Additional Income Description (not wages): 1 Monthly Amount: 2 Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paving) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other Prop. Payment Install. Loan Payment Cable TV Chi|d5upport/A/im. Spending Money Day/Child Care/ Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes [— Mb [— If yes please provide the following information: Counseling Agency: Counselor: Phone (Office): Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yesl No If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Phone: AUTHORIZATION VVVe, authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /we understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Borrower Signature Date Date Please forward this document along with the following information to lender and lender ✓ Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days ✓ Copy of a current utility bill ✓ Letter explaining reason for delinquency and any supporting documentation ✓ (hardship letter) Listing agreement (if property is currently on the V market) Copy of 2 years of federal income tax returns V Copy of deed BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: action; 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court - supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION — MORTGAGE FORECLOSURE No. CASE MANAGEMENT ORDER AND NOW, this day of , 2014, the defendant /borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court - supervised conciliation Conference on at . M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant /borrower must serve upon the Plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. S. All proceedings |nthisrnatterareotayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 0(1J HMR 27 Prf I: 30 UMBERLA1`,IV Syr PENNSYLVANIA U Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14 -1496 FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT UNDER PA. R.C.P. 430 AND NOW, comes the Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank, by and through its undersigned counsel, and moves, pursuant to Pa. R.C.P. 430(a) and (b), for a special order directing service of process upon the Defendants, Unknown Heirs, Successors, Assigns, and all Persons, Firms or Associations Claiming Right, Title or Interest from or under Viola R. Limric, Deceased, by publication, as well as service of any default notices and Notices of Sheriff's Sale upon such Defendants, and avers as follows: 4223373_1.DOCX 1. On March 17, 2014, the Plaintiff filed its Complaint against the Defendant. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and incorporated herein by reference. 2. As stated in the Complaint, on or about November 17, 1999, Viola R. Limric, executed and delivered to Fulton a Promissory Note ( "Note ") and Mortgage ( "Mortgage ") upon the premises at 317 Third Street, Summerdale, Cumberland County, Pennsylvania (the "Premises "). 3. The Note and Mortgage are in default as monthly payments which were due beginning September 5, 2013 and every month thereafter have not been made. 4. Viola R. Lirnric died on October 25, 2010 and, upon information and belief, all of her heirs, successors, assigns, or other representatives are not known, and no estate has been opened on behalf of Viola R. Limric. 5. Under Pa. R.C.P. 430(b)(2), "[w]hen service is made by publication upon the heirs and assigns of a named former owner or party interest, the court may permit publication against the heirs or assigns generally if it is set forth in the complaint or an affidavit that they are unknown." 6. As some or all of the unknown Defendants may have an interest in the Premises, Plaintiff must serve the Defendants, Unknown Heirs, Successors, Assigns, and all Persons, Firms or Associations Claiming Right, Title or Interest from or under Viola R. Limric, Deceased, by publication. 7. The Plaintiff will suffer irreparable harm and injury if the Plaintiff is not allowed to effect alternate service of process upon the Defendants, Unknown Heirs, Successors, Assigns, 4223373_I .DOCX 2 and all Persons, Firms or Associations Claiming Right, Title or Interest from or under Viola R. Limric, Deceased, and serve any default notices and Notices of Sheriffs Sale under Pa. R.C.P. 430 in order to proceed with the enforcement of Plaintiff's rights under Note and Mortgage. WHEREFORE, the Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank, requests that this Honorable Court enter an Order authorizing service of process of the Complaint in the within matter upon the Defendants, Unknown Heirs, Successors, Assigns, and all Persons, Firms or Associations Claiming Right, Title or Interest from or under Viola R. Limric, Deceased, by publication pursuant to Pa. R.C.P. 430(b)(1) and (2), as well as service of any default notices and Notice of Sheriffs Sale by publication pursuant to Pa. R.C.P. 430(b)(1) and (2). BARLEY SNYDER Date: 4223373_1.DOCX By: awn M. Lon, Esquire Attorneys for laintiff Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 ER! PENN } � COUNTY YLVANIPA Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14 -1496 ORDER AND NOW, to wit, this it day of .413 .,'/ , 2014, upon consideration of Fulton Bank, N.A., formerly known as Fulton Bank's Motion for Service Pursuant to Special Order of Court Under Pa. R.C.P. 430, upon the Defendant, Unknown Heirs, Successors, Assigns, and all Persons, Firms or Associations Claiming Right, Title or Interest from or under Viola R. Limric, it is ORDERED that service of the Plaintiff's Complaint in the within matter by publication pursuant to Pa. R.C.P.430(b)(1) and (2) is hereby authorized, and the Plaintiff upon effecting 4223373_1.DOCX service in accordance with said Rule, shall file a certificate of service with the Office of the Prothonotary of Cumberland County, Pennsylvania; and IT IS FURTHER ORDERED that, the service of any default notices and any Notices of Sheriffs