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14-4267
For Prothonotary Use Only. Supreme Co u rt.,olf' PennsyIvania colod MM +'tai P Iia s 41k i um1b�and Docket N°. The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S ®Complaint ❑ Writ of Summons ❑ Petition E ❑Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name:Wells Fargo Bank,N.A. Lead Defendant's Name:Arthur Liebrum T I Are there money damages requested? ❑Yes ® No Dollar Amount Requested: ❑within arbitration limits O (check one) ❑outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No I Is this an MDJAppeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney: McCabe,Weisberg&Conway,P.C. ❑ Check here if you have no attorney(a Self-Represented [Pro Se] .Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑Intentional ❑Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection: Credit Card ❑Board of Assessment ❑Motor Vehicle ❑Debt Collection: Other ❑Board of Elections ❑Nuisance Cl Department of Transportation ❑ Premises Liability(does not include ❑ Statutory Appeal: Other S mass tort) E ❑Slander/Libel/Defamation ❑Employment Dispute: ❑Other: Discrimination C ❑Employment Dispute: Other ❑Zoning Board T ❑Other I O ❑Other N MASS TORT ❑Asbestos ❑Tobacco ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS I3 ❑Toxic Waste ❑Ejectment ❑Common Law/Statutory Arbitration ❑Other: ❑Eminent Domain/Condemnation ❑Declaratory Judgment ❑Ground Rent ❑Mandamus ❑Landlord/Tenant Dispute ❑Non-Domestic Relations °Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY g ❑Mortgage e Foreclosure:Commercial ❑Quo Warranto ❑Dental ❑Partition ❑Replevin ❑Legal XX Quiet Title ❑Other: ❑Medical ❑Other: ❑Other Professional: Updated 1/1/2011 McCABE, WEISBERG AND CONWAY, P.C. By Joseph I. Foley, Esquire Attorneys for Plaintiff Attorney Identification Number 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215)790-1010 c� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISIONCP c> 3476 Stateview Boulevard L4� Fort Mill, SC 29715 No.: �y Plaintiff, V. Arthur Liebrum 3 Tee Jay Drive Mount Holly Springs, PA 17065 Defendant. CIVIL ACTION / COMPLAINT TO QUIET TITLE Plaintiff, Wells Fargo Bank,N.A., hereby complains of defendant Arthur Liebrum, as follows: The Parties 1. The Plaintiff is Wells Fargo Bank,N.A., a national banking association duly organized and doing business at the above captioned address. 2. The Defendant is Arthur Liebrum, a prior owner of the property which is the subject of this action and his last known address is 3 Tee Jay Dr., Mount Holly Springs, PA�D 17065-1142. The Property 3. The real property which is the subject of this action is located in the County of Cumberland, and Commonwealth of Pennsylvania and is known as 309 Sandbank Road, Mt. Holly Springs, PA, 17065, and is more particularly described in the deed attached hereto and marked as Exhibit"A". The Deeds 4. Title to the property is vested in Ronald E. Jumper and Linda C. Jumper, by virtue of a Deed from Raymond J. Gregory and Linda B. Gregory, his wife, and Arthur Liebrum and Emily Liebrum, his wife, dated May 21, 2006 and recorded on June 2, 2006 in the Office of the Recorder of Deeds for Cumberland County in Mortgage Book 274, Page 4529 (the "Jumper Deed"). A true and correct copy of the Jumper Deed is attached as Exhibit"A". 5. Prior to the delivery and recording of the Jumper Deed, title to the property was vested in Raymond J. Gregory, who held a 3/4 interest in the property, and Arthur Liebrum and Emily Liebrum, who together held a 1/4 interest in the property as tenants by the entireties, by virtue of a deed dated August 24, 2000 and recorded on August 28, 2000 in the Office of the Recorder of Deeds for Cumberland County in Mortgage Book 227, Page 1121 (the "Liebrum Deed"). The relationship between the interest of Raymond J. Gregory and the interest of Arthur and Emily Liebrum was a tenancy in common. A true and correct copy of the Liebrum Deed is attached hereto and marked as Exhibit "B". 6. The Jumper Deed was executed by Raymond J. Gregory, Linda B. Gregory, Emily Liebrum, and Arthur Liebrum by Emily Liebrum as Attorney-in-Fact for Arthur Liebrum, her husband. See Exhibit"A". 7. Although the Jumper Deed was executed by Emily Liebrum on behalf of Arthur Liebrum as his attorney in fact, no power of attorney was ever recorded in the Office of the Recorder of Deeds of Cumberland County. 8. The Jumper Deed was acknowledged before a notary public who stated that the signatories to the Jumper deed had satisfactorily proven that they were persons whose names were subscribed on the instrument and had acknowledged that they executed the same for the purposes therein stated. 9. Upon information and belief, a power of attorney between Arthur Liebrum and Emily Liebrum was duly executed and it was intended by all parties that such power of attorney would be recorded at the same time as the Jumper Deed. 10. Upon information and belief, said power of attorney was produced for the notary public before whom the deed was signed and acknowledged as satisfactory proof that Emily Liebrum was, in fact, acting on behalf of Arthur Liebrum under a power of attorney. 11. Upon information and belief, the Jumper Deed was intended by all parties, including Arthur Liebrum, to be a valid transfer of the entire property to Ronald E. Jumper and Linda C. Jumper. The Wells Fargo Loan 12. On May 14, 2009, Wells Fargo Bank,N.A. extended to Ronald E. Jumper and Linda C. Jumper a loan in the amount of$153,000.00 (the "Wells Fargo Loan"). 13. Settlement in connection with the Wells Fargo Loan occurred on May 14, 2009. 14. The Wells Fargo Loan was intended to be secured by a first-position mortgage against the entire property. 15. To secure payment of the Wells Fargo Loan, on May 14, 2009, Ronald E. Jumper and Linda C. Jumper, husband and wife, executed and delivered a mortgage in favor of Wells Fargo Bank,N.A., Plaintiff herein, against the property ("the Mortgage"). 16. The Mortgage was thereafter recorded in the Office of the Recorder of Cumberland County as Instrument Number 200919727. A true and correct copy of the Mortgage is attached hereto as Exhibit"C"and incorporated herein by reference 17. The failure to record the power of attorney between Arthur and Emily Liebrum at the same time as the Jumper Deed was recorded creates a cloud upon title and adversely affects plaintiff's interest in the property. Count I - Quiet Title 18. All paragraphs above are incorporated herein by reference. 