HomeMy WebLinkAbout14-3311 Supreme Court tof Pennsylvania
Cou et'of,Common\Pleas For Prothonotary Use Only.•
Civil"'Cove,Shtpt
Docket No:
I j F
cu rnbey lay
.X County J
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S M Complaint l] Writ of Summons 0 Petition
E] Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T Deutsche Bank National Trust Company et al. Kali L. Pinder and David M. Pinder
Dollar Amount Requested: Owithin arbitration limits
I Are money damages requested? El Yes El No (check one) Qoutside arbitration limits
O
N Is this a Class Action Suit? El Yes l9 No Is this an MDJAppeal? 0 Yes 0 No
A Name of Plaintiff/Appellant's AtterneyEdward J McKPe
El Check here if you have no attorney(are a Self-Represented [Pro Sel Litigant)
Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim,check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT (do not include.judgments) CIVIL APPEALS
El Intentional l Buyer Plaintiff Administrative Agencies
El Malicious Prosecution ll Debt Collection: Credit Card Q Board of Assessment
Motor Vehicle El Debt Collection: Other Board of Elections
F]Nuisance E] Dept.of Transportation
E] Premises Liability El Statutory Appeal:Other
S Q Product Liability(does not include
E mass tort) El Employment Dispute:
El Slander/Libel/Defamation Discrimination
C ll Other: l]Employment Dispute:Other El Zoning Board
T, ®i Other:
I l] Other:
O MASS TORT
Asbestos
N Tobacco
Toxic Tort-DES
Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste
Other: l�Ejectment 0 Common Law/Statutory Arbitration
B Eminent Domain/Condemnation 0 Declaratory Judgment
Ground Rent ll Mandamus
El Landlord/Tenant Dispute El Non-Domestic Relations
El Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY El Mortgage Foreclosure:Commercial 0 Quo Warranto
D Dental El Partition ll Replevin
Q Legal [3 Quiet Title E]Other:
E] Medical Other:
Other Professional:
Updated 1/1/2011
STEVEN K. EISENBERG,ESQUIRE(75736)
M.TROY FREEDMAN,ESQUIRE(85165)
LESLIE J. RASE,ESQUIRE(58365)
CHRISTINA C.VIOLA,ESQUIRE(308909)
� • S i +�
ANDREW J. MARLEY,ESQUIRE(312314) `i
��Er' �
STERN&EISENBERQ PC 7 , ,ND Co
1581 MAIN STREET, SUITE 200 � �„��
THE SHOPS AT VALLEY SQUARE
WARRINGTON,PA 18976
TELEPHONE: (215)572-8111
FACSIMILE: (215)572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee Civil Action Number:
for Residential Asset Securitization Trust Series
2006-A7CB Mortgage Pass-Through Certificates
Series 2006-G, by its servicer Ocwen Loan
Servicing, LLC Complaint in Mortgage Foreclosure
1661 Worthington Road �l✓�
Suite 100
West Palm Beach, FL 33409
(Plaintiff)
V.
Kali L. Pinder
118 Pearl Drive
Carlisle, PA 17013-1044
And
David M. Pinder
118 Pearl Drive
Carlisle, PA 17013-1044
(Defendant(s))
CIVIL ACTION- MORTGAGE FORECLOSURE
This is an attempt to collect a debt and any information obtained will be used for that purpose.
NOTICE
You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must
take action within twenty (20) days after this Civil Action and notice are served, by entering a writter
appearance personally or by attorney and filing in writing with the Court your defense or objections to th S
claims set forth against you. q)D? 7:<
CL k V 32
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 Civil Action or for any other
claim or relief requested by the plaintiff. You may lose money or property of other rights important to you.
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
(800) 990-9108
STEVEN K.EISENBERG,ESQUIRE(75736)
M.TROY FREEDMAN,ESQUIRE(85165)
LESLIE J. RASE,ESQUIRE(58365)
CHRISTINA C.VIOLA,ESQUIRE(308909)
ANDREW J. MARLEY,ESQUIRE(312314)
STERN&EISENBERG, PC
1581 MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON,PA 18976
TELEPHONE: (215)572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee Civil Action Number:
for Residential Asset Securitization Trust Series
2006-A7CB Mortgage Pass-Through Certificates
Series 2006-Q by its servicer Ocwen Loan
Servicing, LLC Complaint in Mortgage Foreclosure
1661 Worthington Road
Suite 100
West Palm Beach, FL 33409
(Plaintiff)
V.
Kali L. Pinder
118 Pearl Drive
Carlisle, PA 17013-1044
And
David M. Pinder
118 Pearl Drive
Carlisle, PA 17013-1044
(Defendant(s))
CIVIL ACTION—MORTGAGE FORECLOSURE
NOTICE AVISO
You have been sued in court. If you wish to defend Le han demandado a usted en la corte. Si usted
against the claims set forth in the following pages, quiere defenderse de estas demandas expuestas en las
you must take action within twenty (20) days after paginas siguientes, usted tiene veinte (20) dias de
this complaint and notice are served by entering a plazo al partir de la fecha de la demanda y la
written appearance personally or by attorney and notificacion. Hace falta asentar una comparencia
filing in writing with the court your defenses or escrita o en persona o con un abogado y entregar a la
objections to the claims set forth against you. You corte en forma escrita sus defensas o sus objeciones a
are warned that if you fail to do so the case may las demandas en contra de su persona. Sea avisado
proceed without you and a judgment may be entered que si usted no se defiende, la corte tomara medidas
against you by the court without further notice for y puede continuar la demanda en contra suya sin
any money claimed in the complaint or for any other previo aviso o notificacion. Ademas, la corte puede
claim or relief requested by the plaintiff. You may decidir a favor del demandante y requiere que usted
lose money or property or other rights important to cumpla con todas las provisiones de esta demanda.
you. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A Lleva esta demanda a un abogado inmediatamente.
LAWYER, OR CANNOT AFFORD ONE, GO TO Si no tiene abogado o si no tiene el dinero suficiente
OR TELEPHONE THE OFFICE SET FORTH de pagar tal servicio, vaya en persona o llame por
BELOW TO FIND OUT WHERE YOU CAN GET telefono a la oficina cuya direccion se encuentra
LEGAL HELP. THIS OFFICE CAN PROVIDE escrita abajo para averiguar donde se puede
YOU WITH INFORMATION ABOUT HIRING A conseguir asistencia legal.
LAWYER.
IF YOU CANNOTAFFORD TO HIREA
LAWYER, THIS OFFICE MAYBEABLE TO
PROVIDE YOU WITH INFORMATIONABOUT
AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS ATA
REDUCED FEE OR NO FEE.
Lawyer Referral and Information Service
(Asociacion de Licenciados Servicio de Referencia e Informacion Legal)
Cumberland County Bar Association
Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
(800) 990-9108
NOTICE PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT
TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.
You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30)
days of receipt of this letter, this firm will obtain and provide you with written verification thereof;
otherwise,the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of
this letter, this firm will send you the name and address of the original creditor if different from above.
IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE
ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A DISCHARGE
IN BANKRUPTCY(AFTER ENTERING INTO THE RELEVANT MORTGAGE NOTE AND
MORTGAGE (OR OTHER SECURED OBLIGATION)AND HAVE NOT REAFFIRMED THE DEBT)
THEN THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT
TO COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE MORTGAGE/LIEN
AGAINST REAL PROPERTY(SECURED PROPERTY).
STEVEN K.EISENBERG,ESQUIRE(75736)
M.TROY FREEDMAN,ESQUIRE(85165)
LESLIE J. RASE,ESQUIRE(58365)
CHRISTINA C.VIOLA,ESQUIRE(308909)
ANDREW J. MARLEY,ESQUIRE(312314)
STERN&EISENBERQ PC
1581 MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON,PA 18976
TELEPHONE: (215)572-8111
FACSIMILE: (215)572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee Civil Action Number:
for Residential Asset Securitization Trust Series
2006-A7CB Mortgage Pass-Through Certificates
Series 2006-Q by its servicer Ocwen Loan
Servicing, LLC Complaint in Mortgage Foreclosure
1661 Worthington Road
Suite 100
West Palm Beach, FL 33409
(Plaintiff)
V.
