HomeMy WebLinkAbout14-3054 Supreme Courof Pennsylvania
Cou�Ert*f Common Pleas
ls�ti�'•CQV.CI, 11�eet Por Prothonotary Use Only:
CUMB RLAW., County Docket No: l/
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supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S ®Complaint ❑Writ of Summons ❑Petition
E ❑Transfer from Another Jurisdiction ❑Declaration of Taking
C Lead Plaintiff's Name: Lead Defendant's Name:
T CITIFINANCIAL SERVICING,LLC Jeffrey L.Morrison a/k/a Jeffrey Morrison
I Are money damages requested? ❑Yes ®No Dollar Amount Requested:❑within arbitration limits
0 check one ❑outside arbitration limits
N Is this a Class Action Suit? ❑Yes ®No Is this an MDJAppeal? ❑Yes ®No
A Name of Plai.ntifflAppellant's Attorney: Robert W.Williams,Esquire
❑ Check here if you have no attorney(are a Self-Represented I Po Sel Litigant)
Nature Of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE.If you are making more than one type of claim,check the one that
you consider most important.
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mass tort) ❑ Employment Dispute:
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S
S ❑ Other: ❑ Employment Dispute:Other ❑ Zoning Board
C ElOther:
T MASS TORT ❑ Other:
I ❑ Asbestos
0 ❑ Tobacco
El Toxic Tort—DES
N
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B ElToxic Waste [IEjectment ElCommon Law/Statutory Arbitration
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PENNSYLVANIA BULLETIN,VOL.42,NO.13,MARCH 31,2012
MILSTEAD & ASSOCIATES, LLC
BY: Robert W. Williams, Esquires
ID No. 315501 " ? '6
1 E. Stow Road Lu%'C'R 1059
Marlton,NJ 08053 6yR'�s f'0CCu�''T
(856) 482-1400 Attorney for Plaintiff t;I,
File: 88.27118
CITIFINANCIAL SERVICING,LLC COURT OF COMMON PLEAS
1000 Technology Drive CUMBERLAND COUNTY_
O'Fallon,MO 63368,
Plaintiff,
Vs. No..
H �OSW 0tv/.
Jeffrey L. Morrison a/k/a Jeffrey Morrison CIVIL ACTION MORTGAGE
131 Echo Road FORECLOSURE
Carlisle,PA 17015,
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this
complaint and notice are served, by entering a written appearance personally or
by attorney and filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
1. This communication is from a debt collector. This is an attempt to collect a
debt and any information obtained will be used for that purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within
30 days after receipt of this notice, the debt will be assumed to be valid by our
offices.
3. If you notify our offices in writing within 30 days of receipt of this notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the Judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
MILSTEAD & ASSOCIATES, LLC
BY: Robert W. Williams, Esquire
ID No. 315501
1 E. Stow Road
Marlton, NJ 08053
(856)482-1400 Attorney for Plaintiff
CITIFINANCIAL SERVICING,LLC COURT OF COMMON PLEAS
1000 Technology Drive CUMBERLAND COUNTY
O'Fallon,MO 63368,
Plaintiff,
No.:
Vs.
CIVIL ACTION MORTGAGE
Jeffrey L. Morrison a/k/a Jeffrey Morrison FORECLOSURE
131 Echo Road
Carlisle,PA 17015,
Defendant
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, CITIFINANCIAL SERVICING, LLC (the"Plaintiff'), is registered to conduct
business in the Commonwealth of Pennsylvania and having an office and place of business
at 1000 Technology Drive, O'Fallon, MO 63368.
2. Defendant, Jeffrey L. Morrison a/k/a Jeffrey Morrison, (the "Defendant"), is an adult
individual and is the real owner of the premises hereinafter described by virtue of a Deed dated
September 21, 2007, recorded September 26, 2007 under Instrument 200737327. The Deed is
attached hereto as Exhibit"A" and made a part hereof.
3. Defendant Jeffrey L. Morrison a/k/a Jeffrey Morrison, upon information and belief,
resides at 131 Echo Road, Carlisle, PA 17015.
4. On May 26, 2010, in consideration of a loan in the principal amount of$27,896.13, a
Note(the"Note") was executed and delivered to CITIFINANCIAL SERVICES, INC. with
interest thereon at 11.8284 percent per annum, payable as to the principal and interest in equal
monthly installments of$331.06 commencing July 1, 2010. The current interest rate is 11.8200
percent per annum. The Note is attached hereto as Exhibit`B" and made a part hereof.
5. To secure the obligations under the Note, the Defendant executed and delivered to
CITIFINANCIAL SERVICES, INC. a mortgage (the "Mortgage") dated May 26, 2010, recorded
on May 28, 2010 in the Department of Records in and for the County of Cumberland under
Instrument 201013913. The Mortgage is attached hereto as Exhibit"C" and made a part hereof.
6. Plaintiff is proper party Plaintiff by way of an Assignment of Mortgage recorded
December 23, 2013 under Instrument 201340064. The recorded Assignment of Mortgage is
attached hereto as Exhibit"D" and made a part hereof.
7. The Mortgage secures the following real property (the"Mortgaged Premises"): 131 Echo
Road, Carlisle, PA 17015. A legal description of the Mortgaged Premises is attached hereto as
Exhibit"E" and made a part hereof.
8. The Defendant is in default of his/her obligations pursuant to the Note and Mortgage
because payments of principal and interest due July 10, 2012, and monthly thereafter are due and
have not been paid, whereby the whole balance of principal and all interest due thereon have
become due and payable forthwith together with late charges, escrow deficit (if any) and costs of
collection including title search fees and reasonable attorney's fees.
9. The following amounts are due on the Mortgage and Note:
Principal Balance .....................................$26,897.23
Accrued but Unpaid Interest from
7/10/12 to 3/28/14.......................................$5,477.63
Deferred Interest ............................................$531.60
TOTAL as of 03/28/2014..........................$32,906.46
Plus, the following amounts accrued after March 28, 2014:
Interest at the Rate of 11.8200 percent per annum ($8.83 per diem);
Late Charges per month if applicable.
10. Plaintiff has complied fully with Act No. 91 (35 P.S.'1680.401(c) of the 1983 Session of
the General Assembly("Act 91") of the Commonwealth of Pennsylvania, by mailing to
the Defendant at 131 Echo Road, Carlisle, PA 17015 on April 15, 2013, the notice pursuant to §
403-C of Act 91, and the applicable time periods therein have expired. The Act Notice
is attached hereto as Exhibit"F" and made a part hereof.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant for
foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 9,
namely, $32,906.46, plus the following amounts accruing after March 28, 2014, to the date of
judgment: (a) interest of$8.83 per day, (b) late charges per month if applicable, (c)plus interest
at the legal rate allowed on judgments after the date of judgment, (d) additional attorney's fees
(if any)hereafter incurred, (e) and costs of suit.
_� MILS D SSOCIATES, LLC
Date: �"� L IX/� �
Robert Williams, Esquire
Attorney for Plaintiff
VERIFICATION
Monica Colter, hereby states that she is employed as a Vice President-Document Control of
CitiMortage, Inc. Pursuant to an agreement, CITIMORTGAGE, INC., provides certain loan
servicing activities to CITIFINANCIAL SERVICING LLC, the Plaintiff in this matter. I am
authorized to execute this Verification on behalf of CITIMORTGAGE, INC., pursuant to the
corporate resolutions of CITIMORTGAGE, INC. The statements of fact contained in the
foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my
information and belief.
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
AFFIANT:
By:
Print:Monica Colter /
Date:
File#: 88.27118
Name: Jeffrey L. Morrison a/k/a Jeffrey Morrison
Exhibit A
ROBERT P. ZIEGLER
i
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013 - -
717-240-6370 (�
Instrument Number-200737327
i;
Recorded On 9/26/2007 At 2:26:25 PM *Total pages-5 !`
s
*instrument Type-DEED j
Invoice Number-5368 User ID-AF
r
*Grantor- MADDY,DARRELL W
*Grantee-MORRISON,JEFFREY L
*Customer-rRWIN
*
FEES
STATE TRANSFER TAX $I 010.00 Certification Page
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00 DO NOT DETACH
JUSTICE
RECORDING FEES - $11.50 This page is now part
RECORDER OF DEEDS
AFFORDABLE HOUSING $11.50 of this legal document.
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
CARLISLE AREA SCHOOL $505.00 i.
DISTRICT
NORTH MIDDLETON $505.00
TOWNSHIP
TOTAL PAID $2,058.50
I Certify this to be recorded
in Cumberland County PA
of cu e
ge
RECORDER O D DS
r�ao
°-Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
0005PM
[Illlllll�l�!l611i11� -
m14arnn1a i raa•nn A►A CUMBERLAND COUNTY Inst.#200737327-Page 5 o
THIS DEED �
TAX PARCEL NO. 29-05-0425-067 ,I
Made the}`�day of September,2007,
BETWEEN DARRELL W.MADDY and KAREN S.MADDY,husband and wife,
herein designated as the Grantors,
AND JEFFREY L.MORRISON, a single person,
herein designated as the Grantee,
WITNESSETH,that the Grantors,for and in consideration of ONE HUNDRED ONE
THOUSAND($101,000.00)DOLLARS lawful money of the United States of America,to the !
Grantors in hand well and truly paid by the Grantee,at or before the sealing and delivery of these
by acknowledged and the Grantors being therewith fully
presents,the receipt whereof is here
satisfied, do by these presents grant,bargain, sell and convey unto the Grantee forever,his heirs
and assigns,
ALL THAT CERTAIN tract of land situate in North Nfiddleton Township, Cumberland
County_ ,Pennsylvania,bounded and described according to survey of Stephen G. Fisher,
Surveyor,dated July 22, 1983 as follows:
BEGINNING at a point in Echo Road, T-427;thence North 31 degrees 25 minutes 53 seconds {
East, 189.72 feet to a railroad spike set;thence by land now or formerly of Robert McGinty and
passing through a private dirt lane, South 88 degrees 45 minutes East,91 feet to an iron pin;
thence by land now or formerly of Robert McGinty, South 27 degrees 30 minutes East... 171 feet
to an iron pin set;thence by land now or formerly of Louis E. Hair, South 88 degrees 15 minutes
West,269 feet to a point in Echo Road,T-427,point and place of BEGINNING.
I
WITH improvements thereon erected and containing 28,177.575 square feet.
BEING the same premises which Dolores A.Losch,Administrator of the Estate of David W.