19. Pa. R.C.P. 1061(b)provides in part: "(b) The action [to quiet title] may be brought to: (1) to compel an adverse party to commence an action of ejectment; (2) where an action of ejectment will not lie, to determine any right, lien,title or interest in the land or determine the validity or discharge of any document, obligation or deed affecting any right, lien, title or interest in land; (3) to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land; or (4) to obtain possession of land sold at a judicial or tax sale." 20. Pa.R.C.P. 1066, relating to "form of judgment or order" in a quiet title action, provides: "(a) The Court shall grant appropriate relief upon affidavit that a complaint containing a notice to defend has been served and that the defendant has not filed an answer, or after a hearing or trial on the pleadings or merits. (b) Upon granting relief to the plaintiff, the court: (1) shall order that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the plaintiff set forth in his complaint, unless the defendant takes such action as the order directs within thirty (30) days thereafter. If such action is not taken within the 30-day period,the prothonotary on praecipe of the plaintiff shall enter final judgment; (2) shall enter a final judgment that a document, obligation or deed affecting a right, lien, title or interest in the land is canceled or is valid, invalid or discharged or that a copy of a lost plan, document, obligation or deed is an authentic copy; (3) shall enter a final judgment ordering the defendant, the prothonotary, or the recorder of deeds to file, record, cancel, surrender or satisfy of record, as the case may be, any plan, document, obligation or deed determined to be valid, invalid, satisfied or discharged, and to execute and deliver any document, obligation or deed necessary to make the decree effective; or (4) shall enter any other order necessary for the granting of proper relief." 21. Pursuant to Pa.R.C.P. 1066, Plaintiff respectfully requests the Court to declare that the Jumper Deed, dated May 21, 2006, and recorded in the Office of the Recorder for Cumberland County in Mortgage Book 274, Page 4529, is deemed to be a valid transfer of the entire Property which is the subject of this action, including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order declaring the Jumper Deed to be a valid transfer of the entire property that is the subject of this action including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. Count II - Quiet Title 22. All of the preceding paragraphs are incorporated herein by reference as if more fully set forth. 23. Pursuant to Pa.R.C.P. 1066, Plaintiff respectfully request the Court to declare that the Wells Fargo Mortgage is a valid and perfected mortgage lien against the entire property which is the subject of this action, including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order declaring the Wells Fargo Mortgage to be a valid and perfected mortgage lien against the entire property which is the subject of this action, including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. Count III - Quiet Title 24. All of the preceding paragraphs are incorporated herein by reference as if more fully set forth. 25. Pursuant to Pa.R.C.P. 1066, Plaintiff respectfully requests the Court to order that Arthur Liebrum be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest held by Wells Fargo Bank, N.A. pursuant to the Wells Fargo Mortgage or any successor in interest to Wells Fargo Bank,N.A. thereunder. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order forever barring Arthur Liebrum from asserting any right, lien,title or interest in the land inconsistent with the interest held by Wells Fargo Bank,N.A. pursuant to the Wells Fargo Mortgage or any successor in interest to Wells Fargo Bank,N.A. thereunder. Respectfully submitted, McCABE, WEISBERG& CONWAY, P.C. By: J eph 1. Foley, Es e Attorneys for Plaintiff VERIFICATION Angelica Hernandez, hereby states that she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that she is authorized to make this Verification, and verify that the statements made in the foregoing Complaint in Quiet Title are true and correct to the best of her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. r An elica Hernandez Vice President Loan Documentation Wells Fargo Bank,N.A. Date: J / EXHIBIT A 3� Parcel#40-32-2334-054 - THIS DEED AllJUN 2 PM 2 56 THIS INDENTURE, MADE THE p� day of , in the year of TWO THOUSAND SIX(2006). BETWEEN: RAYMOND J. GREGORY and LINDA B.GREGORY, his wife, of 243 Grayson Drive, Norwich, New York; and ARTHUR LIEBRUM and EMILY UEBRUM, his wife, of Norwich, New York; hereinafter called the, GRANTORS AND RONALD E.JUMPER and LINDA C.JUMPER, his wife, of Cumberland County, Pennsylvania, hereinafter called the, GRANTEES WITNESSETH, that the said Grantors,for and in consideration of the sum of One Hundred Sixty-Five Thousand and 001100($165,000.00) Dollars, lawful money of the United States of America, unto them well and truly paid by the Grantee, at or before the sealing and delivery hereof, the receipt whereof is hereby acknowledged, have granted, bargained and sold, released.and confirmed, and by these presents, grant, bargain and sell, release and confirm unto the said Grantee, their heirs and assigns: TRACT#1 ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-473, said point being a spike in the center line of West Pine Street Extended, said point also being North 82 degrees 30 minutes West, 25 feet from the line of land now or formerly of Russell S_ Starner; thence along said land now or formerly of Russell S. Starner, South 2 degrees 23 minutes East, 200 feet to a stake at line of land now or formerly of Samuel C. Garonzik, at al;thence along the latter, North 82 degrees 30 minutes West, 100 feet to a stake; thence still along the same, North 2 degrees 23 minutes West,200 feet to a spike in the center line of Township Road T--173(West Pine Street Extended); thence along the latter, South 82 degrees 30 minutes East, 100 feet to a spike, the place of BEGINNING. 90X + PAGL4529 CONTAINING .452 acres according to a survey of Thomas A. Neff, R. S., dated October 24, 1969. BEING improved with a five-room ranch type dwelling and carport, known as 309 Sandbank Road, Mount Holly Springs, Pennsylvania. T CT#2 ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Carl David Bert, Registered Surveyor, dated March 11, 1983, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 43, Page 27, and being Lot No. 313 as shown on said Plan, as follows: BEGINNING at an existing iron pin at the Southwest corner of land now or formerly of Herbert J. George and Cathrine B. George, which point is also on the dividing line between Lot No. 3A and 3B on said Plan; thence along said dividing line between Lot No 313 and land of Herbert J. George and Cathrine B. George, South 88 degrees 45 minutes 04 seconds East, a distance of 100 feet to an existing iron pin on the dividing line between Lot No. 313 and 3C as it appears on said Plan; thence along said dividing line, South 08 degrees 59 minutes 37 seconds East, a distance of 25 feet to an iron pin in line of Lot No. 3A; thence along the dividing line between Lot Nos. 313 and 3A, North 88 degrees 45 minutes 04 seconds West, a distance of 100 feet to an iron pin; thence continuing along Lot No. 3A, North 08 degrees 59 minutes 37 seconds West, a distance of 25 feet to an existing iron pin, the place of BEGINNING. BEING the same premises which the Estate of Cathrine B. George by their Deed dated August 24, 2000, and recorded August 28, 2000, in Cumberland in Cumberland County Recorder of Deeds in Book 227, Page 1121, granted and conveyed unto Raymond J. Gregory, Linda B. Gregory,joins in this deed to convey any interest she may have in the within described property as the spouse of Raymond J, Gregory, and Arthur Liebrum and Emily Liebrum, husband and wife, Grantors herein. TOGETHER with all and singular