Kali L. Pinder
118 Pearl Drive
Carlisle, PA 17013-1044
And
David M. Pinder
118 Pearl Drive
Carlisle, PA 17013-1044
(Defendant(s))
COMPLAINT
CIVIL ACTION—MORTGAGE FORECLOSURE
1. Plaintiff is Deutsche Bank National Trust Company as Trustee for Residential Asset Securitization
Trust Series 2006-A7CB Mortgage Pass-Through Certificates Series 2006-Q by its servicer Ocwen
Loan Servicing, LLC (hereinafter referred to as "Deutsche Bank National Trust Company as Trustee
") with offices located at 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409.
2. The Defendant(s), Kali L. Pinder and David M. Pinder, adult individuals with a last-known address of
118 Pearl Drive, Carlisle, PA 17013-1044.
3. Under the date of 03/23/2006, defendants, Kali L Pinder and David M. Pinder, executed and
delivered to MERS, Inc. as nominee for Indy Mac Bank, F.S.B., a Federally Chartered Savings Bank
a mortgage upon the property 118 Pearl Drive, Carlisle, PA 17013 (the "Property")to secure the
payment of the sum of$124,800.00. The said mortgage is recorded in the Office for the Recorder of
Deeds in and for Cumberland County, Pennsylvania on 03/30/2006, at Book 1945 at Page 0369, and
is incorporated herein by reference as though set forth at length herein. A true and accurate copy of
said Mortgage is attached hereto and made a part hereof as Exhibit "A".
4. Assignment transferring the mortgage originally with MERS, Inc. as nominee for IndyMac Bank,
F.S.B., a Federally Chartered Savings Bank (Originating Lender) as follows:
i. Assignment from Mortgage Electronic Registration Systems, Inc.,(MERS) solely as nominee for
IndyMac Bank, F.S.B., a Federally Chartered Savings Bank to Deutsche Bank National Trust
Company, as Trustee For Residential Asset Securitization Trust Series 2006-A7CB, Mortgage
Pass-Through Certificates Series 2006-Q under the pooling and servicing agreement dated
05/01/2006 was recorded on 12/3/2012, in instrument 201237388, was recorded in the Office of
the Recorder of Deeds of Cumberland County, Pennsylvania.
5. Kali L. Pinder and David M. Pinder are the real owners of Property 118 Pearl Drive, Carlisle, PA
17013.
6. In accordance with Pennsylvania law,the required pre-foreclosure notice (under Act 91/Act 6 as may
be applicable), was sent to the defendant(s) and no response was made in the appropriate period of
time. A true and correct copy of the aforesaid notice is attached hereto, made a part hereof, and
marked as Exhibit`B".
7. The said loan is in default as a result of the failure to pay the monthly installment of$768.42 due on
08/01/2012 and each month thereafter.
8. The following is due on the loan:
PRINCIPAL BALANCE:..................................................................$113,828.14
INTEREST TO THE DATE OF THE 03/11/2014
(CURRENTLY A PER DIEM OF $19.76).......................................$12,054.62
ESCROW ADVANCES: ...................................................................$5,808.21
PROPERTY INSPECTION: .............................................................$10.50
PRIOR SERVICER AMOUNTS:......................................................$3,254.12
LATE CHARGES ACCRUED TO 03/11/2014 OF: .........................$773.66
(LATE CHARGES AFTER 03/11/2014 SHALL ACCRUE AT THE MONTHLY
RATE OF $38.42.)
LESS SUSPENSE BALANCE:........................................................($-59.22)
TOTAL DUE:....................................................................................$135,670.03
Attorney fees are allowed in conformity with the mortgage documents and Pennsylvania law, and may be
requested as part of any judgment requested and collected in the event of a third party purchaser at Sheriffs
Sale. If the mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work
actually performed.
F
WHEREFORE, Plaintiff, Deutsche Bank National Trust Company as Trustee requests this Court to
enter judgment, IN REM, for foreclosure of the mortgaged property in the sum of$135,670.03 and all other
amounts set forth above, less any suspense as set forth above,together with record costs and any other
amounts that accrue over the course of the instant matter until judgment is paid in full and to which Plaintiff
is entitled to recover.
Respectfully Submitted:
By: 4; —1
E;d'ANGV'd 1-
Stern& Eisenberg, PC
1581 Main Street, Suite 200
The Shops at Valley Square
Warrington, PA 18976
Phone: (215) 572-8111
Facsimile: (215) 572-5025
BarNumber:
Date: ( 2R , 20
H
Re: Kali L. Pinder and David M. Pinder
118 Pearl Drive, Carlisle, PA 17013
VERIFICATION
I, Lori Ann Dasch, the undersigned, Contract Management Coordinator, of Ocwen Loan
Servicing, LLC ("Ocwen"), the duly authorized servicing agent for Deutsche Bank National Trust Company
as Trustee for Residential Asset Securitization Trust Series 2006-A7CB Mortgage Pass-Through Certificates
Series 2006-C, am authorized to make this verification on behalf of Ocwen and hereby certify that the facts
set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief.
Except where otherwise stated and/or based upon public record, this verification is based upon a review of
the business records regularly created, kept and maintained in the course of Ocwen's mortgage servicing
business conducted on Plaintiffs behalf.
In making this verification, I understand that it is a crime under 18 Pa.C.S. Section 4904 to make a
written statement to a public servant, or to invite a public servant's reliance upon a written statement or
instrument, which I do not believe to be true or which I to be
ame:ILori Ann Dasch
Title:Contract Management Coordinator
Deutsche Bank National Trust Company as Trustee for Residential Asset
Securitization Trust Series 2006-A7CB Mortgage Pass-Through Certificates Series
2006-Q by its servicer Ocwen Loan Servicing,LLC
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901 E. 104th Street BU-tiding B suite
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Icily,38te Z{D Code]
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MORTGAGE
MIN 100055401230881122
DFINNITIONS
Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11,
13, 18,20 end 21. Certain rules regarding the usage of words used in this document are also provided in Section 16.
(A) "Security Instrument"means this document,which is dated March 23, 2006 ,together
with all Riders to this document.
I&= NO: 123088112
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(B) "Borrower"is Kali L Pinder and David M Pinder
Borrower is the mortgagor under this Security Instrument.
(C) "MFRS"is Mortgage Electronic Registration Systems,Inc. MERS is a separate corporation that is acting
solely as a nominee for Lender and Lender's successors and assigns. MFRS Is the mortgagee larder this Security
Instrument. MERS is organized and existing under the laws of Delaware, and has an address and telephone
number of P.O.Box 2026,Flint,M1 48501-2026,tel.(888)679-MFRS.
(D) 'Lender"is In&yMac Bank, F.S.B.. a federally duwtared savings bank
Lender is a Federal Savi.W Bank ori and existing under the laws of
United states of America. . Lender's address is 155 North bake Averme, Pte,
CA 91101
(E) "Note"means the promissory note signed by Borrower and dated March 23, 2006 . The Note
stye �sver owes Lender one hundred twenty four thousand eight htu�ed and
II�`1A� Dollars (U.S. $ 129,800.00 }
plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not
later than April 1, 2036
(F) "Property" means the property that is described below under the heading "Transfer of Rights in the
Proparty:
(G) "Loan"means the debt evidenced by the Note,plus interest,any prepayment charges and late charges due
under the Note,and all sums due under this Security Instrument,plus interest.
(H) "Riders" means all Riders to this Security Instruinent that are executed-by Borrower. The following
Riders are to be executed by Borrower[check bar as'applicable]:
[j Adjustable Rate hider ❑ Condominium Rider ❑ Second Home hider
❑ Balloon Rider ❑ Planned Unit Development Rider ❑ Biweekly Payment Ruler
❑ 1-4 Family Rider ❑ Revocable Trust Rider
❑ Other(s)jspeciM
(1) "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.
(J) "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 organization.
(K) "Elodrouic Funds Transfer"means any transfer of finds,other than a transaction originated by check,
draft,or similar paper instrument,which is initiated through an electrode terminal,telephonic instrument,computer,
or magnetic tape 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.
Ivan No: 123088112
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(L) "Escrow Items"means those items that are described in Section 3.