Shenk.late,by Deed dated March 3, 2000 and recorded March 7,2000 in the Office of the
Recorder of Deeds in and for Cumberland County in Deed Book 217,Page 236, granted and
conveyed unto Darrell W. Maddy and Karen S. Maddy,husband and wife,the Grantors herein.
rt IMAM AND COUNTY Inst_#200737327-Page 1
• i.
TOGETHER with all and singular the buildings,improvements,ways,woods,waters,
hereditaments and appurtenances to the same belonging
watercourses,rights,liberties,privileges,
or in anywise appertaining,and the reversion and reversions,remainder and remainders,rents,
issues and profits thereof, and of every part and parcel thereof; AND also all the estate, right,
title,interest,use,possession,property,claim and demand whatsoever of the Grantors both in
law and in equity, of,in and to the premises herein described and every part and parcel thereof
i
with the appurtenances. TO HAVE AND TO HOLD all and singular the premises herein
described together with the hereditaments and appurtenances unto the Grantee and to Grantee's
proper use and benefit forever.
AND 1he Grantors covenant that,except as may be herein set forth,they do and will FOREVER
SPECIALLY WARRANT AND DEFEND the lands and premises,hereditaments and
appurtenances hereby conveyed,against the Grantors.
In all references herein to any parties, persons,entities or corporations,the use of any
particular gender or the plural or singular number is intended to include the appropriate gender or
number as the text of the within instrument may require.
Wherever in this instrument any party shall be designated or referred to by name.or I'
general reference,such designation is intended to and shall have the same effect as if the word I
"heirs,executors, administrators, personal or legal representatives,successors and assigns"had
been inserted after each and every such designation.
IN WITNESS WHEREOF,the Grantors have hereunto set their hands and seals,or if a
corporation,it has caused these presents to be signed by its proper corporate officers and its j
corporate seal to be affixed hereto,the day and year first above written.
SIGNED,SEALED AND DELIVERED
in the presence of
or ATTESTED y
WNESS Darrell W
IT . addy
SIGNED,SEALED AND DELIVERED
i
In the presence of
or ATTESTED by
WITNESS :' Karen S. Maddy
F
rAIMSERLANC COUNTY Inst.#200737327-Page 2
COMMONWEALTH OF P ,COUNTY OF
S " the subscriber,
gEff MEIVIgERED,that o , 2007,before me,
personally appeared,Darrell W.Madd known to me(or satisfactorily
proven)to be the persons whose names are subscribed within deed and acknowledged that
they executed the same for the purposes therein con i
WITNESS my hand and seal the day and year aforesaid.
L WDA E WALL
C_
�22
� NOTARY PUBLIC
00 0r
My Commission Expires:
(SEAL)
The undersigned certifies
that the precise residence
and complete post office
address of the Grantee is:
3t E cG`,o'/tc.-4
Y"Kc�.� y,•.�i�ospjf�
lAt, 3
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
RECORDED on this day of ,2007,in the Recorder's
Office of the said County,in Deed Book ,Page
GIVEN under my hand and the seal of the said Office,the date above writterL
Recorder
CUMBERLAND COUNTY Inst#200737327-Page 3
OF
COMMONWEALTH OF MINSYLVANIA,,COUN'T'Y
1=
BE IT =,that on ` ,—
2007,before mc,the
subsm-bea,pemsomally appeased, S-IMfadd�Mown me(or sa3isfac y proven)
to be the pas m whose nares are sabecz b to within deed and sekmowledged that they
executed the same fol the pKpaeies ffiminl oohed
WTTNR.SS my hand and seal the day and year afor+csaid
NOTARY PUBLIC COMMONW T P PENNSYLVANIA
rkA seal
My commission Ares Roger B.Irwin,Notary Public
L) Carlisle Bao,Cumberland County
(SEA
MY Cornrnlss EM*es OcL 3,2008
Member.Panngivania Association OI Notaries
lbe mdemiguc d catifies
dolt the.precim resWmce
and cwplft post office
e
adrdmss'of the Grmfte is:
i
i
i
I
COMMONWEALTH OF PE'MSYLVANIA
COUNTY OF
RECORDED an this day of ,2007,in the
Recmdes Offioc of the said County,im Deed Book �8e
i
(!PAN uWw my hmd and the seal of the said Offce,the dad-abovc
w>a m-
R000rder
I
I
n�i<cnne� i i—o•nn ald CUMBERLAND COUNTY Inst.#200737327-Page 4 c
Exhibit B
Note 10
May 26, 2010 CARLISLE PA
lryatel lCit)'l IScuel
131 ECHO RD
CARLISLE PA 17015
111ropeny Addressl
1. BORROWISR'S PROMISE TO PAY
In return for a loan that I have received,l promise to pay U.S.$ 27,896.13 ((his amount is called"Principal"),plus interest,
u)the order of the Lender. The Lender is CITIFINANCIAL SERVICES, INC. . I will make all payments under this Note in the
first of cash, check or money order.
I understand that(he Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to
receive payments under this Note is called the"Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of
11.8284 m.
The interest rate required by this Section 2 is the rate 1 will pay both before and after any default described in Section 6(13)of this
Note. After the Maturity Date established in Section 3,1 will pay interest at the interest rate required by[his Section 2 or the maximum
rate permitted under the then applicable law.
3. PAYAIENTs
(A)Time and Place of Payments
I will pit),principal and interest by making a payment every month.
1 will make my monthly payment on the 1st day of each month beginning on July 1st , 2010 . [will make
these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe
under this Note. Each monthly payment will he applied as of its scheduled due date and will he applied to interest before Principal. If,
on July 01, 2025 . I still owe amounts under this Note, I will pay those amounts in full on that date,which is called the"Maturity
Dare."
1 will stake my monthly payments at 950 WALNUT BOTTOM ROAD STE 16 CARLISLE PA 17015 or at a different place
if required by the Note Holder.
(B) Amount of Monthly Pa.vinents
My monthly payment will he in the amount of U.S.$ 331.06
4. HORROIVER'S RIGHT 7'O PREPAY
I have the right k, make payments of Principal at any time before they are due_ A payment of Principal only is known as a
"Prepayment.`When Intake a Prepayment,I will(ell the Note Holder in writing that 1 am cluing so. I may not designate a payment as a
Prepayment i1'I have not made all the monthly payments clue under the Note.
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my
Prepayments to reduce the amount of Principal that I owe under this Note. However,the Note Holder may apply my Prepayment to the
accrued and unpaid interest on the Prepayment amount,before applying my Prepayment to reduce the Principal amount of the Note.
If I make a partial Prepayment.there will be no changes in the clue date or in the amount of my monthly payment unless the Note
Holder agrees in writing to those changes.
S. LOAN CRARGFS
If a law,which applies to this loan and which sets maximum loan charges,is finally interpreted so that the interest or other Ivan
charges collected or to be collected in connection with this loan exceed the permitted limits,then: (a)any such loan charge shall be
reduced by the amount necessary to reduce the charge to the permitted limit:and(b)any sums already collected from me which exceeded
permitted limits will be refunded in me. The Note Holder may choose to make this refund by reducing the Principal I owe under this
Note or by making a direct payment to me. If a refund reduces Principal.the reduction will be treated as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date itis
duc,1 will pay a late charge to the Note Holder. The amount of the charge will be the greater of 10.0 ''A of my overdue payment of
principal and interest or U.S.S 20.00 . I will pay(his late charge promptly but only once on each late payment.
(B) Mrault
If 1 do not pay the fill amount of each monthly payment on the(laic it is duc. I will be in default.
(C) Notice of Default
If I am in default,the Note Holder may send me a written notice telling me Thal if I do not pay the overdue amount by a certain date,
(he Note Holder may require one to pay immediately the full amount of Principal which hits not been paid and all the interest that 1 owe
on that amount. That date must he nt least 30 days after the date on which the notice is mailed to me or delivered by other means.
(D) No Waiver By Note Holder
Even i(',at a time when 1 am in default,the Note Holder does not require me to pay immediately in full as described above,the Note
Holder will still have the right to do so if t am in default at a later time. If the Note Holder does not require me to pay all or pan of any
charge for any overdue or returned payment,it will still have the right to charge the full charge on any other overdue or returned
payment. The Note Holder may accept payments after the Maturity Date or after the date the Note Holder requires n,c (o pay
immediately in full without being required to renew or extend the loan,and may extend the time for payment alter maturity without
notice. The Note Holder may delay enforcing any of its other rights under this Note without losing them. The terns of this Note can be
waived or changed only in a writing signed by Note Holder.
(E) Payment of Nude Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above.the Note Holder will have the right to be paid
back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses
include.forexample,reasonable attorneys' fees.
FINED RATE No rr: t Borrower's Initials:
Ps 2OW-1 12130419 original (Branch) Copy (Customer) �— Page t of 2
JEFFREY MORRISON MELANIE L jjjyUkNDER . May 26, 2010
(F) C1targe for Returned Pavments
If any payment that I make by check. draft,or similar instrument is returned to the Note Holder unpaid. I will pay a returned
payment charge to the Note Ilolder. The amount of the charge will be U.S.S 20.00 .
7. GIVING OF NOTICES
Unless applicable law requires it different method,any notice that must he given to me under this Note will be given by delivering it
or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of illy
different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail
to the Note Holder at the address stated in Section 3(A)above or at a different address if I am given a notice of that different address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note,each person is fully and personally obligated to keep all of the promises made in this Note,
including the promise to pay the full amount owed. Any person who is a guarantor.surety or endorser of this Note is also obligated to
do these things. Any person who takes over these obligations,including the obligations of it guarantor,surety or endorser of this Note.
is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each
person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under
this Note. Any one of us can agree to extensions,renewals,or changes in the terms of this Note(which may include releasing security
or adding or releasing parties to this Note),without notice to others. Any such agreement will not relieve any of us from responsibility
under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor."Presentment"
means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor-moms the right to require the
Note Holder to give notice to other persons that amounts due have not been paid.
10. UNiFORIM SECURED NOTE
This Notc is a uniform instrument with limited variations in some.jurisdictions. In addition to the protections given to the Note
Holder under this Note,a Mortgage.Deed of Trust,or Security Deed(the "Security Instrument-),dated the same date as this Note.
protects the Note Holder from possible dosses which might result if 1 do not keep the promises which I make in this Note. That Security
Instrument describes how and under what conditions 1 may be required to make immediate payment in full of all amounts I owe under
this Note. Some of those conditions are described as follows:
If all or any part of the Property or any Interest in the Properly is sold or transferred(or if Borrower is not a natural person and
a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate
payment in full of all sums secured by this Security Instrument. However,this option shall not be exercised by Lender if such
exercise is prohibited by Applicable Law.