ways, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto belonging, or in anywise appertaining, and the reversions and remainders, rents, issues and profits thereof; and also, all the estate right, title, interest, use trust, property, possession, claim and demand whatsoever, in law, equity or otherwise howsoever, of, in, to or out of the same. TO HAVE AND TO HOLD, the said hereditaments and premises hereby granted and released, or mentioned and intended so to be, with the appurtenances, unto the said GRANTEES and their heirs and assigns, to and for the only proper use and behoof of the said GRANTEES their heirs and assigns, forever. x 274 PACE4530 AND the said grantor/grantors do hereby SPECIALLY WARRANT the property hereby conveyed. IN WITNESS WHEREOF,the said Grantors have hereunto set their hands and seal the day and year first above written. SIGNED, SEALED AND DELIVERED IN THE PRESENCE OF (SEAL) RA N J. GR (SEAL) LINDA B. GREGORY 015 Mal �'n (SEAL) "ARHURIE U ` f (SEAL) 'EBROM Cflril �H OF COUNTY OF�� �/1 ON THIS, the day of MA- , 2006, before me, the undersigned office, personally appeared Raymond J. Gregory, Linda B. Gregory,Arthw Ljobfum and Emily Liebrum, known to me(or satisfactorily proven)to be the persons whose names are subscribed to the within instrument, and acknowiedged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public DE=BORAH A. TRYTHALL MMART PMUC,STATE OF um yob CADAM NT CNENANGO COUNTY ��lfE�(i 10.DITRU01268 274 ACE4SU I do hereby certify that the precise residence and complete post office address of the within eaGrantee is IOU Attorney f Grantee 7 Waberlad County tecar&r of keds Instrwent Filins ReceiFtR 610180 Iestri 2006-419250 6/02/2006 15=01:34 Rmrks: BIipM J"ER DEED 12.50 DEEB - MIT .50 Do - ITT ST17E 1650.00 SUN MIMLETIN 0.40 _ SK" MI10 ITBl1 83.00 DEED - 6/H 11.50 J.C.S. I A.T.J. 18.04 CO IIR'R1pIOW FND 2.00 REC. IMllB{A1T FUND 3.00 C6eckd 1856 $3,339.00 Checkl 1855 1.50 Total It awed....... 83:334.54 ? Certify this ` be recorded 'n Cumberlan_5 County PA Recorder of Doe& W. 274 PACE45a i EXHIBIT B Parcel#40-32-2334-M THIS INDENTURE MADE this day of August 2000. BETWEEN JOSEPH L.YORLETS& PAMELA K YORLETS, Co-ExemAors of the Last Will and Testament of Cathrine B. George, late of South Middleton Township, Cumberland County,Pennsylvania; GRANTOR AND RAYMOND J.GREGORY,a married man,of 243 Grayson Drive,Norwich,New York; ARTHUR LiEBRUM&EMiLY LIEBRUM,husband and wife,of Carlisle,Pennsylvania; GRANTEES WHEREAS Cathrine B.George died January 27,2000,testate seized of certain land situate in South Middleton Township,Cumberland County,Pennsylvania;and WHEREAS the VAI of the said Cathrine B.George dated July 31,1997,was duly probated in the Office of the Register of Wills In and for Cumberland County, Pennsylvania,on Febnmq 28,2000,and Letters Testamentary were granted to Joseph L Yodets and.Pameia K Yodets,the above named Co-Executors to#21-00-174;and WHEREAS Section 3351 of the Probate,Estates and Ftduclades Code(20 PS. 3351)confers upon Executors)the power to sell at public or private sale, any real estate not specifically devised;and WHEREAS the hereinafter described premises were not specifically devised;and WHEREAS the said Co-Executom were not required to file any band to secure faithful performance of their duties. NOW THIS INDENTURE WITNESSETH that Joseph L. Yorlats and Pamela K Yoriets, Co.-Executors of the Estate of Cathrine B. George, deceased, for and in consideration of the sum of Ninety Thousand and 001100 Dollars($90,000.00)in lawful money of the United States,to them In hand paid by the said GRANTEES at and before the sealing and delivery hereof,the receipt whereof Is hereby acknowledged they have granted,bargained,sold,aliened,released and confirmed,and by these presents does grant,bargain,sell,allan,release and confirm unto the said GRANTEES,their heirs and assigns: wK 227 nicdl2i It Is the intention of this Dead that Raymond J.Gregory,marled man,shall own an.undivlded 3:Interest therein and that Arthur Llabrum and Emlly Ltebrum, husband and'wlfs,shalt own an undivldsd V4 interest as tenants by the entlretles. The rotation between the owners of the respective undivided Interests shall be tenants in common. TwiCt#1: ALL THAT CERTAIN tract of land with the improvements thereon erected situate In South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a pont!In the center line of Township.Road T-473, said point being a spike in the center line of West Pine Street Extended, said point also being North 82 degrees 30 minutes West,25 feet from the Ana of land now or formerly of Russell S.Stamen;thence along said land now or formarty'of Russell S.Stamar,South 2 degrees 23 minutes East200 feet to a stake at Una of land now or formerly of Samuel C.GamnAk,of at.thence along the letter,North 82 degrees 30 minutes West,100 feet to a stake;thence still along the same,North 2 degrees 23 minutes West,200 feet to a spike in the center line of Township Road T-473(West Pine Street E)dended);thence along the letter,South 82 degrees 30 minutes East, 100 feet to a spike,the place of BEGINNING. CONTAINING.452 ales according to a survey of Thomas A Neff,R:S.,dated — October 24, 1986. 'BEING hprcvW with a five room ranch type dwelling and carport, known as 309 Sandbank Road,Mount Holly Springs,Pennsylvania, BEING the same property which Mark C. Snyder and Linda K.Snyder,his wHe,. by their Deed dated January.16,1979,and recorded to Cumberland County Recorder of Deeds Book"G",Vol.28,Page 218,granted and conveyed unto Herbert J.George and Cathrine B.George,his'wife. The said Herbert J.George died December 18, 1698, thereby vesting,full Main Cathrine B.George. TLLtiZ ALL that'certaln.tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described.In accordance with a survey by Carl David Bert,Registared Surveyor,dated March 11, 1983,and recorded.in the Ofte,of the Recorder of Deeds in and for Cumberland Cormty in Plan Book 43,Page 27,and being Lot No.38 as shown on said Plan,as follows: BEGINNING at.an existing tron pin at the'Southwest comer of land now or formerly of Herbert J. George arid.Cathrine B. George, which point Is also on the dividing line between Lot No.3A and 3B on said Plan;thence along said dividing Una between Lot No 39 and land of Herbert J. George and Cathrine B.George,South 88 degrees 45 minutes 04 seconds East,a distance of 100 feet lo on,erdsftng Iron pin on the dividing Ilse betwasn Lot No,'36 and 3C as it appears on said Plan;thence along said dividing line,South 08 degrees 59 minutes 37 seconds East,a distance of 25 feet 2 � 227 PXdin to an iron pin in line of Lot No.3A;thence along the dividing tine between Lot Nos.313 and 3A. North 88 degrees 45 minutes 04 seconds West,a distance of 100 feet to an Iron pin;thence oontinuing along Lot No.3A.North 08 degrees 59 minutes 37 seconds West,a distance of 25 feet to an existing Iron pin,the place of BEGINNING. BEING the some property which Jenny Lee Shue,by her Deed dated May 18, 1983,and recorded In Cumberland County Recorder of Deeds Book"E',Vol.30,Page 729,granted and conveyed unto Herbert George and Cathrtne George,his wife. The sold Herbert George died December 18, 1998, thereby vesting full title in Cathrine George. TOGETHER