(1VI) "Misettlaneous Proceeds"means any compensation,settlement,award of damages,cc proceeds laid by
any third party(other than insurance proceeds paid under the coverages described in Section S)far. (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 author condition ofthe Property.
(N) "Mortgage Insurance"means insurance protecting Lender against the nonpayment of,or default on,the
Loan.
(0) "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.
(F) "RESPA" means the Real Estate Settlement Procedures Ad (12 U.S.C. §2601 at seq.) and its
implementing regulation,Regulation X(24 G.P.R.Part 3300), 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"federally related mortgage loan"under RESPA.
(Q) "Successor in Interest of Borrower"mans any party that has taken title to the Property,whether or not
that party has assumed Borrower's obllgations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument 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 N ERS(solely as
nominee for Lender and Lender's successors and assigns)and to the sucec&wn and assigns of MFRS the following
described property located in the County of C w ber'lan d
[Type of Reeording.hatsdiction) [Name of Recording Jurisdiction]
Tax Parcel ID No: 1
See Exhibit "A" attached hereto and made a part hereof.
which currently has the address of 118 PEARL C TVE
[Street)
Carlisle Penosylvaria 17013 ("Property Address'):
[City) [2'ip Code)
TOGETHER WITH all the improvements now or hereafter enacted 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 understands and agrees that MERS holds only legal title to the interests granted by Borrower in this
Security Instrument,but, if necessary to comply with law or custom,MERS(as nominee for Lender and Lender's
successors and assigns)has the right to exercise any or all of those interests,including,but not limited to,the right
Loan No: 123088112
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W "Escrow Items"means those items that are described in Section 3.
(M) "Miscellaneous Proceeds"means any compensation, settlement, award of damages,or proceeds paid by
any third party(outer than insurance proceeds paid under the coverages described in Section S)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)misreMsentations of,or omissions as to,the value andfor condition of the Property.
(1) "Mortgage Insurance"paeans insurance protecting Lender against the nonpayment of,or default on,the
Loan.
(0) "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.
(P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. $2601 at seq.) and its
implementing regulation,Regulation X(24 UAL Part 3500),as they might be amended from time to time,or any
additional or successor legislation or regulation that governs the sante 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 IoW even if the Loan does not qualify as a"federally related mortgage loan"under RESPA.
(Q) "Successor in Interest of Borrower"preens any party that has taken title to the Property,whether or not
that party has assumed Borrower's obligations under the Note and/or this Security Instnnnent.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (i)the repayment of the Loan,and all renewals,extensions and
modifications of the Now; 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 MERS(solely as
nominee for Lender and Lender's successors and assigns)and to the successors and assigns of MRS the following
down-bed property located in the QXM-ty of Cwteriand
flpe of Recording Jwisdiction] [Name ofRecondfng Jurisdic#on]
Tax Parcel ID No: 1
See l�hibit "A" attached hereto and made a part hereof.
which currently has the address of 118 PEARL I7I2M
('9"eil j
Carlisle , Pennsylvania 17013 ("Property Address'
10tyi Pp Code]
TOOETHER WrM all the improvements now or hereafter erected on the property, and all eaaemmu,
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 understands and agrees that MERS holds only legal title to the interests gmaed by Borrower in this
Security Instrument,but,if necessary to comply with Iaw or custom,MERS(as nominee for Lender and Lender's
successors and assigns)has the right: to exercise any or all of those interests,including,but not limited to,the right
Trvs� No• Z23488ZZ2
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to foreclose:and sell the Property;and to take any action required of Lender including,but not limited to,releasing
and canceling this Security Instrument.
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the
right to mortgage,grant and convey the Property and that the Property is unencumbered,except for encumbrances of
accord. Borrower warrants and will defend generally the title 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 late 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 instrrtnnent 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 cheek, 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.
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 IS. Lender may
return any payment or partial payment if the payment or partial payments art Insufficient to bring the Loan current.
Lender may accept any payment or partial paymont 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 immodiately prior to foreclosure. No ofi'set or
claim which Borrower might have now or in tit future against Lender shall relieve Borrower fra m 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 r"eee ds. Except as otherwise described in this Section 2,all payments
accepted and applied by Lender shalt 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 Periodic
Paymmt 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 charge. If
more than one Periodic.Payinent 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 ager the payment is applied to the hili payment of one or snare 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 the Periodic Payments.
3. Funds for Escrow 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 Instrument as a lien or encumbrance on the
poetn Nos 1230$$112
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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 lien of the payment of Mortgage Insurance premiums in accordance with the provisions of
Section 1.0. 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 fon'Escrow Items unless Lender
waives Borrower's obligation to pay the Funds for any or all Escrow 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 directly,when and where payable,the amounts due for any Escrow
Items for which payment of Fluids has been waived by Lender and, if Lender requires, shall furnish to Lender
receipts evidencing such payment within such time period as Lendcr may require. Borrower's obligation to make
such payments and to provide receipts shall for all purposes be deemed to be a covenant and 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 bender all
Funds,and in such amounts,that are them required under this Section 3.
Lender may,at any time,collect and hold Funds In an amount(a)sufficient to permit Lender to apply the
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 currant data and reasonable estimates of
expenditures of future Escrow Items or othwMsa 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 trauma!)or in any Federal Home Loan
Bank. Lender shall apply the Funds to pay the.Escrow Items 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 Fmrds 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 make 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,Lender shall notify Borrower as required by RESPA,
and Borrower shall pay to Lander,the amount necessary to make up the deficiency in accordance with RESPA,but in
no mom than 12 monthly payments.
Upon payment in full of all sums secured by this Security Instrument,Lender shall promptly refund to
Borrower any Funds held by Lender.
4. Chants; Liens. Borrower shall pay alI 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 Duos, 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 shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) Wes in writing to the payment of the obligation secured by the lien in a manner acceptable to
Lender,but only so long as Borrower is perfom ung 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 are pending,but only until such proceedings aro concluded;or(c)secures from
the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If
Ivan No: 123088112
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Lender determines that any part of the Property is subject to a lion 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 ones-time charge for a real estate tax verification andlor reporting
service used by Lender in connection with this Loan.
& Property liuusurs:ace, Borrower shall keep the improvements now 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 exorcised unreasonably. Lender may requites Borrower to pay,in connection with this Lotus,
either: (a)a one-tune charge for flood zone determination,certification and tracking services; or(b)a Mime
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 covotagos described above,Lender may obtain insurance coverage,
at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular typo 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 3 shall become additional debt of Borrower secured by this Security
Instr;unent. These amounts shall bear interest at the Note rate from the date of disbmwment and shall be payable,
with such interest,upon notice from Leader 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 Under as mortgagee and/or as an
additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If bender 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. Lender may
make 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 oppommity to inspect such Property to ensure the work has been completed to Lender'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 othor 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.
If Borrower abandons the'Property,Lender may file,negotiate and settle any available insurance claim and
related mattes. 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
wan No: 123088112
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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 premiurns 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,whether or not them 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
beyond Borrower's control.
7. Preservation, Maintenance and Protection of the Property, Inspections, Borrower shalt 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 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. 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. 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.
8. Borrower's Loan Application. 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 to the Property and Rights Under this Security Instrument. If
(a)Borrower fails to perform the covenants and agreements contained in this Security Instrument,(b)time is a legal
proceeding that might significantly affect Lender's interest in the Property and/or rights 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 Instrument,including protecting and/or assessing the value of
the Property, and securing and/or repairing the Property. Lender's actions can include, but are not lhnited to:
(a)paying any sum's secured by a lien which has priority over this Security Instrument;(b)appearing in court and
(c)paying reasonable attorneys' 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 t ocks,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 Lewder 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 segued
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 mquesting payment.
If this Security Instrument is on a leasehold,Borrower shall comply with all the provisions of the lease. If
Borrower acquiree fee title to the Property,the leasehold and the fee title shall not merge unless Lender agrees to the
merger in writing.
1x= No: 123088112
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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 previousty
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 tate 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 payrimts 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 lien of Mortgage Intra=. 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 Ins=oe 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 font from time to time,and may enter
into agreements with other parties that share or modify their risk,or reduce losses. These agreements are on terms
and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements.