If Lender exercises this option,Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less
than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by
this Security Instrument.ll'Borrower fails to pay these sums prior to the expiration of this period,Lender may invoke any remedies
permined by this Security Instrument without further notice or demand on Borrower.
11. APPLICABLE LAW
This Note is governed by PENNSYLVANIA law and federal law,as applicable. If any part of this Note is unenforceable,this will
not make any other part unenforceable. In no event will 1 be required to pay interest or charges in excess of those permitted by law.
12. AUTHORIZATION TO USE CREDIT REPORT
I authorize Note Holder to obtain,review and use information contained in my credit report in order to determine whether 1 may
qualify for products and services offered by Note Holder. This authorization terminates when my outstanding balance due under this
Note,along with any additional amounts that 1 may owe under the Security Instrument that I am giving to secure this Note.is paid in
full. 1 may cancel this authorization at any time by writing to the f'ofdowing address: CiliFinancial-Customer C.A.R.E. Department,
605 Munn Road,Fort Mill,SC 29715. In order to process my request.I must provide Note Holder my full name,address.social security
number and account number.
WITNESS THE HAND(S)AND SEAL(S)OF THE UNDERSIGNED.
J �i RRI N (Seal)
Borrower
),?iQ/ (Seal)
ME IE L A IRR' -Borrower
(Seal)
Borrower
05/26/2010 15:07:40 /Sign Original Only/
I�oc�ef's
u L5
Lp-lao-c' U"�s 1 fl7b3
FIXED RATE NO 11:
['A 201N-1 124(x19 Original (Branch) copy (Customer) rage 2 or 2
NOTE ALLONGE
This indorsement is incorporated into and shall be deemed part of the Note to which it is
attached.
Loan Nun,her*-
*as of rite date of this Note Allonge
Borrower Name(s): JEFFREY MORRISON; MELANIE L ALEXANDER
Date of Loan: 05/26/2010
Amount of Loam: $27,896.13
Property Address: 131 ECHO RD
City,State,Zip: CARLISLE,PA 17015
Pay to the order of:
CitiFinancial Servicing LLC (a Delaware limited liability company)
Without recourse
CFNA Receivables(PA),Inc.f/k/a Ciffinancial Services,Inc. (a Pennsylvania corporation)
By:
Raymond White
Vice President
05-0071-0206465
A '
Exhibit C
ROBERT P.ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE -
m.
CARLISLE, PA 17013
7- -6370 -
71 24� ..
Instrument Number-201013913 j
Recorded On 5/28/2010 At 11:24:08 AM *Total Pages- 16.
*Instrument Type-MORTGAGE
Invoice Number-66382 User ID-KW
*Mortgagor-MORRISON,JEFFREY L
•Mortgagee-CITIFINANCIAL SER INC
*Customer-FINITI
FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS/ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES - $33.50
RECORDER OF DEEDS This page is now part
PARCEL CERTIFICATION $10.00
FEES of this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $84.00
I Certify this to be recorded
in Cumberland County PA
o cviq� ,o
RECORDER O/DZDS
•-Information denoted by so asterisk may change during
the verification process and may not be reflected on this page.
001 TQY
11111111111 oil III I III
,. CUMBERLAND COUNTY Inst#201013913-Page 16
sorr,��rnuer mucmurnYu,i unu w ori
13913
QQ1 TQY
Prepared by:
CITIFINANCIAL SERVICES,
INC.
950 WALNUT BOTTOM ROAD STE 16
CARLISLE PA 17015
(717) 249-9566
When recorded, return to
Rniti
Finiti Recording Team
Accommodation Recording per Client Requests
7090 Samuel Morse Drive `1S'? 1 114 3
Columbia,MD 21046
Parcel Number: 29-05-0425-067
[Space Above This Line For Recording Data]
MORTGAGE
DEFINITIONS
i
Words used in multiple sections of this document are defined below and other words are defined in Sections 3,
11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in
Section t6.
(A)"Security Instrument"means this document,which is dated May 26, 203-0 together with all
Riders to this document.
(B)"Borrower"is JEFFREY L MORRISON
Borrower is the mortgagor under this Security Instrument.
(C)"Lender"is CITIFINANCIAL .SERVICES, INC. Lender is a corporation
organized and existing under the laws of Pennsylvania . Lender's address is
950 WALNUT BOTTOM ROAD STE 16 CARLISLE PA 17015
Lender is the mortgagee under this Security Instrument.
(D)"Note"means the promissory note signed by Borrower and dated May 26, 2010
The Note states that Borrower owes Lender
TWENTY-SEVEN THOUSAND EIGHT HUNDRED NINETY-SIX AND 13/100 DOLLARS
(U.S.$ 27,896.13 )plus interest. Borrower has promised to pay this debt in regular Periodic Payments
and to pay the debt in full not later than July 01, 2025
(E)"Property"means the property that is described below under the heading "Transfer of Rights in the Property."
(F)"Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due
under the Note, and all sutras due under this Security Instrument,plus interest-
(G)"Riders"means all Riders to this Security Instrument that are executed by Borrower. The following Riders
are to be executed by Borrower[check box as applicable]:
❑ Adjustable Rate Rider ❑ Condominium Rider ❑ Second Home Rider
❑ Balloon Rider ❑ Planned Unit Development Rider O Other(s)[specify]
❑ 1-4 Family Rider ❑ Biweekly Payment Rider
(H)"Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances
and administrative rules and orders (that have the effect of law) as well as all applicable final, non-appealable
judicial opinions.
PENNSYLVANIA-Single Farnily-Fannie MaeJFreddie Mac UNIFORM INSTRUMENT Form 3039 t/ol
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(I)"Community Association Dues, Fees, and Assessments" means all dues, _
fees, assessments and other charges that are imposed on Borrower or the
Property by a condominium association, homeowners association or similar i
organization. f
(J)"Electronic Funds Transfer"means any transfer of funds,other than a transaction originated by check,draft,
or similar paper instrument,which is initiated through an electronic terminal,telephonic instrument,computer,or
magnetic rape so as to order,instruct,or authorize a financial institution to debit or credit an account. Such term
includes,but is not limited to,point-of-sale transfers,automated teller machine transactions,transfers initiated by
telephone, wire transfers, and automated clearinghouse transfers.
(K)"Escrow Items"means those items that are described in Section 3.
i
(L)"Miscellaneous Proceeds" means any compensation,settlement, award of damages,or proceeds paid by any
third parry (other than insurance proceeds paid under the coverages described in Section 5) for(i)damage to, or
destruction of,the Property;(ii)condemnation or other taking of all or any part of the Property;(iii)conveyance
in lieu of condemnation; or (iv)misrepresentations of, or omissions as to, the value and/or condition of the
Property.
M)"Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the
Loan
(1)"Periodic Payment" means the regularly scheduled amount due for(i) principal and interest under the Note,
plus(ii)any amounts under Section 3 of this Security Instrument.
(0)"RESPA"means the Real Estate Settlement Procedures Act (12 U.S.C.§2601 et seq.)and its implementing
regulation,Regulation X(24 C.F.R.Part 3500),as they might be amended from time to time,or any additional or
successor legislation or regulation that governs the same subject matter. As used in this Security Instrument,
"RESPA"refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage
loan"even if the Loan does not qualify as a"fedetallyrelated mortgage loan"under RESPA.
(P)"Successor in Interest of Borrower"means any parry that has taken title to the Property,whether or not that
party has assumed Borrower's obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security lnsmmiettt secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and
modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this Security `
Instrument and the Note. For this purpose. Borrower does hereby mortgage, grant and convey to Lender the t
following described property located in the County of CUMBERLAND E`
PENNSYLVANIA--Single Family--Fannie Maeffloddie Mac UNIFORM INSTRUMENT Form 3039 1101
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ALL THAT CERTAIN PARCEL OF LAND IN NORTH MIDDLETON TOWNSHIP,CUMBERLAND
COUNTY, COMMONWEALTH OF PA, AS MORE FULLY DESCRIBED IN INSTRUMENT NO
200737327 ID# 29-05-0425-067, BEING KNOWN AND DESIGNATED AS A METES
AND BOUNDS PROPERTY SURVEY OF STEPHEN G FISHER, SURVEYOR, DATED JULY
22, 1983.
BEING THE SAME FEE SIMPLE PROPERTY CONVEYED BY SPECIAL WARRANTY DEED
FROM DARRELL N MADDY AND KAREN S MADDY TO JEFFREY L MORRISON SINGLE,
DATED 09/21/2007 RECORDED ON 09/26/2007 IN INSTRUMENT NO 200737327, IN
CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PA.
which currently has the address of 131 ECHO RD
CARLISLE
Pennsylvania 17015 ("Property Address'):
TOGETHER WITH all the improvements now or hereafter erected on the property,and all easements,
appurtenances,and fixtures now or hereafter a part of the property. All replacements and additions shall also be
covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
Property.
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the
right to grant and convey the Property and that the Property is unencumbered,except for encumbrances of record. f.
Borrower warrants and will defend generally the dde to the Property against all claims and demands,subject to
any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real
property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges.
Borrower shall pay when due the principal of,and interest on,the debt evidenced by the Note and any prepayment
charges and We charges due under the Note. Borrower shall also pay funds for Escrow items pursuant to Section
3. Payments due under the Note and this Security Instrument shall be made in U.S.currency. However,if any
check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to
Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security
Instrument be made in one or more of the following forms, as selected by Lender: (a)cash; (b)money order;
(c)certified check, bank check,treasurer's check or cashier's check,provided any such check is drawn upon an
institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d)Electronic Funds
Transfer.
PENNSYLVANIA-Single Family-Fannie MabWreddie Mac UNIFORM INSMUNWM Form 3039 VOL
PA21OM-2 42010 Original(Recorded) Copy(Branch) Copy(Custorner) Page 3 of 15
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MELANIE L ALEXANDER
Payments are deemed received by Lender when received at the
location designated in the Note or at such other location as may be designated
by Lender in accordance with the notice provisions in Section 15. Lender may
return any payment or partial payment if the paymerit or partial payments are
insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the
Loan current,without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial �•
payments in the future, but Lender is not obligated to apply such payments at the time such payments are
accepted. If each Periodic Payment is applied as of its scheduled due date,then Lender need not pay interest on
unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan
current. if Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or
return them to Borrower. if not applied earlier,such funds will be applied to the outstanding principal balance
under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the
future against Lender shall relieve Borrower from making payments due under the Note and this Security
Instrument or performing the covenants and agreements secured by this Security Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section 2,all payments
accepted and applied by Lender shall be applied in the following order of priority:(a) interest due under the Note;
(b)principal due under the Note; (c)amounts due under Section 3. Such payments shall be applied to each F
Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late
charges,second to any other amounts due under this Security Instrument,and then to reduce the principal balance
of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
sufficient amount to pay any late charge due,the payment may be applied to the delinquent payment and the late l
charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from
Borrower to the repayment of the Periodic Payments if, and to the extent that,each payment can be paid in full.