with all and singular ways,waters,water-courses,rights,liberties, privileges, hereditaments and appurtenances whatsoever thereunto belonging, or in anywise appertaining, and the reverslons and remainders, rents, Issues and profits thereof,and also,all the estate right,title,interest,use trust,property.posseselon,claim and demand whatsoever,in law,equity or otherwise howsoever,of,in,to or out of the same. TO HAVE AND TO HOLD,the said hereditaments and premises hereby granted and released,or mentioned and intended so to be,with the appurtenances, unto the said GRANTEE and his hairs and assigns,to and for the only proper use and behoof of the sold GRANTEE his helm and assigns,forever. AND the said Co-Executors of the Estate of Cathrine B. George, deceased, covenant,promise,and agree to and with the said GRANTEE his heirs and assigns,by these presents, that halshe, the said Co-Executors have not done, 'committed, knowingly or willingly suffered to be done or committed, any ad, matter or thing whatsoever whereby the premises hereby granted,or any part thereof,is,are.shall or may be Impeached, charged or encumbered, in title, charge, estate, or otherwise howsoever. WITNESS the due execution hereof the day,month and year first above written. Signed,Sealed and Delivered Estate of Cathrine B.George in the Presence of. DOSE H L.YO S,Executor PAMELA K VDRL TS,Executor S COMMONWEALTH OF PENNSYLVANIA 3 as COUNTY OF CUMBERLAND ) On this,the 0 day of Auaust 2000, bafore me, the undemIgned.otfim personally appeared Joseph L. Yorlats and Pamela K. Yortets, known to me(or satisfactorily proven)to be the person whose name Is aabscribed to the within Instrument,and acknowledged that they vocutsd same as Co-Executors for the Estate ofCathrins B.George for the purposes therein contained. �„rIN'MTNESS WHEREOF,I hereunto set my hand and o el seal. Ail d'-P'N(;:•+ F� L ����� �4rC 2609 . 2609 G•:` y�+0r4PMer�t+eru�,Woelttimdr�WY1 Ido hereby car*that the prat residence and complete post officeaddress of the within named Grantee Is: Sr�—�-,—,,z,, t ., „z '7! U � Date. may for COMMONWEALTH OF PENNSYLVANIA ). ss COUNTY OF CUMBERLAND } RECORDED on this 12%_day of 000, in the Recorde4 Office of the said County,In Deed Book. Page •L .m Cy t-i Given under my hand and seal of the said offrce,the date.above written. C0 �,:,• IRKIN,MCKNIGHT&HUGHES Afforrsays 4�l�� : - � �� 4 iii •r��. ponx 2207 F;c�9iR5 ' EXHIBIT C � 9�,� -2 lye. QQOK2kj Prepared By: WELLS FARGO BANK, N.A. 111 CONTINENTAL DR, SUITE 114, NEWARK, DE 197130000 Return To: IXS, S 5 9-024 Core Settlement Services :zw. EE 3000 Market Street DES MO 030 —4600 Camp Hill, PA 17091 Parcel Number:L]Q-3�t`XYY-i_C6 y Premises: 309 SANDBANK ROAD MT HOLLY SPRINGS (Space Above This Line For Recording Data( MORTGAGE DEFINITIONS Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 111 13, 18, 20 and 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 MAY 14, 2009 together with all Riders to this document. (B) "Borrower"is RONALD E JUMPER AND LINDA C JUMPER, HUSBAND AND WIFE Borrower is the mortgagor under this Security Instrument. *—0 UM—�p PMP PANIA le Family-Fenrde Mae/Fiaddle Mae UNIFORM INSTRUMENT } Form 3039 tpt L YM4 A)(0804).00 Wolters Kluwer Finandal Services InWals• L d Page 1 of 17 NMFL 93039(PACM)Rev 72009 1111111111111111111111 * (C) "Lender"is WELLS FARGO BANK, N.A. Lender is a NATIONAL ASSOCIATION organized and existing under the laws of THE UNITED STATES Lender's address is P.O. BOX 11701, NEWARK, NJ 071014701 Lender is the mortgagee under this Security Instrument. (D) "Note"means the promissory note signed by Borrower and dated MAY 14, 2009 The Note states that Borrower owes Lender ONE HUNDRED FIFTY THREE THOUSAND AND 00/100 Dollars (U.S.$ ******153,000.00 )plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than JUNE 01, 2039 (E) "Property"means the property that is described below under the heading "Transfer of Rights in the Property." (F) "Loan"means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due under the Note, and all sums due under this Security Instrument,plus interest. (G) "Riders"means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower[check box as applicable]: 0 Adjustable Rate Rider 0 Condominium Rider ❑Second Horne Rider 0 Balloon Rider Planned Unit Development Rider 0 1-4 Family Rider 0 VA Rider 0 Biweekly Payment Rider 0 Other(s) [specify] (H) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final, non-appealable judicial opinions. (I) "Community Association Dues, Fees, and Assessments"means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (J) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or magnetic 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. (K)"Escrow Items"means those items that are described in Section 3. (L) "Miscellaneous Proceeds"means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the PENNSYLVANIA-Single Farnily-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT f Form 30391/01 VMP 8 /VMPB(PA)(0804}00 Wolters Kluwer Rnanaial Services Intuals: ✓✓✓ Page 2 of 17 Property; (iii) conveyance in lieu of condemnation;or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (h) "Mortgage Insurance"means insurance protecting Lender against the nonpayment of, or default on, the Loan. (N) "Periodic Payment"means the regularly scheduled amount due for(i)principal and interest under the Note, plus(ii)any amounts under Section 3 of this Security Instrument. (0) "RESPA"means the Real Estate Settlement Procedures Act(12 U.S.C. Section 2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan"under RESPA. (P) "Successor in Interest of Borrower"means 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 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 Lender the following described property located in the COUNTY [Type of Recording Jurisdiction] of C0MBFJU.AND [Name of Recording Jurisdiction]: SEE ATTACHED LEGAL DESCRIPTION TAX STATEMENTS SHOULD BE SENT TO: WELLS FARGO HOME MORTGAGE, P.O. SOX 11701, NEWARK, NJ 071014701 which currently has the address of 309 SANDBANK ROAD 309 SANDBANK ROAD [Street] MT HOLLY SPRINGS [City], Pennsylvania 17065 [Zip Code ("Property Address"): PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Faun 3639 1/D1 VMP® MPS(PA)(0804�0D Wafters IQuwer Financial Services Inh)als: Page 3 of 17 TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the"Property." BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. 