These agreements may require the mortgage insurer to make payments using any source of funds that the mortgage
insurer may have available(which may include funds obtained from Mortgage Insurance premiums).
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 Insurance, in exchange for sharing or
modifying the mortgage insurer's risk,or reducing losses. If such agreement provides that an affiliate of Lender
takes a share of the insurer's risk in exchange for a sham 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 iaerease the amount Borrowerwill owe
for Mortgage Insurance,and they will not entitle Borrowtr 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 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 hfiscetlancous Proceeds are hereby
assigned to and shalt be paid to Lender.
If the Property is damaged, such Miscellaneous Proceeds snail 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 Miscellaneous Proceeds until Lender has had
an opportuuily to inspect such Property to ensure the work has been completed to Lender's satisfaction,provided
that such inspection shall be undertaken promptly. Lender 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 made in writing
or Applicable Law requires interest to be paid on such Miscellaneous Proceeds,Lender shall not be required to pay
Borrower any interest or earnings on such Miscellaneous Proceeds. if the restoration or repair is not economically
Loran No: 123088112
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feasible or Lender's security would be lessened,the Nfiscellaneous Proceeds shall be applied to the suns secured by
this Security instrument,whether or not then due,with the excess, if any,paid to Borrower. Such Mseellaneous
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 their due,with the excess,if any,paid to
Borrower:
In the event of partial taking,destruction,or loss in value of the property in which the fair market value of
the Property immediateiy 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 bender otherwise agree in writing, the sums secured by this Security Instrument shall be
reduced by the amount of the Miscollaneous Proceeds multiplied by the following fraction: (a)the total amount of
the suras 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 shall 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,of 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.
If the Property is abandoned by Borrower,or if,after notice by Lender to Borrower that the Opposing Party
(as defined in the next sentence)offers to make an award to settle a claim for damages,Borrower fails to respond to
Lender within 30 days atter the date the notice is given,Lender is authorised to collect and apply the M'scellateous
Proceeds either to restoration or repair of the Property or to the sums swurod by this Security instrument,whether or
not then due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party
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 rights 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 bender's judgment,procludes forfeiture of the Property or other material impairment of Lender's interest in the
Property or rights under this Security Instrument, 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 Under;.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in
the order provided for in Section 2.
12, Borrower Not Released;Forbeara►nee By Lender Not a Waiver: Extension of the time for payment
or modification of amortization of the suras secured by ibis 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 Successors in
Interest of Borrower. Lender shall not be required to commence proceedings against any 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, bender'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 exercise of 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 bo 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 this Security Instrument only to
rrnortgagc,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 accotmnodations with regard to the terms of this
Security instrument or the Note without the co-signer's consent.
14= No: 123088112
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Subject to the provisions of Section 18, any Successor in Interest of Borrower who assume Borrower's
obligations under this Security Instrument in writing, and is approved by Leader, 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.
It 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
lwtrumen4 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 may not charge foes that are expressly prohibited
by this Security instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges,and 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
limits,then: (a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the pemnitted
limit; and (b) any sums ahve4 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 making 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 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 roport a change
of address though that specified procedure. There may 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 mailing 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 required under Applicable Law,the Applicable
Law requirement will satisfy the corresponding requirement under this Security Instrument,
16. Governing Law; Severahility;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. 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)wards of the 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"may"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,
1B, Transfer of the Property 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 a future date to a pruchaser.
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,
Loran No: 123088112
Pemylvants Moripp-Single Family-Fannie Mee/rudder Mn UNROAM TIVS'tR'tIYYtTrNT MFRS Mod led berm 3039 01lllt
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BX 1945PG3378
Lender may'require immediate payment in full of all sums secured by this Security lnstnunent. 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 34 days tirorn the date the notice is given in accordance with Section 15 within which
Borrower must pay all sums secured by this Security Instt r mt. If Borrower fails to pay these sums prior to the
expiration of this period,Lender may invoke any remedits permitted by this Security Insttlunent without further
notice or demand on Borrower.
19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions,Borrower
shall have the Tight to have enforcement of this Security Instrument discontinued at any time prior to the earliest of:
(a)five clays before sale of the Property pursuant to any power of sale contained in this Security lit a ritment;(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 htstrument,
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 Instrunrerrt,shall
continue unchanged, Lender may require that Borrower pay such reinstatement sums and expenses in one or more
of the following forms,as selected by Lender: (a)curb;(b)money order;(c)certified chock,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 fi str rent and obligations secured hereby shall remain fgly effective as if no acceleration had occurred.
However,this fight 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 Servioer)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 moron changes of the Loan Servicer unrelated
to a We 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 tr nsferral to a successor Loan Servicer and are
not assumed by the Now purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nun Lender may commence, join, or be joined to any judicial action (as either an
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 party 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
compliance withh the requirements of Section 15) of such alleged broach and afforded the other party hereto a
reasonable period atter 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 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 20.
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
Load Not 123068112
Perwyiventt Mort w4iO&Family-Funrte Nb lFreddk Mac UNVORM R4StRUM EW MFRS ModW"FOraE 3839 OINI
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defined in Environmental Law;and(d)an"Favironmental Conditiota"means a condition that can cause,contribute
to,or otherwise trigger an Environmental Cleanup.
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(e)which,due to the presence, use, or release of a Hazardors 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 arc 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 Leader written notice of(a)any investigation, claim, demand, lawsuit or
other action by any governmental or regulatory agency or private parry involving the Property and any Hazardous
Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition,
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 govcrruu=W or regujatory 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 EnvirolmlentO Law. Nothing herein
shall create any obligation on Lender for an Environmental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
22. Acceleration;Remedies. Lender shall give notice to Borrower prior to acceleradoli following
Borrower's breach of any covenant or agreement in this Security Instrument(but not prior to acceleration
under Section 18 unless Applicable Lowy provides otherwtse). Lender shall notify Borrower of,among other
things: (a)the default;(b)the action required to cure the default;(e)when the default moat be cured;sad(d)
that failure to cure the default as gmcifled may result in acceleration of the sums scoured by this Security
Instrument, foreclosure by judicial proceeding mad sale of the Property. Lender shall farther Worm
Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proctediag the
non-existeace of a default or any other defense of Borrower to acceleration and foredosaure. H the default is
not cured as specified,Lender at Its option may require immediate payment In full of all sums secured by this
Security Instrument without further demand and may foreclose this Security Instrument by judicial
proceeding. Leader shall be entitled to collect all expenses Incurred In pursuing the remedies provided In this
Section 22,including, but not limited to,attorneys'fees Brad costs of dtk evidence to the eateut permitted by
Applicable Law.
23. Release. Upon payment of all sums 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 Imtrurnent. 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 firture
laws providing for stay of execution,extension of time,exemption from attachment,levy and sale,and homestead
exemption.
2S. Reinstatement Period. Borrower's time to reinstate provided in Section 14 shall extend to one hour
prior to the commencement of bidding at a sheriff's sale or other We pursuant to this Security Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property,this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable atter a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the
Note.
Loan No; 123088112
Pennsyivanrw Morlog"Woc Famfly-Fannie!!1'sOftddk Mac UNMRM INSMUMM KM ModWed Form 3939 91A1
—TM CobssaMZ sounc8,INC— rage 12*1 14 14MA Nn►x r ft"
wwweeeq�iuwnoreawm �� 0300�.71teCaapnae &MEW,hx-
'01H 1945PG0380
(Stgnaft"s on FoAbwft Pegs]
BY SIGNING BELOW,Borrower accepts and agrees to the terms and covenants contained in this Seewity
Instrument and in any Rider executed by Borrower and recorded with it.
(seal)
L P.><.Ixier -B--Wa
(�.bu�tNarnej
David M P -amowe
(Prbued Name]
(seal)
-Ra
(I��tedNamej
-Bacrowor
1p"Hed Name]
Certificate of Residence:
UWe da hereby certify t the precise address of the within named mortgagee,assignee or person entitled to internes{
n
By:
Title:
(AOuVwletlgment on FoBow&rg page]
Lin No: 1230$6112
PeOWAvaeia M SuWe Famidy-Faank Ab6Wmddtr Mac Ute MRM DWMUMWr MERE M*M d I+em 3014 ON[
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BX1945PGO38I
State of '�
County of
On this,the j jkIday of It4o fu 1 2-oOYQ before me
the undersigned officer,petsooaliy..
appeared Rall. L Pinder and David M Pinder
known to me (or satisfactorily proven) to be the person(s)
whose name(s)is/are subscribed to the within instmment, and acknowledged that he/sheacy executed the same for
the purposes therein contained.