To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic
Payments,such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to
any prepayment charges and then as described in the Note.
Any application of payments, insurance proceeds,or Miscellaneous Proceeds to principal due under the
Note shall not extend or postpone the due date,or change the amount,of Periodic Payments.
3. Funds for F-wmw Items.Borrower shall pay to Lender on the day Periodic Payments are due under
the Note,until the Note is paid in full,a sum(the "Funds")to provide for payment of amounts due for: (a)taxes
and assessments and other items which can attain priority over this Security Instrurnent as a lien or encumbrance
on the Property; (b)leasehold payments or ground rents on the Property, if any; (c)premiums for any and all
insurance required by Lender under Section 5;and(d) Mortgage Insurance premiums,if any,or any sums payable
by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions
of Section LO_ These items are called `Escrow Items." At origination or at any time during the term of the Loan,
Lender may require that Community Association Dues,Fees,and Assessments,if any,be escrowed by Borrower,
and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all
notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless
Lender waives Borrower's obligation to pay the Funds for any or all E=ow Items. Lender may waive
Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time.Any such waiver may only
be in writing. In the event of such waiver,Borrower shall pay ditectly,.when and where payable,the amounts due
for any Escrow Items for which payment of Fands has been waived by Lender and, if Lender requires, shall
furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's
obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and
PENNSYLVANIA—Single Family--Fannie Mee/Freddie Mee UNIFORM INSTRUMENT Form 3039 1/01
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agreement contained in this Security Instrument,as the phrase "covenant and
agreement"is used in Section 9. If Borrower is obligated to pay Escrow Items
directly,pursuant to a waiver,and Borrower fails to pay the amount due for an
Escrow Item, Lender may exercise its rights under Section 9 and pay such
amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may
revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and,
upon such revocation,Borrower shall pay to Lender all Funds,and in such amounts,that are then required under
Section 3_
Lender may,at any time,collect and hold Funds in an amount (a)sufficient to permit Lender to apply the j
Funds at the time specified under RESPA,and(b)not to exceed the maximum amount a lender can require under
RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of
expenditures of future Escrow Items or otherwise in accordance with Applicable Law.
'The Funds shall be held in an institution whose deposits are insured by a federal agency,instrumentality,
or entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Horne
Loan Bank. Lender shalt apply the Funds to pay the Escrow Iters no later than the time specified under RESPA.
Lender shall not charge Borrower for holding and applying the Funds,annually analyzing the escrow account, or
verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits
Lender to make such a charge.Unless an agreement is made in writing or Applicable Law requires interest to be
paid on the Funds,Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower
and Lender can agree in writing,however,that interest shall be paid on the Funds. Lender shall give to Borrower,
without charge,an annual accounting of the Funds as required by RESPA.
If there is a surplus of Funds held in escrow,as defined under RESPA,Lender shall account to Borrower
for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow,as defined under
RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount
necessary to matte up the shortage in accordance with RESPA,but in no more than 12 monthly payments. If there
is a deficiency of Funds held in escrow,as defined under RESPA, Leader shall notify Borrower as required by
RESPA,and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with
RESPA,but in no more than 12 monthly payments.
Upon payment in full of all sutras secured by this Security Instrument, Lender shall promptly refund to
Borrower any Funds held by Lender.
4. Charges; liens.Borrower shall pay all taxes,assessments,charges,fines,and impositions attributable
to the Property which can attain priority over this Security Instrument,leasehold payments or ground rents on the
Property,if any,and Community Association Dues,Fees,and Assessments,if any. To the extent that these items
are Escrow Items, Borrower shall pay them in the manner provided in Section 3.
Borrower gall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the paytnent of the obligation secured by the lien in a manner acceptable to
Lender,but only so long as Borrower is performing such agreement; (b)contests the lien in good faith by, or
defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the
enforcement of the lien while those proceedings ate pending,but only until such proceedings are concluded;or(c)
secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security
Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over
this Security Instrument,Lender may give Borrower a notice identifying the lien. Within 10 days of the date on
which that notice is given.Borrower shall satisfy the lien or take one or more of the actions set forth above in this
Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting
service used by Lender in connection with this Loan.
PENNSYLVANIA--Single Family-Ferutle MWFreddie Mat:UNIFORM INSTRUMENT Form 3039 I/Ot
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5. Property Insurance. Borrower shall keep the improvements now l
existing or hereafter erected on the Property insured against loss by fire,
hazards included within the term "extended coverage,"and any other hazards
including,but not limited to,earthquakes and floods,for which Lender requires
insurance. This insurance shall be maintained in the amounts(including deductible levels)and for the periods that
Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the
Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to
disapprove Borrower's choice,which right shall not be exercised unreasonably- Lender may require Borrower to
pay, in connection with this Loan, either: (a)a one-time charge for flood zone determination, certification and
tracking services; or(b)a one-time charge for flood zone determination and certification services and subsequent
charges each time remappings or similar changes occur which reasonably might affect such determination or
certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency
Management Agency in connection with the review of any flood zone determination resulting from an objection
by Borrower_
If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance
coverage,at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular
type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might not protect
Borrower,Borrower's equity in the Property,or the contents of the Property,against any risk,hazard or liability
and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost
of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have
obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower
secured by this Security instrument. These amounts shall bear interest at the Note rate from the date of
disbursement and shall be payable,with such interest, upon notice from Lender to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right
to disapprove such policies,shall include a standard mortgage clause,and shall name Lender as mortgagee and/or
as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender i
requires,Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower
obtains any form of insurance coverage,not otherwise required by Lender,for damage to,or destruction of, the
Property,such policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an
additional loss payee.
In the event of loss,Borrower shall give prompt notice to the insurance carrier and Lender. Leader may
snake proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing,
any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to
restoration or repair of the Property,if the restoration or repair is economically feasible and Lender's security is
not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance
proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to
Leader's satisfaction,provided that such inspection shall be undertaken promptly. Lender may disburse proceeds
for the repairs and restoration in a single payment or in a series of progress payments as the work is completed.
Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds,
Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees for public adjusters,
or other third parties,retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole
obligation of Borrower. If the restoration or repair is not economically feasible or Lender's security would be
lessened,the insurance proceeds shall be applied to the sums secured by this Security Instrument,whether or not
then due,with the excess,if any,paid to Borrower. Such insurance proceeds shall be applied in the order provided
for in Section 2.
PENNSYLVANIA-Single Family-Fannie Mw1freddie Mac UNIFORM INSTRUMENT Form 3039 1/01
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If Borrower abandons the Property, Lender may file, negotiate and
settle any available insurance claim and related matters. If Borrower does not
respond within 30 days to a notice from Lender that the insurance carrier has
offered to settle a claim,then Lender may negotiate and settle the claim. The
30-day period will begin when the notice is given. In either event, or if Lender acquires the Property under
Section 22 or otherwise,Borrower hereby assigns to Lender(a)Borrower's rights to any insurance proceeds in an
amount not to exceed the amounts unpaid under the Note or this Security instrument, and (b) any other of
Borrower's rights(other than the right to any refund of unearned premiums paid by Borrower)under all insurance
policies covering the Property,insofar as such rights are applicable to the coverage of the Property_ Lender may
use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this
Security Instrument, whetheror not then due.
6. Occupancy, Borrower shall occupy, establish, and use the Property as Borrower's principal
residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property
as Borrower's principal residence for at least one year after the date of occupancy,unless Lender otherwise agrees
in writing,which consent shall not be unreasonably withheld,or unless extenuating circumstances exist which are i
beyond Borrower's control.
7. Preservation, Maintenance and Protection or the Property; Inspections. Borrower shall not
destroy. damage or impair the Property, allow the Property to deteriorate or commit waste on the Property.
Whether or not Borrower is residing in the Property,Borrower shall maintain the Property in order to prevent the
Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to i
Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if
damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in connection
with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the
Property only if Lender has released proceeds for such purposes.Leader may disburse proceeds for the repairs and
restoration in a single payment or in a series of progress payments as the work is completed. If the insurance or
condemnation proceeds are not sufficient to repair or restore the Property,Borrower is not relieved of Borrower's
obligation for the completion of such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has
reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give
Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause.
S. Borrower's Loan Applkadon. Borrower shall be in default if,during the Loan application process,
Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent
gave materially false,misleading,or inaccurate information or statements to Lender(or failed to provide Lender
with material information) in connection with the Loan. Material representations include,but are not limited to,
representations concerning Borrower's occupancy of the Property as Borrower's principal residence.
9. 'Protection of Lender's Interest In the Property and Rights Under this Security Instrument. If
(a)Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b)there is a
legal proceeding that might significantly affect Lender's interest in the Property and/or righis under this Security
Instrument(such as a proceeding in bankruptcy,probate,for condemnation or forfeiture,for enforcement of a lien
which may attain priority over this Security Instrument or to enforce laws or regulations),or(c)Borrower has
abandoned the Property,then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's
interest in the Property and rights under this Security Instnunent,including protecting and/or assessing the value
of the Property,and sectoring and/or repairing the Property. Lender's actions can include, but are not limited to:
(a)paying any sums secured by a lieu which has priority over this Security Instrument;(b)appearing in court;and
r
PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mex UNERORM INSTRUMENT Form 3039 1101
PA2IaM-2 412010 Original(Recorded) Copy(Branesh) copy(custcmer) Page 7 of 15
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(c)paying reasonable atromeys' fees to protect its interest in the Property
and/or rights under this Security Instrument,including its secured position in a
bankruptcy proceeding- Securing the Property includes, but is not limited to,
entering the Property to make repairs,change locks,replace or board up doors
and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and
have utilities turned on or off. Although Uridcr may take action under this Section 9,Lender does not have to do
so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any
or all actions authorized under this Section 9.
Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured
by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and
shall be payable,with such interest, upon notice from Lender to Borrower requesting payment.
If this Security Instrument is on a leasehold.Borrower shall comply with all the provisions of the lease.