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 Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency,instrumentality, or entity;or(d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1101 VMP W VMPS(PA)(0804 00 Wolters Nlrmmer Financial Servloes Inidals: Page 4 of 17 shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date,or change the amount,of 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 Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow items unless Lender waives Borrower's obligation to pay the Funds for any or all 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 Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase"covenant and agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts,that are then required under this Section 3. Lender may, at any time, collect and bold 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 current data and PENNSYLVANIA-Single Family-Fannie Mae/Freddle Mae UNIFORM INSTRUMENT //nJJ /// Form 3039 1/01 VMP O VMPB(PA)(080 Woken Kluwer Financial Services initials- of 1-+� Page 5 of 17 reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality,or entity(including Lender, if Lender is an institution whose deposits are so insured)or in any Federal 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 Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to 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 Lender the amount necessary to make up the deficiency in accordance with RESPA,but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees 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 performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the Iien while those proceedings are pending, but only until such proceedings are concluded; or(c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4. Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service used by Lender in connection with this Loan. 5. Property Insurance. 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 PENNSYLVANASIngle Famlly-Fannie MaelFreddie Mac UNIFORM INSTRUMENT Foran 3039 1101 VMP6 J rVMP6(PA►(0804�00 WoNem Kluwer Financial Services Initials: e/ Pape 6 of 17 other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and certification services and subsequent charges each time remappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might-or might not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender 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 opportunity 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 other third parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If PENNSYLVANIA-Single Family-Fannie Mae/Froddle Mac UNIFORM INSTRUMENT Form 3039 1/01 VMP® VMP6(PA)(0804).00 Wolters 10u"r Financial Services In'eiabs: Page 7 of 17 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 matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30-day period will begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument,whether or not then due. 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to 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. PENNSYLVANIA-Single Family-Fannie Mae/Freddle Mae UNIFORM INSTRUMENT Form 3039 1101 VMP 8 �,/ VMPB(PA)(0804).00 Wafters Kluwer Financial Services Inftia _� Page 8 of 17 9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b)there is a legal proceeding that might significantly affect Lender's interest in the Property and/or 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. Lendees actions can include, but are not limited to: (a) paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in court; .and (c) paying reasonable attomeys' fees to protect its interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Mortgage Insurance.If Lender required Mortgage Insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loss reserve in lieu of Mortgage insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no Ionger require loss reserve payments if Mortgage Insurance coverage(in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and PENNSYLVANWSIngle Family-Fannie MaefFreddie Mac UNIFORM INSTRUMENT Foam 3039 1/01 VMP® /� �l }VMP6(PA)(0804�0 Wafters Kluwer Financial Services Mhia � L Page 9 d 17 Lender providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and 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 share of the premiums paid to the insurer, the arrangement is often termed"captive reinsurance."Further: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund. (b) Any such agreements will not affect the rights Borrower has - if any - with respect to the Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any Mortgage Insurance premiums that were unearned at the time of such cancellation or termination. 11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. 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 feasible or Lender's security would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any,paid to Borrower. PENNSYLVANLASInple Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1101 VMP® �q j }rMPB(PA0 Wolters Kluwer Finandal Services Initials: / t � �[ Papege 1fof I0 of 7 o ► In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in value.Any balance 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, or loss in value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. 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 after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party that 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 Lender's judgment, precludes 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 Lender. 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; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any 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, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the 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 be joint and several. However, any Borrower who co-signs this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this �p®VANIRSIngle Family-Fannie Mae/Frafte Mac UNIFORM INSTRUMENT /7 Form 3039 1101 Watters Kluwer Financial Services Initials• f V VMPfi page01�d17 Security Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without the co-signer's consent. Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section 20)and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees 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 permitted limit; and(b)any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by 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 report a change of address through 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. PENNSYLVANIA-Single Family-Fannia Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1107 vMP® � )VMP6(PA)(080400 Wolters Kluwer Financial Services Inlllsis: y Paye 12 of 17 1 S. 16. Governing Law; Severability; 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) words 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. 18. 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 purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred(or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section is within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of (a)five days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b)cures any default of any other covenants or agreements; (c)pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check,provided any such check is drawn upon PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1/01 VMP® MPB(PA)(0804).00 Wolters Kluwer Financial Services Initials: Page 13 of 17 an institution whose deposits are insured by a federal agency, instrumentality or entity; or(d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer;Notice of Grievance.The Note or a partial interest in the Note (together with this Security Instrument) can he sold one or more times without prior notice to Borrower. A sale might result in a change in the entity (known as the "Loan Servicer") that collects Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and'address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor 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 with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to 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 defined in Environmental Law; and (d) an"Environmental Condition" 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 (c)which, due to the presence,use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences shall not-apply to the presence, use, or storage on the Property of small quantities of PENNSYLVANU1Single Family-Fannie MaelFreddle Mac UNIFORM INSTRUMENT Form 3039 1101 vMP8 1VMPS(PA)(OWXI G0 Woken l0uwer Financial Services Initial F- fJ Page 14 0[17 Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property(including,but not limited to, hazardous substances in consumer products). Borrower shall promptly give Lender written notice of(a)any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration;Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a)the default; (b) the action required to cure the default; (c)when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall he entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable Law. 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 Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale 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 after 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. PENNSYLVANIA-Single Family-Fannie Mae/Freddle Mac UNIFORM INSTRUMENT Form 3039 1101VMP® MP6(PA)(0604).00 Wohem Kluwer Financial Services Inffials: Page 15 of 17 BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. Witnesses: RONALD E JUMPER -Borrower 34 eal) LIN—Sk O JUMPER -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower PENNSYLVAN1Av^ingte FamBy Fannte MaelFreddie Mac UNIFORM INSTRUMENT Form 3039 1/01 VMP® �1/MPO(PA)(0804).00 Woltem Khmw Financial Services InfUals: [l Page 16 of 17 r J COMMONWEALTH OF PENNSYLVANIA, 6414 t County ss: On this, the /Y day of / qe'� L , before me,the undersigned officer,personally appeared RONALD E JUMPER AND LINDA C JUMPER known to me(or satisfactorily proven) to be the persot whose name(' are subscribed to the within instrument and acknowledged that he/s they xecute the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: 11—Ly-QF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Karen L.Burch,Notary Public n Mechanicsburg Boro,Cumberland County My Commission Expires Nov.24,2009 Member.Pennsylvania Association of Notaries i 641 '0ii Title of Officer Certificate of Residence 11 r YJ ,do hereby certify that the correct address of the within-named Mortgagee is 0. BOX 11701, NEWARK, NJ 071019701 Witness my hand this L� day of Agent of Mortgagee PENNSYI-VANIA-Single Family-Fannie MaafFreddle Mac UNIFORM INSTRUMENTForm 3039 1101 VMP® VMPS(PA)(0804 00 Wolters Kluwer Financial Services Initials: Page 17 of 17 Stewart Title Guaranty Company Commitment Number: 2009030054' SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: TRACT#1 ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T473, said point being a spike in the center line of West Pine Street Extended, said point also being North 82 degrees 30 minutes West, 25 feet from the line of land now or formerly of Russell S. Starner; thence along said (and now or formerly of Russell S. Sta mer, South 2 degrees 23 minutes East, 200 feet to a stake at line of land now or formerly of Samuel C. Garonzik,et al; thence along the latter. North 82 degrees 30 minutes West, 100 feet to a stake: thence still along the same, North 2 degrees 23 minutes West. 200 feet to a spike in the center line of Township Road T473(West Pine Street Extended);thence along the latter, South 82 degrees 30 minutes East, 100 feet to a spike, the place of BEGINNING. CONTAINING .452 acres according to a survey of Thomas A. Neff, R. S., dated October 24, 1969. BEING improved with a five-room ranch type dwelling and carport, known as 309 Sandbank Road, Mount Holly Springs, Pennsylvania. TRACT#2 ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Carl David Bert, Registered Surveyor, dated March 11, 1983, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 43, Page 27, and being Lot No.3B as shown on said Plan, as follows: BEGINNING at an existing iron pin at the Southwest corner of land now or formerly of Herbert J. George and Cathrine B.George, which point is also on the dividing line between Lot No. 3A and 3B on said Plan;thence along said dividing line between Lot No 36 and land of Herbert J. George and Cathrine B. George, South 88 degrees 45 minutes 04 seconds East, a distance of 100 feet to an existing iron pin on the dividing line between Lot No. 3B and 3C as it appears on said Plan; thence along said dividing line, South 08 degrees 59 minutes 37 seconds East,a distance of 25 feet to an iron pin in line of Lot No. 3A;thence along the dividing line between Lot Nos. 3B and 3A, North 88 degrees 45 minutes 04 seconds West, a distance of 100 feet to an iron pin; thence continuing along Lot No. 3A, North 08 degrees 59 minutes 37 seconds West, a distance of 25 feet to an existing iron pin, the place of BEGINNING. Parcel#40-32-2334-054 ALTA Commitment Schedule C (2009030054.PFD/2009030054/40) u ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE - CARLISLE, PA 17013 = I Y • - c a 717-240-6370 Instrument Number-200919727 Recorded On 6/11/2009 At 12:59:30 PM *Total Pages- 19 *Instrument Type-MORTGAGE Invoice Number-45778 User ID-KW *Mortgagor-JUMPER,RONALD E *Mortgagee-WELLS FARGO BK N A *Customer-CORE SETTLEMENT SERVICES *FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $10.00 JUSTICE DO NOT DETACH . RECORDING FEES — $39.50 RECORDER OF DEEDS Thise a is now art PARCEL CERTIFICATION $10.00 p g P FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $76.50 I Certify this to be recorded in Cumberland County PA i of CU ,O RECORDER O D EDS Urso *-Information denoted by an asterisk may change during the verification process and may not be reflected on this page. OOOPUM 1111111 IN III SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson TIED -OFFICE Sheriff OF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor ofnarrLrpl,, 2014 WC 12 PM 2: 22 CUMBERLAND COUNTY OFFICE GFTHE HER!€= PENNSYLVANIA Wells Fargo Bank, N.A. vs. Arthur T. Liebrum Case Number 2014-4267 SHERIFF'S RETURN OF SERVICE 07/30/2014 06:10 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Arthur T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 3 Teejay Drive, South Middleton Township, Mount Holly Springs, PA 17065. This is the defendant's father's address. 08/07/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Arthur T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 309 Sandbank Road, South Middleton, Mt. Holly Springs, PA 17065. Mortgaged address is vacant. SHERIFF COST: $40.91 SO ANSWERS, August 07, 2014 CountySuite Sheriff, Teleosoft. Inc. 'a<-2 RON R ANDERSON, SHERIFF IL..E J�"�-7OFFti(✓�j.j ;J . if I RO 1 HE MONO 1AR1 t 20111 AUG 25 AM le: 21 CUMBERLAND COUNTY PENNSYLVANIA McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14-4267 CIVIL PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above -captioned matter. McCABE, : ERG BY: D C �., AY, P.C. [ ] Terrenc;, . ► 'cC.. _, Esq. [ ] Edward . Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esquire Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY .:F T F v?iERIFF 251ii SEP -14P;i 2' 31 CUMBERLAND CU TY PENNS Wells Fargo Bank, N.A. Case Number vs. Arthur T. Liebrum 2014-4267 SHERIFF'S RETURN OF SERVICE 08/28/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Arthur T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint to Quiet Title as "Not Found" at 801 Sandbank Road, Lot 17, Dickinson Township, Mt. Holly Springs, PA 17065. Deputies were advised by the current tenant that the defendant no longer resides at this addresses but may have been a previous tenant. SHERIFF COST: $35.91 SO ANSWERS, August 28, 2014 RONR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleoseft, Inc. McCABE, WEISBERG AND CONWAY, P.C. BY: JOSEPH I. FOLEY, ESQUIRE - ID # 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant P of HONOL- k SEP 12 All 1G: i t CUMBERLAND COUNT'S PENNSYLVANIA Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14 -4267 -Civil MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 1. Plaintiff attempted to personally serve a true and correct copy of the Complaint in Quiet Tiltle upon the Defendant, Arthur Liebrum, at his last -known address of 3 Teejay Drive, South Middleton Township, Mount Holly Springs, Pennsylvania 17065. The process server was not able to serve the Defendant because the Defendant was not found at this address. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit 2. Plaintiff attempted to personally serve a true and correct copy of the Complaint in Quiet Title upon the Defendant, Arthur Liebrum, at his last -known address of 801 Sandbank Road, Lot 17, Dickinson Township, Mount Holly Springs, Pennsylvania 17065. The process server was not able to serve the Defendant because per the current tenant, the Defendant no longer resides at this address. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit "B". 3. Plaintiff attempted to serve a true and correct copy of the Complaint in Quiet Title upon the Defendant's mortgaged property of 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. The process server was not able to serve the Defendant. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof, and marked as Exhibit "C". 4. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendant and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "D". 5. As a result of the investigation, a special Order of Court is required permitting service by certified mail at the Defendant's last -known addresses. 6. No judge has ruled upon any other issue in this matter or in any related matter. 7. No attorney has entered an appearance in this matter on behalf of Defendant and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 8. If service cannot be made on the Defendant, Arthur Liebrum, the Plaintiff will be prejudiced. WHEREFORE, Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve the Complaint in Quiet Title upon the Defendant, Arthur Liebrum, certified mail, return receipt requested, to the last -known address of Defendant and the mortgaged premises known in this herein action as 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. McCABE '.G AND CO► Y, P.C. BY: [ 1 Joseph oley, Esquire Attorney or Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: JOSEPH I. FOLEY, ESQUIRE - ID # 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14 -4267 -Civil MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. McCABE, W BY: G AND CONWAY, P.C. [ ] Joseph I. 'fey, Esquire Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: JOSEPH I. FOLEY, ESQUIRE - ID # 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14 -4267 -Civil CERTIFICATION OF SERVICE The undersigned attorney for the Plaintiff hereby certifies that he served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the,th day of September, 2014, upon the following: Arthur Liebrum 3 Teejay Drive South Middleton Township Mount Holly Springs, Pennsylvania 17065 Arthur Liebrum 801 Sandbank Road, Lot 17 Dickinson Township Mount Holly Springs, Pennsylvania 17065 Arthur Liebrum 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 E, WEISB RG A AY, P.C. BY: [ ] Jose. Foley, Esquire Attorney for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of this jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCAB G Al 1CONWAY, P.C. BY: [ ] Joseph I. oley, Esquire Attorney for Plaintiff Wells Fargo Bank, N.A. v. Arthur Liebrum Cumberland County; CCP; Number 14 -4267 -Civil File Number: 78476 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY "'`�1tp Dl FImot.'/,r Wells Fargo Bank, N.A. Case Number vs. Arthur T. Liebrum 2014-4267 SHERIFF'S RETURN OF SERVICE .07/30/2014 06:10 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Arthuf T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 3 Teejay Drive, South Middleton Township, Mount Holly Springs, PA 17065. This is the defendant's father's address. 08/07/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Arthur T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 309 Sandbank Road, South Middleton, Mt. Holly Springs, PA 17065. Mortgaged address is vacant. SHERIFF COST: $40.91 SO ANSWERS, August 07, 2014 Cc mIvSite Sheriff, r k,osoff RONNY R ANDERSON, SHERIFF Exhibit A Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY y,\op DI CZ! 4f/r�, Wells Fargo Bank, N.A. vs. Arthur T. Liebrum Case Number 2014-4267 SHERIFF'S RETURN OF SERVICE 08/28/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Arthur T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint to Quiet Title as "Not Found" at 801 Sandbank Road, Lot 17, Dickinson Township, Mt. Holly Springs, PA 17065. Deputies were advised by the current tenant that the defendant no longer resides at this addresses but may have been a previous tenant. SHERIFF COST: $35.91 SO ANSWERS, August 28, 2014 Exhibit B {c) County Suite ShenIf; Tblr:accfi Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �Q�`ov of CiIinbr,.r fr h OFFICE' OF'!?6$' RIFF Wells Fargo Bank, N.A. vs. Arthur T. Liebrum Case Number 2014-4267 SHERIFF'S RETURN OF SERVICE 07/30/2014 06:10 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry Tor the within named Defendant to wit: Arthur T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 3 Teejay Drive, South Middleton Township, Mount Holly Springs, PA 17065. This is the defendant's father's address. / 08/07/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry -for the within named Defendant to wit: Arthur T. Liebrum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found"att09 Sandbank Road, South Middleton, Mt. Holly Springs, PA 17065.: Mortgaged address is vacant. - } SHERIFF COST: $40.91 SO ANSWERS, August 07, 2014 :u4 ,Et4 : C (c) CountvSuito Shon6, Tokosoft Inc. •V- ice__ «..♦s"__r. \ `\.\ '..'2. AFFIDAVIT THOF GOOD 1111111 1 11111 11111 11111 11111 1111 1111 FAI INVESTIGATION *249640* File#:302-2860PA Subject: Arthur Liebrum Last -known Address: 309 Sandbank Road , Mount Holly Springs, PA 17065 STATE OF NEW YORK COUNTY OF SUFFOLK ss.: Crystal D. Navas, the undersigned, being duly sworn, deposes and says that I am over the age of eighteen and not a party to this action. I reside in the STATE OF NEW YORK. I conducted a good faith investigation into the whereabouts of the Arthur Liebrum at the last-known/property address indicated below and the extent of the investigation and the results are as follows: Date DueDiligence Remarks 08/15/2014 PROPERTY/LAST-KNOWN ADDRESS: 309 Sandbank Road, Mount Holly Springs, PA 17065 08/15/2014 INQUIRY OF LOCAL TELEPHONE COMPANY: Directory Assistance: Search results list the telephone number of 717-486-3135 registered to the subject. Results also list 3 Tee Jay Dr, Mount Holly Springs, PA 17065 associated with the subject. 