In witness whereof,I hereunto set my hand and official seal.
C�MMONWEJRLTH OF PENNSYLVANIA
s�kdsr t See
�(Seal) T%VSiwe
Wim}bq*wA'*$2008
Mwnbe(,I' aN�MrHr A-oo"m of troUAW Title of I
Ioan >o: 123088112
Pmm)Ivam%Morlpp-ShWe FaMUy-Fausk Mr vTAd&14 me LMORM 1NMUAUWr MIRS Modkted Form 3M OIAAI
--Tale C.f1 MUAN(x SoUMCF,l r-- Pkae 14 of 14 ta�aa+ww rw..yrs
naw. aoereunx cnm 1��� 0200"M Cowf uee Sam"tae.
Legal Dation
ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF NORTH
MIDDLETON IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF
PENNSYLVANIA,BEING DESCRIBED AS FOLLOWS:LOT NO.20 ON PLAN NO.
6 OF NOLL MANOR,AS RECORDED IN PLAN BOOK VOLUME 22,PAGE 163.
BEING MORE FULLY DESCRIBED IN A FEE SRAPLE DEED DATED 02/07/2000
AND RECORDED 02/09/2000;AMONG THE LAND RECORDS OF THE COUNTY
AND STATE SET FORTH ABOVE,IN VOLUME 215 PAGE 1146
BEING Parcel No.29-16-1096-012
1n CunAlu—
p-e,oj'der of Deed'
5-1945PG0383
a cr
-F G
STERN &EISENBERCT, PC
1581 MAIN STREET,SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON,PA 18976
TELEPHONE: (215)572-8111
FAcsrnm.E: (215)572-5025
Date: January 31, 2014
COMBINED NOTICE UNDER
ACT 6 and ACT 91
TAKE ACTION TO SAYE YOUR DOME
FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help
to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your
County are listed at the end of this Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397.(Persons with impaired hearing
can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The Iocal bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION -OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
EX IBIT
HOMEOWNER'S NAME(S): DAVID M PINDER,KALI L PINDER
PROPERTY ADDRESS: 118 PEARL DRIVE,CARLISLE,PA 17013
MAILING ADDRESS: DAVID M PINDER 118 PEARL DRIVE CARLISLE,PA 17013-1044
KALI L PINDER 118 PEARL DRIVE CARLISLE,PA 17013-1044
LOAN ACCT NO.: 7192270481
ORIGINAL LENDER: MFRS,INC.AS NOMINEE FOR INDY MAC BANK,F.S.B.,A FEDERALLY
CHARTERED SAVINGS BANK
CURRENT LENDER/SERVICER: DEUTSCHE BANK NATIONALTRUST COWANYAS TRUSTEE FOR
RESIDENTIALASSET SECURITIZATION TRUST SERIES 2006-A7CB MORTGAGE PASS-THROUGH
CERTIFICATES SERIES 2006-G,BY ITS SERVICER OCWEN LOAN SERVICING LLC
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 (plus three (3) days for mailing) from the date of this
Notice. 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 THE NEXT (33) DAYS. 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
desi,gnated 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
i
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.)
If you have tried and are unable to resolve this problem with the lender, 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. Your application
MUST be filed or postmarked within thirty(30) days of your face-to-face meeting.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS 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.
AGENCYACTION -- Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance.Agency
of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property
located at: 118 PEARL DRIVE,CARLISLE,PA 17013
IS IN SERIOUS DEFAULT because:
A.YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
Monthly Payments from 08/01/2012 through and including January 31, 2014 as follows:
Monthly Payments of$768.42 due on 08/01/2012 through and including 06/01/2013,
in the amount of................................................................................$8,452.62
Monthly Payments of$768.42 due on 07/01/2013 through and including 01/01/2014,
in the amount of................................................................................$5,378.94
TOTAL OF PAYMENTS IN DEFAULT: .....................................................$13,831.56
Other Charges (Explain/Itemize): -
LateCharges: ...................i................................................................ $773.66
Escrow Advances: ........................................................................... $5,808.21
OtherFees Due: ............................................................................... $3,254.12
Less Suspense: .................................................................................. $(59.22)
TOTAL OF OTHER CHARGES:..................................................... $9,776.77
TOTALAMOUNT DUE: ..................................................................................$23,608.33
B. Reserved for items other than amounts set forth in A. above.
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY-THREE (33)DAYS of
the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,
WHICH IS $23,608.33 ,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:
Deutsche Bank National Trust Company as Trustee for Residential Asset
Securitization Trust Series 2006-A7CB Mortgage Pass-Through Certificates
Series 2006-G,by its servicer Ocwen Loan Servicing, LLC
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY(30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt.This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY(30)DAYS, the lender also intends to instruct its
attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00.Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYS
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 four (4) to six (6)
months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to
you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will be by contacting the
lender.
HOW TO CONTACT THE LENDER:
NAME OF LENDER: Deutsche Bank National Trust Company as Trustee for
Residential Asset Securitization Trust Series 2006-A7CB
Mortgage Pass-Through Certificates Series 2006-G
ADDRESS: 1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
PHONE NUMBER: (800) 446-2936
FAX NUMBER: - (407) 737-6300
CONTACT PERSON: Ocwen Loan Servicing LLC
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 or X may not (CHECK ONE) sell or
transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the
outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the
other requirements of the mortgage are satisfied.
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
(See Attached Page)
Sincerely,
STERN & EIS G, PC
BY:
drew J.
y, sq.
Stern &Eisenberg, PC
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND REGULAR MAIL
NOTICE PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS
NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS
REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
You may dispute the validity of the debt or any portion thereof. If you do so in writing within
thirty (30) days of receipt of this letter, this firm will obtain and provide you with written
verification thereof; otherwise, the debt will be assumed to be valid. Likewise,if requested within
thirty (30) days of receipt of this letter,this firm will send you the name and address of the
original creditor if different from above.
IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A
DISCHARGE IN.BANKRUPTCY(AFTER ENTERING INTO THE RELEVANT MORTGAGE
NOTE AND MORTGAGE AND HAVE NOT REAFFIRMED THE DEBT)THEN THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO
COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE
MORTGAGE/LIEN AGAINST REAL PROPERTY.
VHFAComprehensive HousinCounseling Agencies
g
PENNSYLVANIA HOUSING FINANCE AGENCY Agencias de Consejo al Cliente para Vivienda
Cumberland County
*CCCS of Western PA-York
888.511.2227/888.511.2227
55 Clover Hill Road
www.cccspa.org
Dallastown PA 17313
Community Action Commission-Capital Region
717.232.9757
1514 Deny St
www.cactricounty.org
Harrisburg PA 17104
Harrisburg Fair Housing Council
717.238.9540
2100 N 6th St
Harrisburg PA 17110
Housing&Redevelopment Authority-Cumberland Cnty
866.683.5907/717.249.0789
114 N Hanover St;STE 104
www.cchra.com
Carlisle PA 17013
Pathstone Corporation Pennsylvania
717.234.6616
1625 North Second St
www.ruralisc.org/pathstone_pa.htm
Harrisburg PA 17102
Pennsylvania Interfaith Community Programs,Inc.
717.334.1518
40 E High St
www.adamscha.org
Gettysburg PA 17325
Report last updated:4/30/2012 9:03:04 AM
Prepare Date: January 27,2014
NOTE: NOTE:Many of the agencies offer workshops at various location sites;call to find a location near you.