Sale in the within matter by publication pursuant to Pa. R.C.P. 430(b)(l) and (2) is hereby authorized. BY THE COURT: 4223373_1 .DOCX 2 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, NA., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14-1496 PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the Complaint originally filed on March 17, 2014 in the above-captioned action. Dated: 4280344-1 BARLEY SNYDER d /5) .00 By: hawn M. Long, Esquire Keith Mooney, Esquire Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank 126 E. King Street Lancaster, PA 17602 717.299.5201 0.15 P e 53 P--30 4 55 f AVY BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 I Iii L I INiJFI�'i:a. 2)0111S - t l H It: 17 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14-1496 VERIFICATION Colleen Brelje, hereby verifies that on May 2, 2014 service of the Complaint was served by publication upon the Defendant, unknown heirs, successors, assigns and all persons, firms or associations claiming right, title or interest from or under Viola R. Limric, deceased, in accordance with Order of Court dated April 1, 2014 in The Sentinel and the Cumberland Law Journal. Proofs of publication are attached hereto and marked Exhibit "A". BARLEY SNYDER Dated: May 21, 2014 By: 4322975-1 Colleen K. Brelje, Paralegal 50 N. Fifth Street P.O. Box 942 Reading, PA 19603 610.376.6651 • .. r PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Patrick Doane, Production Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): May 2, 2014. COPY OF NOTICE OF PUBLICATION o p ace your ad. AUCTION at6pm. csburg, PA 17055 ! SF, 3 BR, 2.5 BA Level'w/ 2 Car Gar on 3 -sac. .34 Acres on f sloped lot w/ fenced Mechanicsburg Area of District. AS: $10K down. Settle days. See web or call. Call 717-731-8662 Nancy Payton photos & more details RLAND COUNTY, PENNSYLVANIA FORECLOSURE OWN AS FULTON BANK ISONS,.FIRMS, OR ASSOCIATIONS CLAIMING ER VIOLA R. LIMRIC, DECEASED ti FORECLOSURE or Associations Claiming Right, Title or Interest from lank, N.A., formerly known as Fulton Bank filed a (Court of Common Pleas of Cumberland County, to enforce its rights under its loan documents. dated April 1, 2014, ordered notice of said facts and .R C:P:430(b). nt pti or before 20 DAYS from the date of this UCTION anal Property 1:00 AM le, PA. 17013 I home Hair Salon business: LR w/ fireplace, Hair Salon Dors, Natural Gas forced ail' 1. Recent installations and •. siding, gas furnace, gas d side porch. Over 2000 sq' rood. Great•starter home or In. • r a written appearance personally or by attorney, and ire warned that if you fail to do so, the case may without further notice for the relief requested by the tant to you. • CE. IF!YOU DO NOT HAVE A LAWYER GO TO CE CAN PROVIDE YOU WITH INFORMATION OR MAY BEABLE TO PROVIDE YOU WITH L SERVICES TO ELIGIBLE PERSONS AT A Association Street 13 9-3166 • I • Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this aN et, inau8 ao i 4 1It i t,lA, R) . r'tYC Notarublic My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Bethany M. Holtry, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action—Mortgage Foreclosure 14-1496 FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendants NOTICE To: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Viola R. Limric You are hereby notified that on March 17, 2014, Plaintiff, Fulton Bank, N.A., formerly known as Ful- ton Bank filed a Complaint endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 14-1496, wherein Plaintiff seeks to enforce its rights under its loan documents. Since your current whereabouts are unknown, the Court by Order dated April 1, 2014, ordered notice of said facts and the filing of the Complaint to be served upon you as provided by R.C.P. 430(b). You are hereby notified to plead to the above referenced Complaint on or before 20 DAYS from the date of this publication or Judgment will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and a Judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE 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 INFORMA- TION 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 RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 SHAWN M. LONG, ESQUIRE BARLEY SNYDER LLC 126 East King Street Lancaster, PA 17602 (717) 299-5201 May 2 25PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r ?� , V\-- -- a Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 2 day of May, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 OFt.„ i � PRO 'SONU7;F 2014 JUL 14 P1 CUMBERLAND COUNT)/NIA '�r1' Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14-1496 VERIFICATION Colleen Brelje, hereby verifies that on June 27, 2014 service of the 10 -day default notice was served by publication upon the Defendant, unknown heirs, successors, assigns and all persons, firms or associations claiming right, title or interest from or under Viola R. Limric, deceased, in accordance with Order of Court dated April 1, 2014 in The Sentinel and the Cumberland Law Journal. Proofs of publication are attached hereto and marked Exhibit "A". BARLEY SNYDER Dated: July 7, 2014 4372824-1 Colleen K. Brelje, Paralegal 50 N. Fifth Street P.O. Box 942 Reading, PA 19603 610.376.6651 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Patrick Doane, Production Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached. hereto is exactly the same as was printed and published in the regular editions and issues of June 27, 2014. COPY OF NOTICE OF PUBLICATION NOTICE F COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -MORTGAGE FORECLOSURE N BANK, N.A., FORMERLY KNOWN AS FULTON BANK • Plaintiff vs. SORS, ASSIGNS; AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED Defendant - , • - CIVIL ACTION - MORTGAGE FORECLOSURE 14-1496 Assigns, and all Persons, Firms or Associations Claiming Right, Title or Interest from IMPORTANTNOTICe' SE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE ST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR ORTANT RIGHTS. . ER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR SET FORTH BELOW..THIS OFFICE CAN PROVIDE YOU WITH INFORMATION HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH NCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717-249-3166 Shawn M. Long, Esquire I.D. No. 83774 Barley Snyder LLP 126 East King Street Lancaster, PA 17602-2893. 