If Borrower acquires fee title to the Property,the leasehold and the fee title shall not merge unless Lender agrees i.
to the merger in writing. ;
10. Mortgage Insurance, If Lender required Mortgage Insurance as a condition of making the Loan,
Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason,the
Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously
provided such insurance and Borrower was required to make separately designated payments toward the premiums
for Mortgage Insurance,Borrower shall pay the premiums required to obtain coverage substantially equivalent to
the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the
Mortgage Insurance previously in effect,from an alternate mortgage insurer selected by Lender. If substantially
equivalent Mortgage Insurance coverage is not available,Borrower shall continue to pay to Lender the amount of
the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender will
accept, use and retain these payments as a non-refundable loss reserve in lieu of Mortgage Insurance. Such loss
reserve shall be non-refundable,notwithstanding the fact that the Loan is ultimately paid in full,and Lender shall
not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss
reserve payments if Mortgage Insurance coverage(in the amount and for the period that Lender requires)provided
by an insurer selected by Lender again becomes available,is obtained,and Lender requires separately designated
payments toward the premiums for Mortgage Insurance.
If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make
separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums
required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve,until Lender's
requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender
providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10
affects Borrower's obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender(or any entity that purchases the Note) for certain losses it may
incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time,and nay enter
into agreements with other parties-that share or modify their risk,or reduce losses.'Mese agreements are on terms
and conditions that are satisfactory to the mortgage insurer and the other party for parties) to these agreements.
(hese agreements may rewire the mortgage insuter to make payments using any source of funds that the
mortgage insurer may have available(which may include funds obtained from Mortgage Insurance premiums).
PENN,WLVANIA-•Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1/61
PA210M-2 4/2010 original(Recorded) Copy(Branch) Copy(custoaner) Page 8 of 15
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07/16/2013 11.59:58 AM CUMBERLAND COUNTY Inst#201013913-Page 8 of 1
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JEFFREY MORRISON 05/26/2010
MELANIE L ALEXANDER
As a result of these agreements, Lender,any purchaser of the Note,
another insurer,any reinsurer,any other entity,or any affiliate of any of the
foregoing, may receive (directly or indirectly) amounts that derive from (or
might be characterized as) a portion of Borrower's payments for Mortgage j
Insurance, in exchange for sharing or modifying the mortgage insurer's risk, or reducing losses- if such
agreement provides that an affiliate of tender takes a share of the insurer's risk in exchange for a share of the
premiums paid to the insurer, the arrangement is often termed "captive reinsurance."Further:
(a) Any such agreements will not affect the amounts that Borrower has agreed to pay for
Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount
Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund.
(b) Any such agreements will not affect the rights Borrower has — if any — with respect to the
Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may
include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage
i.
Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any
Mortgage Insurance premiums that were unearned at the time of such cancellation or termination.
11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby
assigned to and shall be paid to Lender.
If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the
Property,if the restoration or repair is economically feasible and Lender's security is not lessened. During such j
repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has
had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction,
provided that such inspection shall be undertaken promptly. Leader may pay for the repairs and restoration in a
single disbursement or in a series of progress payments as the work is completed. Unless an agreement is trade in
writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be
requited to pay Borrower any interest or earnings on such Miscellaneous Proceeds, If the restoration or repair is
not economically feasible or Leader's security would be lessened,the Miscellaneous Proceeds shall be applied to
the sums secured by this Security Instrument,whether or not then due,with the excess,if any,paid to Borrower.
Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2.
In the event of a total taking,destruction,or loss in value of the Property,the Miscellaneous Proceeds
shall be applied to the sums secured by this Security Instrument,whether or not then due,with the excess,if any,
paid to Borrower.
In the event of a partial taking, destruction,or loss in value of the Property in which the fair market
value of the Property immediately before the partial taking,destruction,or loss in value is equal to or greater than
the amount of the sums secured by this Security Instrument immediately before the partial taking,destruction,or
loss in value, unless Borrower and Lender otherwise agree in writing, the sutras secured by this Security
Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following fraction:(a)
the total amount of the sums secured immediately before the partial taking,destruction,or loss in value divided by
(b) the fair market value of the Property immediately before the partial taking,destruction,or loss in value. Any !:
balance shalt be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Property immediately before the partial taking,destruction,or loss in value is less than the amount of
the sums secured immediately before the partial taking,destruction,or loss in value,unless Borrower and Lender
otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security
Instrument whether or not the sums are then due.
PENNSYLVANIA--Single Fatuity--Farmie Mae/Fremie Mac UNIFORM INSTRUMENT Form 309 1101
PA210M-2 4/2010 original(Recorded) Copy(Branch) Copy(custower) Page 9 of 15
m/zannta 11-M-SA AM CUMBERLAND COUNTY Inst.#201013913-Page 9 of 1
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JEFFREY MORRISON 05/26/2010
MELANIE L ALEXANDER
If the Property is abandoned by Borrower, or if, after notice by
Lender to Borrower that the Opposing Party(as defined in the next semence)
offers to make an award to settle a claim for damages, Borrower fails to
respond to Lender within 30 days after the date the notice is given, Lender is
authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the
sums secured by this Security Instrument,whether or not then due. "Opposing Party"means the third party that l
owes Borrower Miscellaneous Proceeds or the parry against whom Borrower has a right of action in regard to
Miscellaneous Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in
Lender's judgment,could result in forfeiture of the Property or other material impairment of Lender's interest in
the Property or tights under this Security Instrument. Borrower can cure such a default and,if acceleration has
occurred,reinstate as provided in Section 19,by causing the action or proceeding to be dismissed with a ruling
that, in Lender's judgment,precludes forfeiture of the Property or other material impairment of Lender's interest l
in the Property or rights tattler this Security Instntment. The proceeds of any award or claim for damages that are
attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in
i.
the order provided for in Section 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for
payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to
Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any j
Successors in Interest of Borrower. Lender shall not be required to commence proceedings against arty Successor
in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Security Instrument by reason of any demand made by the original Borrower or any Successors in
Interest of Borrower. Any forbearance by Lender in exercising any right or remedy including,without limitation,
Lender's acceptance of payments from third persons,entities or Successors in Interest of Borrower or in amounts
less than the amount then due, shall not be a waiver of or preclude the exerciseof any right or remedy.
13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants
and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who
co-signs this Security Instrument but does not execute the Note (a "co-signer"):(a) is co-signing dtis Security
Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this
Security Instrument;(b) is not personally obligated to pay the sums secured by this Security Instrument; and(c)
agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations
with regard to the terms of this Security Insttvment or the Note without the co-signer's consent.
Subject to the provisions of Section 18,any Successor in Interest of Borrower who assumes Borrower's
obligations under this Security Insttutrterd in writing,and is approved by Lender,shall obtain all of Borrower's
rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations
and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and
agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors
and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with
Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security
Instrument,including,but not limited to,attorneys' fees,property inspection and valuation fees. In regard to any
other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower shall
not be construed as a prohibition on the charging of such fee. Lender tray not charge fees that are expressly
prohibited by this Security Instrument or by Applicable Law.
PV%rNSYLVAN1A-Singk Family-Fa®te MadFreddk Mae UMFORM INSTRUMENT Form M39 1/01
PA210M-2 4/2010 origiaal(Recorded) Copy(Sremch) Copy(CUB tomer) Page 10 of 15
n�isann�z t 1 SO SR AM CUMBERLAND COUNTY Inst.#201013913-Page 10 of
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JEFFREY MORRISON 05/26/2010
MELANIE L ALEXANDER
If the Loan is subject to a law which sets maximum loan charges,and l
that law is finally interpreted so that the interest or other loan charges
collected or to be collected in connection with the Loan exceed the permitted f..
limits,then: (a)any such loan charge shall be reduced by the amount necessary
to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded
permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal
owed under the Note or by malting a direct payment to Borrower. If a refund reduces principal,the reduction will
be treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is
provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower
will constitute a waiver of any right of action Borrower might have arising out of such overcharge.
15. Notices. All notices given by Borrower or lender in connection with this Security Instrument must
be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been
given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent
by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law
expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated a j
substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of
address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only
report a change of address through that specified procedure. There nay be only one designated notice address
under this Security Instrument at any one time. Any notice to Lender shall be given by delivering it or by tailing
it by first class mail to Lender's address stated herein unless Lender has designated another address by notice to
Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been given to
Lender until actually received by Lender. If any notice required by this Security Instrument is also requited under
Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security
Instrument.
16. Governing Law; Severablllty; Rules of Construction. This Security Instrument shall be governed
by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations
contained in this Security Instrument are subject to any requirements and Limitations of Applicable Law.
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Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent,but such
silence shall not be construed as a prohibition against agreement by contract- In the event that any provision or
clause of this Security Instrument or the Note conflicts with Applicable Law,such conflict shall not affect other
provisions of this Security Instrument or the Note which can be given effect without the conflicting provision.
As used in this Security Instrument: (a)words of die masculine gender shall mean and include
corresponding neuter words or words of the feminine gender;(b)words in the singular shall mean and Include the
plural and vice versa;and(c)the word"tray" gives sole discretion without any obligation to take any action.
17.Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
18. Transfer of the Properly or a Beneficial Interest in Borrower. As used in this Section 18,
"Interest in the Property"means any legal or beneficial interest in the Property,including,but not limited to,those
beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow
agreement, the intent of which is the transfer of title by Borrower at afuture date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or transferred(or if Borrower is
not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written
consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
PENNSYLVANIA—Single Family--Famde MaeTre&lle Mee UNIFORM INSTRUMENT Form 3039 If0i
PA21OM•2 412010 Original(Recorded) Copy(Brauch) Copy(Custamer) Page t1 of 15
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07116f2013 11:59:58 AM CUMBERLAND COUNTY Inst#201013913-Page 11 of
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JEFFREY MORRISON 05/26/2010
MELANIE L ALEXANDER
If Lender exercises this option, Lender shall give Borrower notice of I:
acceleration. The notice shall provide a period of not less than 30 days from
the date the notice is given in accordance with Section 15 within which i.
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Borrower must pay all sures secured by this Security Instrument. If Borrower �
fails to pay these sums prior to the expiration of this period,Lender may invoke any remedies permitted by this
Security Instrument without further notice or demand on Borrower-
19.Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions.Borrower
shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest
of: (a) five days before sale of the Property pursuant to any power of sale contained in this Security Instrument;
(b)such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or(c)
entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all
sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred;(b)
cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security
Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and
other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security
Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the
Property and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this
Security Instrument,shall continue unchanged. Lender may require that Borrower pay such reinstatement sutras
and expenses in one or more of the following forms,as selected by Lender:(a)cash; (b)money order;(c)certified
check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution
whose deposits are insured by a federal agency,instrumentality or entity; or(d) Electronic Funds Transfer. Upon
reinstatement by Borrower,this Security Instrument and obligations secured hereby shall remain fully effective as
if no acceleration had occurred. However,this right to reinstate shall not apply in the case of acceleration under
Section 18.