Name and STERN&EISENBERG
Address 1581 Main Street,Suite 200
of Sender Warrington,PA 18976
Line Article Postage Fee
Number
DAVID M PINDER U.S. Postal Service TM
118 PEARL DRIVE CERTIFIED MAIL. RECEIPT
3 (Domestic Mail Only,No Insurance Coverage Provided)
CARLISLE,PA 17013-1044
2 Ln KALI L PINDER flfi
118 PEARL DRIVE M1 L
co
CARLISLE,PA 17013-1044 Postage $
3 Cj 9�511%
M
Certified Fee
r
C3 Return Receipt Fee P..
rk
4 C3 (Endorsement Required)
M ..re
;b
Restricted Delivery Fee z te) x
5 C3 (Endorsement Required)
Total Postage&Fees $
6 PHFA M
PO BOX 8029 ru Sent To
r-9
HARRISBURG,PA 17105-8029 M 'SRiiii-AjYt.NY------- KALI L PINDER ........
7 r- or PO-Box.No 118 PEARL DRIVE
-------------
City,State,ZIP+4 CARLISLE,RA 17013-1044 --------
8 ..........
9
10 U.S.. Postal ServiceTm
11
CERTIFIED MAILT,, RECEIPT
W . . .. .. Er (Domestichfall Only,No insurance Coverage Provided)
U.S.POSTAGE>>PITNEY BOWES M
Ln •
12 rM
cc
ZIP 18976
13 $ 001.410
02 1YV Postage $
r%-
0001371685 JAN. 31 2014. M Certified Fee
14 C3
heturn Receipt Fee Post r101
C3 (Endorsement Required)
15 Reslacted Delivery Fe
RE: ACT NOTICE C3 (Endorsement Required)
Total Number of Total Number of Pieces — Postmaster,Per(Name of Receiving M Total Postage&Fees =
$
Pieces Listed by Sender Received at Post Office Employee) ru Sent To .
DAVID M PINDER
O ------- .............
r- Or PO Box No. 118 PEARL DRIVE
City State,ziP+a CARLISLE,PA 17013-1044 -------------
Deutsche Bank National Trust Company, et al IN' TUF rni IRT nG COMM nni PLEAS OF
CP
VS.
Kali L. Pinder and David M. Pirgdo nd n s ✓�'
e a tO Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer you must take the following steps to be eligible for a
conciliation conference. First,within twenty(20) days of your receipt of this notice,you must contact MidPenn Legal
Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative,
at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal
representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal
representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If
you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will
prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days
of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled,you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to
be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that
a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format
attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed
with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation
conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out
reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
1-7
5/28/2014
Date Signature of Counsel for Plaintiff
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance,your lender must consider your circumstances to determine
possible options while working with your
Please provide the following information to the best of your knowledge:
APPLICATIONCUSrOMERIPRIMARY
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?
CO BORROWER
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 and Insurance:
Date of Last Payment:
Primary Reason for Default:
i
Is the loan in Bankruptcy? Yes❑ No❑ If yes,provide names, location of court,case number&attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile#1: Model: Year:
Amount owed: Value:
Automobile#2: Model: Year:
Amount owed: Value:
Other transportation(automobiles,boats,motorcycles): Model:
Year: Amount owed: Value:
Monthly Income
Name of Employers:
1. Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description(not wages):
1. Monthly Amount:
2. Monthly Amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses:(Please only include expenses you are currently 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 Payment Cable TV
Child Support/Alim. Spending Money
Day/Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income and Expenses:
Have you been working with a Housing Counseling Agency?
Yes F] No❑
If yes,please provide the following information:
Counseling Agency:
Counselor:
Phone(Office): Fax:
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?
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
[/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 I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Borrower Signature Date
Please forward this document along with the following information to lender and
lender counsel:
V Proof on income
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
V (hardship letter)
Listing agreement(if property is currently on the market)
V Copy of 2 years of federal income tax returns
V Copy of deed
FORM 3
Deutsche Bank National Trust Company, et al. IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
VS.
Kali L. Pinder and David M. Pinder
Defendant(s) Civil
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as
follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program: and has taken all of the steps required in that Notice to be eligible to participate in a
court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand that
statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities. I
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
FORM 4
Deutsche Bank National Trust Company, et al. IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Kali L. Pinder and David M. Pinder
Defendants) Civil
CASE MANAGEMENT ORDER
AND NOW,this day of ,20 ,the defendant/borrower in
the above-captioned residential mortgage foreclosure action having filed a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule. requirements for the scheduling of a Conciliation Conference, it is hereby
ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on at M. in
at the Cumberland County Courthouse,Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
servlice of the completed Form 2 is to be made may be extended. Upon notice to the
i
Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
i
the court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months;and the institution of bankruptcy proceedings.
S. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
i
i
I
I
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Srrllth ,���tz, 9 t atarttr ,44
Chief Deputy i?� j20
_'
Richard W Stewart '_UM3E1 L��, ✓
Solicitor Po; - PENNSYLVANIA
Deutsche Bank National Trust Co.
vs. Case Number
Kali Pinder(et al.) 2014-3311
SHERIFF'S RETURN OF SERVICE
06/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Kali Pinder, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion
Program and Complaint in Mortgage Foreclosure as"Not Found"at 18 Pearl Drive, North Middleton,
Carlisle, PA 17013. Residence is vacant.
06/10/2014 08:39 PM - Deputy Christopher Sharpe, 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 Laura Shockey, Fiancee, who accepted
as"Adult Person in Charge"for David Pinder at 1417 Walnut Bottom Road, South Middleton, Carlisle, PA
17015.
HRIST• ARPE, DEPUTY
SHERIFF COST: $62.56 SO ANSWERS,
June 12, 2014 RONNY R ANDERSON, SHERIFF
i i u •u .. ,"C s_. ...
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
ANDREW J. MARLEY, ESQUIRE (312314)
STERN & EISENBERG, PC
1581 MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON, PENNSYLVANIA 18976
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
2014,10 l,41.
Y
COUNTY
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
Deutsche Bank National Trust Company as
Trustee for Residential Asset Securitization Trust
Series 2006-A7CB Mortgage Pass -Through
Certificates Series 2006-G, by its servicer Ocwen
Loan Servicing, LLC
(Plaintiff)
v.
Kali L Pinder
and
David M Pinder
(Defendant(s))
Civil Action Number: 2014-3311
MOTION FOR SPECIAL ORDER DIRECTING SERVICE
BY POSTING AND CERTIFIED MAIL PURSUANT TO PA. R.C.P. 430(a)
TO DEFENDANT KALI L. PINDER
1. Plaintiff is Deutsche Bank National Trust Company, assignee of a loan to defendant's
secured by a mortgage on their real estate at 118 PEARL DR., CARLISLE, PA 17013. As a result of
defendants' default on said mortgage, Plaintiff filed a Civil Action on May 28, 2013.
2. The whereabouts of defendant whose last known address according to Plaintiffs
records is 118 PEARL DR., CARLISLE, PA 17013 is unknown, and accordingly, an attempt to
serve such defendants pursuant to the usual process prescribed by Pa. R.C.P. 400-405 would be
futile.
3. Pursuant to Pa. R.C.P. 430(a), an investigation has been made to determine the
whereabouts of the Defendants and the reason why service cannot be made. Attached hereto and
made part hereof as Exhibit "A" is an affidavit stating the nature and extent of that investigation.
4. Pursuant to Pa. R.C.P. 430(a) and Pa. R.C.P. 410(c)(2) and (3), this Court may
enter a special order directing that service be made by posting a copy of Plaintiffs Civil Action
and all further notices requiring personal service, if any, on the most public part of 118 PEARL
DR., CARLISLE, PA 17013 and by certified mail, return receipt requested to the Defendant at
her last known addresses being 118 PEARL DR., CARLISLE, PA 17013.
WHEREFORE, Plaintiff by its attorney moves this Honorable Court to enter a special order
directing that service be made by posting a copy of Plaintiffs Civil Action on premises 118 PEARL
DR., CARLISLE, PA 17013 and by sending a copy of same to the Defendant, at her last known
addresses being 118 PEARL DR., CARLISLE, PA 17013 by certified mail, return receipt requested
and regular mail. The Court is further requested to direct that all further notices required in the
above-captioned matter, requiring personal service, if any, be served on Defendant in the same
manner as permitted for service of Plaintiffs Civil Action in this case.