717-299-5201 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this obttikal / "'!!l Notary P lic My commission expires: COMMONWEALTH OF PENNSYLVrANIA Notarial Seal Bethany M. Noltry, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz June 27, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyn Editor SWORN TO AND SUBSCRIBED before me this 27 day of June, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action—Mortgage Foreclosure 14-1496 FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK Plaintiff vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED Defendant IMPORTANT NOTICE To: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Viola R. Limric YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSON- ALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IM- PORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 10 INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 SHAWN M. LONG, ESQUIRE I.D. No. 83774 BARLEY SNYDER LLP 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 June 27 t J T HONG TA l';'( 2014 AUG 20 AH 11:4 CUI-IBERC r UNTY BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Attorneys for Plaintiff Lancaster, PA 17602 Fulton Bank, N.A., formerly known as Fulton 717.299.5201 Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14-1496 PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank against Defendant, Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title, or interest from or under Viola R. Limric, deceased for want of an answer: Assess damages as follows: Principal Balance $6,779.95 Interest through 02/12/14 at a rate of $1.53 per diem 168.37 Late Charges 219.27 Attorneys' Fees 3,000.00 Total 4375254-1 $10,167.59 0,4 SSS to Lt- w6A\-ea plus continuing interest after February 12, 2014 at a rate of $1.53 per diem, plus continuing late charges and costs. • I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ❑ Pursuant to Pa. R.C.P. §237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. • Pursuant to Pa. R.C.P. §237.5, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: kt 4375254-1 BARLEY SNY B Shawn M. Long, Esq re Court I.D. No. 83774 Attorneys for Plainti of Fulton Bank, N.A., formerly known as Fulton Bank 126 E. King Street Lancaster, PA 17602 717.299.5201 NOW, atIO • 91) , JUDGMENT IS ENTE Prothonotary/CI`trlc,' i1 By: , Deputy NOTICE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -MORTGAGE FORECLOSURE FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK Plaintiff vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED Defendant CIVIL ACTION - MORTGAGE FORECLOSURE 14-1496 To: Unknown Heirs, Successors, Assigns, and all Persons, Firms or Associations Claiming Right, Title or Interest from or under Viola R. Limric IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 Shawn M. Long, Esquire I.D. No. 83774 Barley Snyder LLP 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 4346910-1 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 • FP,ED-OFF ..... OF THE: PRO THONO mil JUL 14 PM 09 CUMBERLAND �a COUNTY' y►_...f u L r1-2C.a Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14-1496 VERIFICATION Colleen Brelje, hereby verifies that on June 27, 2014 service of the 10 -day default notice was served by publication upon the Defendant, unknown heirs, successors, assigns and all persons, firms or associations claiming right, title or interest from or under Viola R. Limric, deceased, in accordance with Order of Court dated April 1, 2014 in The Sentinel and the Cumberland Law Journal. Proofs of publication are attached hereto and marked Exhibit "A". BARLEY SNYDER Dated: July 7, 2014 By: 4372824-1 Colleen K. Brelje, Paralegal 50 N. Fifth Street P.O. Box 942 Reading, PA 19603 610.376.6651 BARLEY SNYDER Shawn M. Long, Esquire Court I.D. No. 83774 126 E. King Street Attorneys for Plaintiff Lancaster, PA 17602 Fulton Bank, N.A., formerly known as Fulton 717.299.5201 Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER VIOLA R. LIMRIC, DECEASED, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — MORTGAGE FORECLOSURE No. 14-1496 AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned, Shawn M. Long, Esquire, doth depose and say that Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title, or interest from or under Viola R. Limric, deceased, Defendant is not in the Military or Naval Service, based on the following facts: Defendant, Viola R. Limric, deceased, as of the date of this affidavit. ADDITIONAL FACTS, if any, affidavit based upon representations of Plaintiff. The statements set forth in this Affidavit are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. BARLEY SNYDER Dated: -7 ( 9 1 By: Sh�aw'M. Long, Esquire Court I.D. No. 83774 Attorneys for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank 126 E. King Street Lancaster, PA 17602 717.299.5201 4375254-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY CARLISLE, PA TO: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title, or interest from or under Viola R. Limric, deceased Defendant YOU ARE HEREBY NOTIFIED that Fulton Bank, N.A., formerly known as Fulton Bank has caused a judgment by default to be entered against you with the Prothonotary of Cumberland County. The judgment was entered on . v D/ 't o No. 14- 1496 with the Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount of $10,167.59, plus interest at the rate of $1.53 per diem from February 12, 2014, costs of this action. By: 4375267-1 PROTHONOTARY Deputy Cler"