20. Sale of Note; Change of Loan Servicer; Notice of Grievance, The Note or a partial interest in the
Note(together with this Security Instrument)can be sold one or more times without prior notice to Borrower. A
sale might result in a change in the entity (known as the "Loan Servicer")that collects Periodic Payments due
under the Note and this Security Instrument and perforans other mortgage loan servicing obligations under the
Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan
Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer,Borrower will be given written
notice of the change which will state the name and address of the new Loan Servicer, the address to which
payments should be made and any other information RESPA requires in connection with a notice of transfer of
servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the
Note,the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to
a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by tate Note
purchaser.
Neither Borrower not Lender may commence,join, or be joined to any judicial action (as either an k.
individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security
Instrument or that alleges that the other parry has breached any provision of,or any duty owed by reason of, this
Security Instrument, until such Borrower or Lender has notified. the other party (with such notice given in
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compliance with the requirements of Section 15)of such alleged breach and afforded the other party hereto a
reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time
period which must elapse before certain action can be taken,that time period will be deemed to be reasonable for
purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to
is
PENNSYLVANIA—Singk Family--Famde MaeJFreddie Mac UNIFORM tNSMUMENT Farm 3039 1101
PA21OM 2 412010 Original(Recorded) Copy(xirarich) Copy(customer) Pap 12 of 15
07/16/7013 11:59:58 AM CUMBERLAND COUNTY Inst.#201013913-Page 12 of 1,
JEFFREY MORRISON 05/26/2010
MELANIE L ALEXANDER
Section 22 and the notice of acceleration given to Borrower pursuant to
Section 18 shall be deemed to satisfy the notice and opportunity to take
corrective action provisions of this Section 24.
21. Hazardous Substances. As used in this Section 21: (a)
"Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, or wastes by
Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum
products, toxic pesticides and herbicides,volatile solvents, materials containing asbestos or formaldehyde, and
radioactive materials; (b) "Environmental Law" means federal laws and laws of the jurisdiction where the
Property is located that relate to health,safety or environmental protection;(c) "Environmental Cleanup" includes
any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an
"Environmental Condition"means a condition that can cause,contribute to,or otherwise trigger an Environmental
Cleanup. j
Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous
Substances, or threaten to release any Hazardous Substances, on or in the Property.Borrower shall not do, nor
allow anyone else to do, anything affecting the Property (a)that is in violation of any Environmental Law,
(b) which creates an Environmental Condition,or (c)which, due to the presence,use,or release of a Hazardous
Substance,creates a condition that adversely affects the value of the Property. The preceding two sentences shall
not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are
generally-recognized to be appropriate to normal residential uses and to maintenance of the Property (including,
but not limited to,hazardous substances in consumer products).
Borrower shall promptly give Lender written notice of(a) any investigation, claim, demand, lawsuit or
other action by any governmental or regulatory agency or private party involving the Property and any Hazardous
Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition, j
including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous
Substance, and (c)any condition caused by the presence,use or release of a Hazardous Substance which adversely
affects the value of the Property. If Borrower learns,or is notified by any governmental or regulatory authority,or
any private party, that any removal or other remediation of any Hazardous Substance affecting the Property is
necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental law.
Nothing herein shall create any obligation on Lender for an Environmental Cleanup.
1
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following 1
Borrower's breach of any covenant or agreement in this Security Instrument(but not prior to acceleration
under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among
other things-. (a) the default; (b) the action required to cure the default; (c) when the default must be I
cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured
by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall
further inform Borrower of the right to reinstate after acceleration and the right to assert in the
foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and
foreclosure. If the default is not cured as specified,Lender at its option may require immediate payment
in full of all surras secured by this Security Instrument without further demand and may foreclosure this
Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in
pursuing the remedies provided in this Section 22, including,but not limited to,attorneys' fees and costs
of title evidence to the extent permitted by Applicable Law.
PENNSYLVANIA--Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Foran 3039 1/01
PA210M-2 4/2010 original(Recorded) Copy(Branch) copy(customer) Page 13 of 15
(TIMBERLAND COUNTY Inst_#201013913-Page 13 of
OY�MYY69�Y�YIIY■eRYYIYIYI iuh�47 r .
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JEFFREY MORRISON 05/26/2010
MELANIE L ALEXANDER �;-
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23. Releases_ Upon payment of all sutras secured by this Security
Instrument, this Security Instrument and the estate conveyed shall terminate
and become void. After such occurrence, Lender shall discharge and satisfy
this Security Instrument. Borrower shall pay any recordation costs. Lender
may charge Borrower a fee for releasing this Security Instrument,but only if the fee is paid to a third party for
services rendered and the charging of the fee is permitted under Applicable Law.
24. Waivers. Borrower, to the extent permitted by Applicable Law,waives and releases any error or
defects in proceedings to enforce this Security Instrument,and hereby waives the benefit of any present or future
laws providing for stay of execution,extension of time,exemption from attachment,levy and sale,and homestead
exemption.
25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour I.
prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is tent to i
Borrower to acquire title to the Property, thisSecurity Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is i.
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the
Note,
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BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this
Security Instrument and in any Rider executed by Borrower and recorded with it.
i
(Seal)
effrey L. Morrison - Borrower
(Seal)
- Borrower
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FENNSYLVANW-Single Family--Fannie MaelFreddie Mat UNIFORM IINS1RUWNT Form 3039 1101
PA21OM-2 4/2010 original(Recorded) Copy(Branch) Copy(Customer) Page 14 or 15
07/16/2013 11:59:58 AM CUMBERLAND COUNTY Inst#201013913-Page 14 of
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JEFFREY MORRISON 05/26/2010
MELANIE L ALEXANDER
COMMONWEALTH OF PENNSYLVANIA, Cumberland County ss.-
On
s:On this the 26th day of May 2010 before me,
David M. Pinder ,the undersigned officer, personally appeared
Jeffrey L. Morrison i
known to me(or satisfactorily proven)to be the person(s)whose name(s) is subscribed i
to the within instrument and acknowledged that he executed the same for the
purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My Commission expires:
COMMONWE&TH OF PENNSYLVANIA
Noladal Seal -�
DaM Ki finder,Notwy PukftSusqualvrm op ry Public
E►pkesMarch a20�t Certification of Lender(Mortgagee)Address.
Aiember,Pennsylvania AssodaVan of Nolades
I hereby certify that the precise address of the Lender(Mortgagee)is: 950 Walnut Bottom Road
Suite 16 Carlisle, Pa. 17015
On behalf of the Lender. By: Kimberly A. RodgersTitle Branch Account Manager
PENNSYLVANIA-Single Family—Fade MaeWiedde Nine UNWORN iNSTRUNWWr Form 3039 IMI
PA21OM-2 4/2010 Origianl(Recorded) Copy(Branch) Copy(Customer) Pagc 13 of 15
(Space Below This Una Reserved For Lender and Recorder)
i
Commonwealth of Pennsylvania
ss.
County of
Recorded on this day of in the Office for
Recording Deeds of said County, in Mortgagee Book No. Page
RECORDER
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nen fi77013 11.59:58 AM CUMBERLAND COUNTY InstA 201013913-Page 15 of 1
Exhibit D
Inst. # 201340064 - Page 3 of 3
ROBERT P. ZIEGLER
RECORDER OF DEEDS '
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370 -
Instrument Number-201340064
Recorded On 12/23/2013 At 9:24:02 AM Total Pages-3
*Instrument Type-ASSIGNMENT OF MORTGAGE
Invoice Number- 153516 User ID-RZ
•Mortgagor-MORRISON,JEFFREY L
•Mortgagee-CITIFINANCIAL SERVICING LLC
"Customer- SIMPLIFILE LC &RECORDING
"FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS/ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES - $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $15.00 This page is now part
FEES of this legal document.
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $55.50
I Certify this to be recorded
in Cumberland County PA
of CU
RECORDER OF DEEDS
�nso
*-Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
Inst. # 201340064 - Page 1 of 3
CERTIFIED PROPERTY IDENTIFICATION NUMBERS
Prepared By/Return To: 29-05-0425-067 - NORTH MIDDLETON
p CCGIS REGISTRY 12/23/2013 BY TS
E.Lance/NTC,2100 Alt.19 North,
Palm Harbor,FL 34683
(800)346-9152
CFNA Unique
Tax Code/PIN/UPI#:29-05-0425-067
ASSIGNMENT OF MORTGAGE
FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the
undersigned, CFNA RECEIVABLES (PA), INC. F/K/A CITIFINANCIAL SERVICES, INC., A
PENNSYLVANIA CORPORATION, WHOSE ADDRESS IS 300 ST. PAUL PLACE, LEGAL
DEPARTMENT- 17TH FLOOR, BALTIMORE,MD, 21202, (ASSIGNOR), by these presents does convey,
grant, assign, transfer and set over the described Mortgage therein together with all interest secured thereby, all
liens, and any rights due or to become due thereon to CITIFINANCIAL SERVICING LLC,A DELAWARE
LIMITED LIABILITY COMPANY, WHOSE ADDRESS IS 300 ST. PAUL PLACE LEGAL
DEPARTMENT- 17TH FLOOR, BALTIMORE, MD 21202 (800)249-2181, ITS SUCCESSORS AND
ASSIGNS,(ASSIGNEE).
Said Mortgage dated 05/26/2010, in the amount of $27,896.13 made by JEFFREY L. MORRISON to
CITIFINACIAL SERVICES, INC.recorded on , in the Office of the Recorder of Deeds of CUMBERLAND
County,in the State of Pennsylvania,in Book,Page and/or Document#201013913.
Property is more commonly known as: 131 ECHO RD TWP.OF NORTH MIDDLETON,CARLISLE,PA 17015.
Dated this 20th day of December in the year 2013
CFNA RECEIVABLES (PA), INC. F/K/A CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION
-2�L�
By: / -
NADINE HOMAN
VICE PRESIDENT
All Authorized Signatories whose signatures appear above are employed by NTC and have reviewed this
document and supporting documentation prior to signing.