STERN & EISENB RG, PC
BY:
EDWARD J. MCKEE,
Attorney for Plaintiff
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
ANDREW J. MARLEY, ESQUIRE (312314)
STERN & EISENBERG, PC
1581 MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON, PENNSYLVANIA 18976
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
Deutsche Bank National Trust Company as
Trustee for Residential Asset Securitization Trust
Series 2006-A7CB Mortgage Pass -Through
Certificates Series 2006-G, by its servicer Ocwen
Loan Servicing, LLC
(Plaintiff)
v.
Kali L Pinder
and
David M Pinder
(Defendant(s))
Civil Action Number: 2014-3311
AFFIDAVIT OF INVESTIGATION
I, EDWARD J. MCKEE, being duly sworn according to law, depose and say that I am
counsel for Plaintiff, Deutsche Bank National Trust Company in the foregoing action and that the
following efforts were made by my office to serve the defendant with Plaintiffs Civil Action and to
determine the present whereabouts of said defendant:
1. Service of Plaintiff's Civil Action was attempted by the sheriff of Cumberland
County at the mortgaged property address being 118 PEARL DR., CARLISLE, PA 17013 but
service was not effectuated, Sheriff indicates "not found". See Exhibit "B" which is attached hereto
and made a part hereof.
EXHIBIT
I A
2. Plaintiff sent an inquiry to the Department of Motor Vehicles in order to obtain
information concerning the defendant KALI L. PINDER and the defendant is not registered in
Pennsylvania. See Exhibit "C" which is attached hereto and made a part hereof.
3. Plaintiff also sent an inquiry to the Department of Voter Registration in
Cumberland County and according to the records it maintains, the defendant KALI L. PINDER is
registered at the mortgaged property address, 118 PEARL DR., CARLISLE, PA 17013. See Exhibit
"D" which is attached hereto and made a part hereof
4. In addition to the standard searches conducted above, Plaintiff's Counsel has also
conducted an accurint search in order to determine additional information as to the whereabouts of
the Defendant and the Defendant is registered at 118 PEARL DR., CARLISLE, PA 17013. See
Exhibit "E" which is attached hereto and made a part hereof The information provided has enabled
Counsel to conduct additional investigation including those contemplated pursuant to Pa.RCP 430.
Notwithstanding, those additional inquiries and calls have lead to no information that would indicate
that the Defendants are at any other addresses. Based on the additional investigation, Counsel
believes that Defendant is simply evading service.
This information is true and correct to the best of my knowledge, information and
belief
NOTARIAL SEAL
ANGELA HARRIGAN. Notary Public
Warrington Twp., Bucks County
My Commission Expires November 26, 2016
Sworn to and subscribed
before me this Ir -day of
`T/ ,2014.
Public
STERN & EISENBERG, PC
B
T
EDWARD J. MCKEE,
Attorney for Plaintiff
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
71001109M i7'4-vtc�
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
UFFiCE OF T = 5k'hIFF
Deutsche Bank National Trust Co.
vs.
Kali Pinder (et aI.)
Case Number
2014-3311
SHERIFF'S RETURN OF SERVICE
06/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Kali Pinder, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion
Program and Complaint in Mortgage Foreclosure as "Not Found" at 18 Pearl Drive, North Middleton,
Carlisle, PA 17013. Residence is vacant.
06/10/2014 08:39 PM - Deputy Christopher Sharpe, 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 Laura Shockey, Fiancee, who accepted
as "Adult Person in Charge" for David Pinder at 1417 Walnut Bottom Road, South Middleton, Carlisle, PA
17015.
CHRISTO 1 R $ ARPE, DEPUTY
SHERIFF COST: $62.56 SO ANSWERS,
June 12, 2014
ANDREW J MARLEY ESQ
1581 MAIN ST
SUITE 200
WARRINGTON PA 18976
Dear Customer:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
BUREAU OF DRIVER LICENSING
HARRISBURG, PA 17123
02/24/14
140556685630562 055
KALI L PINDER
The Bureau of Driver Licensing has received your re-
quest for information. We are not able to provide this
information because the record you requested does not exist
in our files.
We regret that your payment must be retained to cover
,the cost of the search.
If you have any questions concerning this transaction,
please contact the Information Sales Unit at the address or
telephone number listed below.
ADDRESS CORRESPONDENCE TO:
Department of Transportation
Information Sales Unit
P 0 Box 68691
Harrisburg, PA 17106-8691
Sincerely,
Customer Service Team
Bureau of Driver Licensing
INFORMATION (8:00 AM to
IN STATE 1 -800 -
OUT -OF -STATE 717 -
TDD IN STATE 1 -800 -
TDD OUT-OF-STATE 717-
EXHIBIT
6:00 PM)
932-4600
412-5300
228-0676
412-5380
•
00
Voters: Find/Modify Voter
DELANEY. KALI `
001102532-21
A General I t Districts
Security: 'Not Restricted
Last Changed 17/6/2010 11:47:08
Federal Voter r
Votes I Correspondence Petitions I , d. Cbanges 1- ' Documents 1 ti Other I' Appligation
Application Source: Registered: Status -Reason:'
IML .101/01•/1989 'ACTIVE - REGISTERED
1/1/1999 1/1/1989
Title: Last Name: First Name: Middle Name: Suffix: Maiden Name:
I.....211
I J'DELANEY 1KALI
House 11: 112 Street Name: - Unit: Unit It: City: State: Zip Code:
118' .. 'PEARL DR J 1 •_ zi 1-71CARLISLE
... I� 'zi IPA 117013 zi
Address Line 2: Mail AddrLine 1: Mail City State- Mail Zip: : Mail Country
I I_ 1_ -_- ;II ._r -JI _...JI.
Email Address:
BirthDate: Social Sec: Driver's Lim: Phone: U r .Sex: Race Language:" Assistance:
03/02/1971 1=4-n.4.6547 122379733 11!.....JI... ..- J.I
Party: Other Party LastVoted
Msto
'REPUBLICAN I . ;
Precinct Split:,�J111/04/2008 r In uPeVrsonte r Poll Worker
r- Poll Worker Interest ;
119.02-1Insert , -s, _
Clear r. • • ;,
'NORTH MIDDLE i
MxC
Record: main 1 . ,, '.i Iof-1
EXHIBIT
KALI L PINDER
Gender - Female
118 PEARL DR
CARLISLE, PA 17013-1044
SSN - 206-52-xxxx
DOB/Age -
03/xx/1971 (43)
Dates - Apr 1996 - Jun 2014
https://secure.accurint.corn/app
Page 1 of 1
7/3/2014
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
ANDREW J. MARLEY, ESQUIRE (312314)
STERN & EISENBERG, PC
1581 MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON, PENNSYLVANIA 18976
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
Deutsche Bank National Trust Company as
Trustee for Residential Asset Securitization Trust
Series 2006-A7CB Mortgage Pass -Through
Certificates Series 2006-G, by its servicer Ocwen
Loan Servicing, LLC
(Plaintiff)
v.
Kali L Pinder
and
David M Pinder
(Defendant(s))
Civil Action Number: 2014-3311
CERTIFICATE OF SERVICE
I, EDWARD J. MCKEE, attorney for the within Plaintiff, hereby certify that a true
and correct copy of Plaintiffs Motion for Alternative Service was mailed to the following by first
class, postage prepaid mail on Ill 1, lok t
KALI L. PINDER
118 PEARL DR.,
CARLISLE, PA 17013
DATE: 1111 lti
STERN & EISENBERG, PC
BY.
J
EDWARD J. MCKEE,
Attorney for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION -LAW
Deutsche Bank National Trust Company as
Trustee for Residential Asset Securitization Trust
Series 2006-A7CB Mortgage Pass -Through
Certificates Series 2006-G, by its servicer Ocwen
Loan Servicing, LLC
(Plaintiff)
v.