CIF, K AND FC 3 N1 D EFRMPA1
111111 IIIII IIIII 11111 11111 11111 11111 11111 1111 1111 11111111 Iill hill 11111 11111 lllli lilll 11111 illll 11111 11111 1111 1111
Inst. # 201340064 - Page 2 of 3
CFNA Uniquf
STATE OF FLORIDA COUNTY OF PINELLAS
The foregoing instrument was acknowledged before me on this 20th day of December in the year 2013,by Nadine
Homan as VICE PRESIDENT of CFNA RECEIVABLES(PA),INC.F/K/A CITIFINANCIAL SERVICES,INC.,
A PENNSYLVANIA CORPORATION,who,as such VICE PRESIDENT being authorized to do so,executed the
foregoing instrument for the purposes therein contained.He/she/they is(are)personally known to me.
Nicole Baldwin
?&ALLIT)A�'
Notary Public State of Florida
NICOLE BALDWIN-NOTARY PUBLIC My Commission EE 222285
44"®r Expires Auguss t 5,2016
COMM EXPIRES: 08/05/2016
Assignment of Mortgage from:
CFNA RECEIVABLES (PA), INC. F/K/A CITIFINANCIAL SERVICES, INC., A PENNSYLVANIA
CORPORATION, WHOSE ADDRESS IS 300 ST. PAUL PLACE, LEGAL DEPARTMENT- 17TH
FLOOR,BALTIMORE,MD,21202,(ASSIGNOR),
to:
CITIFINANCIAL SERVICING LLC, A DELAWARE LIMITED LIABILITY COMPANY, WHOSE
ADDRESS IS 300 ST.PAUL PLACE LEGAL DEPARTMENT- 17TH FLOOR,BALTIMORE,MD 21202
(800)249-2181,ITS SUCCESSORS AND ASSIGNS,(ASSIGNEE)
Mortgagor:JEFFREY L.MORRISON
When Recorded Return To:
CitiFinancial,Inc.
C/O Nationwide Title Clearing,Inc.2100 Alt. 19 North
Palm Harbor,FL 34683
All that certain lot or piece of ground situated in
Mortgage Premise: 131 ECHO RD TWP.OF NORTH MIDDLETON
CARLISLE,PA 17015
CUMBERLAND
(Borough or Township,if stated),Commonwealth of Pennsylvania.
Being more particularly described in said Mortgage.
Certificate of Residence
I,Nadine Homan,do certify that the precise address of the within named Assignee is:
CITIFINANCIAL SERVICING LLC, A DELAWARE LIMITED LIABILITY COMPANY, WHOSE
ADDRESS IS 300 ST.PAUL PLACE LEGAL DEPARTMENT- 17TH FLOOR,BALTIMORE,MD 21202
(800)249-2181,ITS SUCCESSORS AND ASSIGNS,(ASSIGNEE)
NADINE HOMAN
VICE PRESIDENT
All Authorized Signatories whose signatures appear above are employed by NTC and have reviewed this
document and supporting documentation prior to signing.
—.F AND FC 3 NI D -21 EFRMPA1
1111111111111111111111111 IN 1111 111111111111111111111111111 IIIA 1111111111111111111111111 IN 1111
Exhibit E
ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland
County, Pennsylvania,bounded and described according to survey of Stephen G. Fisher,
Surveyor,dated July 22, 1983 as follows:
BEGINNING at a point in Echo Road,T-427; thence North 31 degrees 25 minutes 53 seconds
East, 189.72 feet to a railroad spike set;thence by land now or formerly of Robert McGinty and
passing through a private dirt lane, South 88 degrees 45 minutes East,91 feet to an iron pin;
thence by land now or formerly of Robert McGinty, South 27 degrees 30 minutes East_ 171 feet
to an iron pin set;thence by land now or formerly of Louis E.Hair, South 88 degrees 15 minutes
West,269 feet to a point in Echo Road,T-427, point and place of BEGINNING.
WITH improvements thereon erected and containing 28,177.575 square feet.
BEING the same premises which Dolores A.Losch,Administrator of the Estate of David W.
Shenk,late, by Deed dated March 3,2000 and recorded March 7,2000 in the Office of the
Recorder of Deeds in and for Cumberland County in Deed Book 217,Page 236, granted and
_ conveyed unto Darrell W. Maddy and Karen S. Maddy,husband and wife,the Grantors herein.
Exhibit F
70121640000135023090
Date: 4/15/2013
JEFFREY MORRISON
131 ECHO RD
CARLISLE, PA 17015
RE: Property Address: 131 ECHO RD
CARLISLE, PA 17015
OneMain Financial, Inc., a Delware corporation Loan#
ACT 91 NOTICE
TAS ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender
intends to foreclose. Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
(HEMAP) may be able to help save your home. This Notice explains how the program
works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE.
Take this Notice with you when you meet with the Counseling Agency.
The name, address, and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of the Notice. If you have any questions, you
may call the Pennsylvania Housing Finance Agency toll-free at(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 NOTIFICACI6N 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 ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE 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.
HOMEOWNER'S NAME(S): JEFFREY MORRISON
MELANIE ALEXANDER
PROPERTY ADDRESS: 131 ECHO RD
CARLISLE,PA 17015
LOAN ACCT.NO.:
ORIGINAL LENDER: CitiFinancial Services, Inc.
CURRENT LENDER/SERVICER: OneMain Financial,Inc.,a Delware corporation
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR
HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE
PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE.
THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT"EXPLAINS
HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit
counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty(30)
days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer
credit counseling agencies for the county in which the property is located are set forth at the end of this
Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your
intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth
later in this Notice(see following pages for specific information about the nature of your default). You have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program.
To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for the program, and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the
lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within
thirty(30)days of your face-to-face meeting with the counseling agency.
YOUSHOULD FILER HEMAPAPPLICA TIONASSOONAS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN
APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE
TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE,IN THE SECTION CALLED"TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF
YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty(60)days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE.IF YOU ARE CURRENTLY PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE
PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED
AS ANATTEMPT 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:
131 ECHO RD
CARLISLE,PA 17015
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
7/10/2012 through 8/9/2012 1 @$327.04/month
1 @$20.00/late charge/month $347.04
8/10/2012 through 5/9/2013 9 @$501.54/month
8 @$33.11/late charge/month $4,778.74
Other charges:
Previous Late Charge(s): $284.88
TOTAL AMOUNT PAST DUE: $5,125.78
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$5,125.78 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:
OneMain Financial,Inc.,a Delware corporation
605 Munn Road
Fort Mill,SC 29715
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 attorneys' fees
actually incurred by the lender even if they exceed$50.00. Any attorney's fees will be added to the amount you owe the
lender,which may also include other reasonable costs. If you cure the default within the THIRTY(30)DAY period,
you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and
prevent the sale at any time up to.one hour before the Sheriffs Sale. You may do so by paying the total amount then
past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure
sale, and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any
other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such a Sheriffs Sale of
the mortgaged property could be held would be approximately 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: OneMain Financial,Inc.,a Delware corporation
Address: 605 Munn Road
Fort Mill,SC 29715
Phone Number: 877-622-1611 EXT.0340787 7 am-8 pm CST
TTY Services are also available. To access:Dial 711 from the United States or Dial
1-866-280-2050 from Puerto Rico.
Fax Number: 866-714-4160
Contact Person: Barbara Moore
E-Mail Address: RECustomerservice@citi.com
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You may not sell or transfer your home to a buyer or transferee who will assume
the mortgage debt,provided that all the outstanding payments,charges, and attorney's fees and costs are paid prior to or
at the sale and that 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 OTI=IER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER-
* TO SEEK.PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCA'T'ED ON THE
ATTACHED LIST.
Sincerely,
OneMain Financial,Inc.,a Delware corporation
605 Munn Road
Fort Mill,SC 29715
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated. 1/25/2013
CCCS of Western PA
55 Clover Hill Road
Dallastown PA 17313
888.511.2227/888.511.2227
CCCS of Western PA
114 N Hanover St
Carlisle PA 17013
888.511.2227
Community Action Commission - Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
Harrisburg Fair Housing Council
2100 N 6th St
Harrisburg PA 17110
717.23 8.9540
Housing&Redevelopment Authority-Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907/717.249.0789
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
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Date: 4/15/2013
JEFFREY MORRISON
131 ECHO RD
CARLISLE, PA 17015
RE: Property Address: 131 ECHO RD
CARLISLE, PA 17015
OneMain Financial, Inc., a DeIware corporation Loan#
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 EMERGENCY 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 the Notice. If you have any questions,you
may call the Pennsylvania Housing Finance Agency toll-free at(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, DUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDIATAMENTE LLA.MANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER
ELEGIBLE PARA UN PRtSTAMO 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.
HOMEOWNER'S NAME(S): JEFFREY MORRISON
MELANIE ALEXANDER
PROPERTY ADDRESS: 131 ECHO RD
CARLISLE,PA 17015
LOAN ACCT.NO.:
ORIGINAL LENDER: CitiFinancial Services,Inc.
CURRENT LENDER/SERVICER: OneMain Financial,Inc.,a Delware corporation
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR
HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE
PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983(THE"ACT''),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE.
THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS
HOW TO BRING YOUR.MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit
counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty(30)
days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer
credit counseling agencies for the county in which the property is located are set forth at the end of this
Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your
intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth
later in this Notice(see following pages for specific information about the nature of your default). You have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program.
To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for the program, and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the
lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within
thirty(30)days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE HEMAP APPLICA TIONAS SOONAS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN
APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE
TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE,IN THE SECTION CALLED"TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF
YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty(60)days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE:IF YOU ARE CURRENTLY PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE
PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED
AS ANA TTEMPT 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:
131 ECHO RD
CARLISLE, PA 17015
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
7/10/2012 through 8/9/2012 1 @$327.04/month
1 @$20.00/late charge/month $347.04
8/10/2012 through 5/9/2013 9 @$501.54/month
8 @$33.11/late charge/month $4,778.74
Other charges:
Previous Late Charge(s): $284.88
TOTAL AMOUNT PAST DUE: $5,125.78
HOW TO CARE 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$5,125.78 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:
OneMain Financial,Inc.,a Delware corporation
605 Munn Road
Fort Mill,SC 29715
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 attorneys' 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 perfonning any
other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE -It is estimated that the earliest date that such a Sheriff's Sale of
the mortgaged property could be held would be approximately 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: OneMain Financial,Inc.,a Delware corporation
Address: 605 Munn Road
Fort Mill,SC 29715
Phone Number: 877-622-1611 EXT.0340787 7 am-8 pm CST
TTY Services are also available. To access:Dial 711 from the United States or Dial
1-866-280-2050 from Puerto Rico.
Fax Number: 866-7144160
Contact Person: Barbara Moore
E-Mail Address: RECustomerservice@citi.com
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale,a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You may not sell or transfer your home to a buyer or transferee who will assume
the mortgage debt,provided that all the outstanding payments,charges, and attorney's fees and costs are paid prior to or
at the sale and that other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCATED ON THE
ATTACHED LIST.
Sincerely,
OneMain Financial, Inc.,a Delware corporation
605 Munn Road
Fort Mill, SC 29715
HEMAP Consumer Credit CounselingAizencies
CUMBERLAND County
Report last updated: 1/25/2013
CCCS of Western PA
55 Clover Hill Road
Dallastown PA 17313
888.511.2227/888.511.2227
CCCS of Western PA
114 N Hanover St
Carlisle PA 17013
888.511.2227
Community Action Commission - Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
Harrisburg Fair Housing Council
2100 N 6th St
Harrisburg PA 17110
717.23 8.9540
Housing&Redevelopment Authority- Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907/717.249.0789
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
Pennsylvania Interfaith Community Programs,Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
1664 THE COURTS
FORM 1
CITIFINANCIAL SERVICING, LLC IN THE COURT OF COMMON PLEAS
1000 Technology Drive CUMBERLAND COUNTY,
O'Fallon, MO 63368, PENNSYLVANIA
Plaintiff, ! �_
Vs. ! C '
Jeffrey L. Morrison a/k/a Jeffrey Morrison > e3 C) ,
131 Echo RoadT
Carlisle, PA 17015, >C-) -
Defendant `"t
c~
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSUI
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your
home.
If you own and live in the residential property which is the subject of this foreclosure
action, you may be able to participate in a court-supervised conciliation conference in an effort to
resolve this matter with your lender.
If you do not have a lawyer,you must take the following steps to be eligible for a
conciliation conference. First,within twenty (20) days of your receipt of this notice, you must
contact MidPenn Legal Services at(717) 243-9400 extension 2510 or(800) 822-5288 extension
2510 and request appointment of a legal representative at no charge to you. once you have been
appointed a legal representative, you must promptly meet with that legal representative within
twenty(20) days of the appointment date. During that meeting, you must provide the legal
representative 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
PENNSYLVANIA BULLETIN,VOL.42,NO.13,MARCH 31.,2012
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.
Resp ctfully submitted:
-SACJ
Date Robert W. Williams, Esquire
Milstead& Associates, LLC
1 E. Stow Road
Marlton,NJ 08053
856-482-1400
856-482-9190 (f)
PENNSYLVANIA BULLETIN,VOL.42,NO.13,MARCH 31,2012
THE COURTS 1.665
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances
to determine possible options while working with your
Please provide the following information to the best of your knowledge:
CUSTOMER .. , . APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes❑No❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes❑No❑
Mailing Address(if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes&Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy?Yes❑No❑
88.27118
PENNSYLVANIA BULLETIN,VOL.42,NO. 13,MARCH 31,2012.
1666 THE COURTS
If yes,provide names,location of court,case number&attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile#1:Model: Year:
Amount Owed: Value:
Automobile#2: Model: Year:
Amount Owed: Value:
Other transportation(automobiles,boats,motorcycles): Model:
Year: Amount Owed: Value
Monthly Income
Name of Employees:
1.
2.
3.
Additional Income Description(not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2° Mortgage Utilities
Car Payment(s)) Condo/Neigh.Fees
Auto Insurance Med.(not covered)
Auto fuel/repairs Other prop.payment
Install. Loan Payments Cable TV
Child Su ort/Alim. Spending Money
Day/Child Care/Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income&Expenses:
Have you been working with a Housing Counseling Agency?
Yes❑No❑
If yes,please provide the following information:
Counseling Agency:
Counselor:
Phone(Office): Fax:
88.27118 2
PENNSYLVANIA BULLETIN,VOL.42,NO.13,MARCH 31,2012
THE COURTS 1667
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)assistance?
Yes ❑ No ❑
If yes,please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes,please indicate the status of those negotiations:
Please provide the following information,if know,regarding your lender or lender's loan servicing company:
Lender's Contact(Name): Phone:
Servicing Company(Name):
Contact: Phone:
AUTHORIZATION
I/We, ,authorize the above
named to use/refer this information to my lender/servicer for the sole purpose of
evaluating my financial situation for possible mortgage options.I/We understand that Uwe am/are under no
obligation to use the services provided by the above named
Borrower Signature Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and lender's counsel:
✓ Proof of income
✓ Past 2 bank statements
✓ Proof of any expected income for the last 45 days
✓ Copy of a current utility bill
✓ Letter explaining reason for delinquency and any
supporting documentation(hardship letter)
✓ Listing agreement(if property is currently on the
market)
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
,YF f.
f.,r THE PRO T HONG 4 :
1 JUN -4 PM 3: 1 5
ruMSERLAND COUNT'
PENNSYLVANIA
Citifinancial Servicing, LLC
vs.
Jeffrey L Morrison
Case Number
2014-3054
SHERIFF'S RETURN OF SERVICE
05/23/2014 08:30 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Jessica Mummert, Roommate, who accepted as
"Adult Person in Charge" for Jeffrey L Morrison at 131 Echo Road, North Middleton Township, Carlisle,
PA 17015.
DAWN KELL, DEPUTY
SHERIFF COST: $34.78 SO ANSWERS,
May 27, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoft. Inc.
CITIFINANCIAL SERVICING, LLC : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 2014-3054 CIVIL TER%
-
JEFFREY L. MORRISON a/k/a •
---
JEFFREY
JEFFREY MORRISON, : IN MORTGAGE FORECLOSURE v
Defendant --0
(--)
c;, r�
REQUEST FOR CONCILIATION CONFERENCE
. Pursuant to the Administrative Order dated February 28, 1012 governing the
Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned
hereby certifies as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and have taken all of the steps required in that Notice to be
eligible to participate in a court -supervised conciliation conference.
CD
C.)
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating
to unsworn falsification to authorities.
Sign
Legal
re of Defendants' Counsel/Appointed Date
epresentati e
--7/)1)1
/tffey
nature of defendant Date
CERTIFICATE OF SERVICE
I, James M. Robinson, Esquire hereby certify that I served a true and correct
copy of the Request for Conciliation Conference by first class, postage pre -paid and
depositing same in the United States Mail, first class, postage pre -paid on the 17th day
of July, 2014, from Carlisle, Pennsylvania, addressed as follows:
Robert W. Williams, Esquire
Milstead & Associates, LLC
1 East Stow Road
Marlton, NJ 08053
TORO ROBINSON ATTORNEYS AT LAW
Ja M. Robi on, Esquire
12 • • outh Pitt treet
Carlisle, PA 17 1 13
(717) 245-9688
Supreme Court I.D. No. 84133
Attorney for the Defendant
CITIFINANCIAL SERVICING, LLC,
Plaintiff
v.
JEFFREY L. MORRISON a/k/a
JEFFREY MORRISON,
Defendant
In Forma Pauperis Form
• • IN THE COURT OF COMMON PLEAS OF
• CUMBERLAND COUNTY PENNSYLVANIA
NO.2014-3054
CIVIL TERM
IN MORTGAGE FORECLOSURE
C) r'
rn c
erWn I-
r'`
CD -�r3
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Jeffrey L. Morrison a/k/a Jeffrey Morrison, Defendant, to proceed in forma pauperis.
I, James M. Robinson, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe
the party is unable to pay the costs and that I am providing free legal services to the party.
Jamel�I. Robinson, (quire
Turo Robinson Attorneys at Law
Attorney for Defendant
129 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
CITIFINANCIAL SERVICES LLC, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI
vs. CIVIL ACTION c
fir'' C..NO. 14-3054 CIVIL `-'
JEFFREY L. MORRISON a/k/a cnC NI ''
JEFFREY MORRISON, ( Z c....) `
Defendant >c) V cD -1
5z,a
CASE MANAGEMENT ORDER
XF
AND NOW, this 0214.t- day of July, 2014, the parties having agreed to a conciliation
conference, it is hereby ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court -supervised
Conciliation Conference on j O4e, oaf ad/y at d: OZ) D. m. in
Chambers No. 4 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 within the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
obert W. Williams, Esquire
Milstead & Associates, LLC
1 East Stow Road
Marlton, NJH 08053
For the Plaintiff
/Jes M. Robinson, Esquire
28South Pitt Street
Carlisle, PA 17013
For the Defendant
:rim
iEs atatiEL
y��3py
BY THE COURT,
CITIFINANCIAL SERVICES LLC, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI
vs.
JEFFREY L. MORRISON a/Ida
JEFFREY MORRISON,
Defendant
: CIVIL ACTION
: NO. 14-3054 CIVIL
ORDER
AND NOW, this hi day of September, 2014, the conciliation conference in this
matter set for September 12, 2014, is continued to Friday, September 19, 2014, at 3:00 p.m. in
Chambers of the undersigned.
Robert W. Williams, Esquire
Milstead & Associates, LLC
1 East Stow Road
Marlton, NJH 08053
For the Plaintiff
M. Robinson, Esquire
129 South Pitt Street
Carlisle, PA 17013
For the Defendant
es, fiLa..1
9/ cf
`re)
BY THE COURT,
CITIFINANCIAL SERVICES LLC, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI
vs.
JEFFREY L. MORRISON a/k/a
JEFFREY MORRISON,
Defendant
AND NOW, this
CIVIL ACTION
NO. 14-3054 CIVIL
ORDER
2 a day of September, 2014, after conciliation conference, the,
parties being in agreement that materials necessary for a review by the plaintiff will be
forthcoming within 14 days, continued conciliation conference herein is set for Friday,
November 14, 2014 at 1:45 p.m.
Robert W. Williams, Esquire
Milstead & Associates, LLC
1 East Stow Road
Marlton, NJH 08053
For the Plaintiff
..Taines M. Robinson, Esquire
129 South Pitt Street
Carlisle, PA 17013
For the Defendant
alp es fl(L I. LE_
BY THE COURT,
)
Fri
r-
<
CITIFINANCIAL SERVICES LLC, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI
vs. : CIVIL ACTION
JEFFREY L. MORRISON a/k/a
JEFFREY MORRISON,
Defendant
AND NOW, this / 7
: NO. 14-3054 CIVIL
ORDER
day of November, 2014, after conciliation conference, it
appearing that the plaintiff is insisting on additional documentation, same will be provided
within seven (7) days. Continued conciliation conference is set in this matter for Monday,
December 29, 2014, at 3:30 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevi A. Hess, P.J.
Xathan Wolf, Esquire
10 West High Street
Carlisle, PA 17013
For the Plaintiff
Ziames M. Robinson, Esquire
129 South Pitt Street
Carlisle, PA 17013
For the Defendant
:rim
J! 7/I /