Kali L Pinder
and
David M Pinder
(Defendant(s))
Civil Action Number: 2014-3311
ORDER
AND NOW, this / day of
9-1,
-�
, 2014, upon consideration of
Plaintiff's Motion for Special Order Directing Service of its Civil Action by Posting and Certified
Mail Pursuant to Pa. R.C.P. 430(a), it is hereby ORDERED AND DECREED that defendant KALI
L. PINDER shall be served by posting a copy of Plaintiffs Complaint, Notice of Sheriff Sale and all
other documents requiring personal service on the mortgaged premises, 118 PEARL DR.,
CARLISLE, PA 17013 and by sending a copies of same to defendant at her last known addresses
being 118 PEARL DR., CARLISLE, PA 17013 by certified mail, return receipt requested and regular
mail.
ecri PtafLES
V/Loy
BY THE COURT:
J.
y
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
LESLIE J. RASE, ESQUIRE (58365)
ANDREW J. MARLEY, ESQUIRE (312314)
EDWARD J. MCKEE, ESQUIRE (316721)
STERN & EISENBERG, PC
1581 MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON, PA 18976
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
O THON0 LA
2014 JUL 21 AFS 10: 43
CUr'DERLAND COUNTY
PENNS YLVAN!A
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for Residential Asset Securitization Trust Series
2006-A7CB Mortgage Pass -Through Certificates
Series 2006-G, by its servicer Ocwen Loan Servicing,
LLC
(Plaintiff)
V.
Kali L Pinder
David M Pinder
(Defendant(s))
7/18/14
Civil Action. Number: 2014-3311
Complaint in Mortgage Foreclosure
PRAECIPE TO REINSTATE CIVIL ACTION
Kindly reinstate the civil action in the above captioned matter.
STERN & EISENBERG, PC
BY:
E
T
2L—
RD J. MCKEE, E Q.
Attorney for Plaintiff
Q,Mk s I1. -%p8 a cJ
alc* apLig
2# 30S -)(4l
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
LESLIE J. RASE, ESQUIRE (58365)
ANDREW J. MARLEY (312314)
EDWARD J. MCKEE (316721)
STERN & EISENBERG, PC
1 581 MAIN STREET, SUITE 200
WARRINGTON, PENNSYLVANIA 18976
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for Residential Asset Securitization Trust Series
2006-A7CB Mortgage Pass -Through Certificates
Series 2006-G, by its servicer Ocwen Loan Servicing,
LLC
(Plaintiff)
v.
Kali L Pinder
David M Pinder
(Defendant(s))
Civil Action Number: 2014-3311
Complaint in Mortgage Foreclosure
CERTIFICATE OF SERVICE
c')
rn
rri
r
C'
c,
N)
CO
I, EDWARD J. MCKEE, ESQ., attorney for the within Plaintiff, hereby certify that the
Reinstated Complaint was mailed to the Defendant by certified mail, return receipt requested on
July 25, 2014, pursuant to the court order attached, as evidenced by copy of certified mail
receipts.
7/28/2014
STERN & ISENBERG, PC
BY:
EDWARD J. MCKEE
Attorney for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION -LAW
Deutsche Bank National Trust Company as
Trustee for Residential Asset Securitization Trust
Series 2006-A7CB Mortgage Pass -Through
Certificates Series 2006-G, by its servicer Ocwen
Loan Servicing, LLC
(Plaintiff)
v.
Kali L Pinder
and
David M Pinder
(Defendant(s))
Civil Action Number: 2014-3311
-0 -7,-
-1-• (7:
ORDER
AND NOW, this / / day of
9-1-)
4-
, 2014, upon consideration of
Plaintiff s Motion for Special Order Directing Service of its Civil Action by Posting and Certified
Mail Pursuant to Pa. R.C.P. 430(a), it is hereby ORDERED AND DECREED that defendant KALI
L. PINDER shall be served by posting a copy of Plaintiffs Complaint, Notice of Sheriff Sale and all
other documents requiring personal service on the mortgaged premises, 118 PEARL DR.,
CARLISLE, PA 17013 and by sending a copies of same to defendant at her last known addresses
being 118 PEARL DR., CARLISLE, PA 17013 by certified mail, return receipt requested and regular
mail.
BY THE COURT:
J.
Name and
Address
of Sender
STERN & EISENBERG
1581 Main Street, Suite 200
Warrington, PA 18976
Line
Article
Number
Postage
Fee
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Kali L. Pinder
118 Pearl Drive
Carlisle, PA 17013
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RE:
PSzFo;r�n'�380-0;'Augustt'2006� _ ,LrSeenRgversefor n§t uctons.
U.S. POSTAGE» PITNEY BOWES
t4,r
ZIP 18976 $ 001 .30°
02 11N
0001371685 JUL. 25. 2014
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
j LII._11r,r;1�y
wTHE PROTNUW1 T:=�:;
2014 MG 14 P11 3: 05
CUMBERLAND COUNTY
PENNSYLVANIA
OFF)CCE OF THE f-MEF,IFP
Deutsche Bank National Trust Co.
vs.
Kali Pinder (et al.)
Case Number
2014-3311
SHERIFF'S RETURN OF SERVICE
08/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Kali Pinder, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Sheriff Sale as "Not Found" at 118 Pearl
Drive, North Middleton, Carlisle, PA 17013. Residence is vacant and per the neighbors has been so for
over a year and per the Carlisle Postmaster the defendant moved and left no forwarding address.
SHERIFF COST: $34.78 SO ANSWERS,
August 12, 2014 RONNY R ANDERSON, SHERIFF
• (c) CountySuiie Sherif!, Teleosoft, Inc.
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
LESLIE J. RASE, ESQUIRE (58365)
ANDREW J. MARLEY, ESQUIRE (312314)
EDWARD J. MCKEE, ESQUIRE (316721)
STERN & EISENBERG, PC
-F-MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON, PA 18976
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
FA ED -Of t.
OF -HE PROTHONOTAFI
2014 AUG 29 PH 2:
CUMBERL AND COUNTY
PENNS YL VA NIA
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for Residential Asset Securitization Trust Series
2006-A7CB Mortgage Pass -Through Certificates
Series 2006-G, by its servicer Ocwen Loan Servicing,
LLC
(Plaintiff)
V.
Kali L Pinder
David M Pinder
(Defendant(s))
8/27/14
Civil Action Number: 2014-3311
Complaint in Mortgage Foreclosure
PRAECIPE TO REINSTATE CIVIL ACTION
Kindly reinstate the civil action in the above captioned matter.
STERN & EISENBER
BY:
Attorney for P a.
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
LESLIE J. RASE, ESQUIRE (58365)
ANDREW J. MARLEY, ESQUIRE (312314)
EDWARD J. MCKEE, ESQUIRE (316721)
STERN & EISENBERG, PC
1581 MAIN STREET, SUITE 200
THE SHOPS AT VALLEY SQUARE
WARRINGTON, PA 18976
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
FILED -OFFICE
OF THE PROTHONOTARY
2O f 4 QCT 14 AMU: 26
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for Residential Asset Securitization Trust Series
2006-A7CB Mortgage Pass -Through Certificates
Series 2006-G, by its servicer Ocwen Loan Servicing,
LLC
(Plaintiff)
v.
Kali L Pinder
David M Pinder
(Defendant(s))
10/9/14
Civil Action Number: 2014-3311
Complaint in Mortgage Foreclosure
PRAECIPE TOAREINSTATECIVIL ACTION
Kindly reinstate the civil action in the above captioned matter.
STERN & EISENBERG, PC
EDWARD J. MCKEE, ESQ.
Attorney for Plaintiff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
. _ rl r.` r C
Ronny R Anderson ?moi) �, r 1
Sheriff i= THE 'i'RO HOHCTA!
enpubri,..4
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
FF OF TIE VIERIF
*AMENDED*
2014 OCT 23 AM 9: V/
CUMBERLAND COUNTY
PENNSYLVANIA
Deutsche Bank National Trust Co.
vs.
Kali Pinder (et al.)
Case Number
2014-3311
SHERIFF'S RETURN OF SERVICE
08/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Kali Pinder, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Sheriff Sale as "Not Found" at 118 Pearl
Drive, North Middleton, Carlisle, PA 17013. Residence is vacant and per the neighbors has been so for
over a year and per the Carlisle Postmaster the defendant moved and left no forwarding address.
10/15/2014 06:43 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Kali Pinder, pursuant to Order of Court by "Posting" the premises located
at 118 Pearl Drive, North Middleton, Carlisle, PA 17013 with a true and corr- t op according to law.
WILLIAM CLINE, D
SHERIFF COST: $34.78 SO ANSWERS,
October 16, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySu to Sheriff, Te!eosoft, Inc.