08/15/2014 INTERNET SEARCH: Search results provided 801 Sandbank Rd, 17, Mount Holly Springs, PA 17065 and 3 Tee Jay Dr, Mount Holly Springs, PA 17065 as the most recent addresses for the subject. Results provide the telephone numbers of 717-961-1433, 717-422-8353, 717-440-0780, and 315-778-5951 associated with the subject. 08/15/2014 DEATH RECORDS: Social Security Death Index Search was unable to locate a death record for the subject. 08/15/2014 LOCAL TAX RECORD INQUIRY: Search was unable to confirm a mailing address for the above stated property address. I, Crystal D. Navas, reviewed and signed this affidavit on 08/15/2014. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge, information and belief. Sworn to and subscribed before me on C -,U ,20 t`1 ary Public, TRACY L SAU$BURY Notary Public, State of NewYett 01SA6295$30 Qualtfled In Suffolk County Coramliiton Expkes, March 24,2AI Crysta '• . Navas Attorney Outsourcing Support Services, Inc. Agency License #2004244 -DCA 1 Huntington Quadrangle, Suite 2SO4 Melville, NY 11747 (516) 284-5850 Firm Ref#: 302-2860PA a MR Exhibit D Free people search and contact details for Arthur T Liebrum I WhitePages Page 1 of 1 Advertisement: Take control of your credit with Equifax Completer', Premier. Arthur T Liebrum Age: Phone number 717-486-3135 Address 3 Tee Jay DrMount Holly Springs, PA 17065-1142 People Arthur may know Barbara E Liebrum Larry L Liebrum Sr Larry L Liebrum Ii Larry L Liebrum Previous locations Oswego, NY Altmar, NY Mount Holly Springs, PA Lewisberry, PA © 2014 WhitePages Inc. - Privacy Policy and Terms of Use Print this page \r/ Send them flowers 1-800-Flowers.com http://www.whitepages.com/name/Arthur-T-Liebrum/Mount-Holly-Springs-PA/3 gm 1 jic 8/15/2014 Tracers Information Specialists, Inc. - Premium People Search Page 1 of 2 Premium People Search 35 Records Search Criteria SSN: 163-60-2598 Name Address SSN / DOB Phone LIEBRUM ARTHUR T 801 SANDBANK RD 17 5x MOUNT HOLLY SPRINGS PA 17065 - 1152 Reported: 01/31/1993 - 08/13/2014 County: Cumberland Cell: (717)961-1433 Cell: (717)422-8353 Cell: (717)440-0780 Cell: (315)778-5951 LIEBRUM ARTHUR T 3 TEE JAY DR 3x MOUNT HOLLY SPRINGS PA 17065- 1142 Reported: 06/18/1992 - 08/10/2014 County: Cumberland Cell: (717)440-0780 LIEBRUM ARTHUR T PO BOX 64 2x LEWISBERRY PA 17339-0064 Reported: 04/26/2011 - 10/19/2011 County: York LIBRUM ARTHUR PO BOX 64 1x LEWISBERRY PA 17339-0064 Reported: 04/26/2011- 10/19/2011 County: York LIEBRUL ARTHUR T PO BOX 64 1x LEWISBERRY PA 17339-0064 Reported: 04/26/2011 - 10/19/2011 County: York LIBRUM ARTHUR 3 TEE JAY DR 1x MOUNT HOLLY SPRINGS PA 17065- 1142 Reported: 06/18/1992 - 09/01/2011 County: Cumberland LIEBRUL ARTHUR T 3 TEE JAY DR 1x MOUNT HOLLY SPRINGS PA 17065- 1142 Reported: 06/18/1992 - 09/01/2011 County: Cumberland LIEBRUM ARTHUR T 2536 COUNTY ROUTE 22 GAR 2x ALTMAR NY 13302-2208 Reported: 06/22/2009 - 06/22/2009 County: Oswego LIEBRUL ARTHUR T 2536 COUNTY ROUTE 22 GAR 1x ALTMAR NY 13302-2208 Reported: 06/22/2009 - 06/22/2009 County: Oswego . LIBRUM ARTHUR 2536 COUNTY ROUTE 22 GAR 1x ALTMAR NY 13302-2208 Reported: 06/22/2009 - 06/22/2009 County: Oswego LIEBRUL ARTHUR T 51 E 6TH ST 1x OSWEGO NY 13126-2244 Reported: 09/26/2007 - 06/17/2008 County: Oswego LIBRUM ARTHUR 51 E 6TH ST lx OSWEGO NY 13126-2244 Reported: 09/26/2007 - 06/17/2008 County: Oswego LIEBRUM ARTHUR T 51 E 6TH ST 2x OSWEGO NY 13126-2244 Reported: 09/26/2007 - 06/17/2008 County: Oswego LIEBRUM ARTHUR T AKA: LIEBRUM ARTHUR PO BOX 378 2x ALTMAR NY 13302-0378 Reported: 05/01/2008. 05/01/2008 County: Oswego LIEBRUL ARTHUR T PO BOX 31 1x OSWEGO NY 13126-0031 Reported: 04/13/2007 - 01/14/2008 County: Oswego LIEBRUM ARTHUR T PO BOX 31 7x OSWEGO NY 13126-0031 Reported: 10/31/1996 - 01/14/2008 County: Oswego LIBRUM ARTHUR PO BOX 31 1x OSWEGO NY 13126-0031 Reported: 04/13/2007 - 01/14/2008 County: Oswego LIEBRUM ARTHUR T 444 DAN MAINHILL RD 4x NORWICH NY 13815 Reported: 01/12/2008 - 01/12/2008 County: Chenango 444 DAN MAIN RD ' 1x https://www.tracersinfo.com/SearchCentral/printable.php 8/15/2014 Tracers Information Specialists, Inc. - Premium People Search Page 2 of 2 LIEBRUL ARTHUR T NORWICH NY 13815-3433 Reported: 04/03/2006 - 12/16/2007 County: Chenango LIBRUM ARTHUR 444 DAN MAIN RD ix NORWICH NY 13815-3433 Reported: 04/03/2006 - 12/16/2007 County: Chenango LIEBRUM ARTHUR T 444 DAN MAIN RD 2x NORWICH NY 13815-3433 Reported: 04/03/2006. 12/16/2007 County: Chenango LIEBRUL ARTHUR T 309 SANDBANK RD 1x MT HOLLY SPGS PA 17065-1132 Reported: 04/08/2001 - 12/08/2007 County: Cumberland LIBRUM ARTHUR 309 SANDBANK RD 1x MT HOLLY SPGS PA 17065-1132 Reported: 04/08/2001 - 12/08/2007 County: Cumberland LIEBRUM ARTHUR T 309 SANDBANK RD 2x MT HOLLY SPGS PA 17065-1132 Reported: 04/08/2001 - 12/08/2007 County: Cumberland LIEBRUM ARTHUR T AKA: LIEBRUM ARTHUR PO BOX 31 4x OSWEGO NY 13126-0031 Reported: 05/01/2007 - 05/01/2007 County: Oswego LIEBRUM ARTHUR T 444 DAN MAIN RD 2x NORWICH NY 13815-3433 Reported: 02/01/2006 - 02/01/2006 County: Chenango LIEBRUM ARTHUR T 309 SANDBANK RD 3x MT HOLLY SPGS PA 17065-1132 Reported: 09/01/2000 - 10/15/2005 County: Cumberland LIEBRUM ARTHUR T 309 SANDBANK RD 3x MOUNT HOLLY SPRINGS PA 17065- 1132 Reported: 02/01/2001 - 02/25/2004 County: Cumberland Landline: (717)486-8054 LIEBRUM ARTHUR T RR 1 POB 74E 3x ELLIOTTSBURG PA 17024 Reported: 11/13/2000 - 11/13/2000 County: Perry LIEBRUM ARTHUR T 801 SANDBANK RD 17 1x MT HOLLY SPGS PA 17065-1152 Reported: 08/24/1998 - 10/07/1999 County: Cumberland MAST ROBIN L 1503 RIDGE AV 3x NEW CASTLE PA 16101-1415 Reported: 01/01/1998 - 01/01/1998 County: Lawrence LIEBRUM ARTHUR T 801 SANDBANK RD 17 2x MOUNT HOLLY SPRINGS PA 17065- 1152 Reported: 11/01/1996 -11/01/1996 County: Cumberland LIEBRUM ARTHUR T 801 SANDBANK RD 17 1x MT HOLLY SPRINGS PA 17065 Reported: 11/01/1996 - 11/01/1996 County: Cumberland LIEBRUM ARTHUR T 3 TEE JAY DR 4x MOUNT HOLLY SPRINGS PA 17065- 1142 Reported: 06/18/1992 - 05/12/1996 County: Cumberland LIEBRUM ARTHUR T 3 TEEJAY DR 2x MOUNT HOLLY SPRINGS PA 17065 Reported: 12/02/1994 - 12/02/1994 County: Cumberland https://www.tracersinfo.com/SearchCentral/printable.php 8/15/2014 Arthur Liebrum Social Security Death Index (SSDI) Records - Social Security Death Inde... Page 1 of 2 Search All Collections Newspapers Recent Obituaries Newspaper Archives Historical Obituaries Birth Records Marriage Records Passenger Lists Newspaper Articles Legal, Probate & Court Photos & Illustrations -vr More Other Genealogy Records Social Security Death Index Historical Books Historical Documents African-Arnerlcan N wspapers Irish -American Newspapers Log In 1 $ubscribe Home About Us I Help 1 Learning Center Store GIFT MEMBERSHIPS Questions? Call 1-866-641-3297 Arthur Liebrum Death Records in the Social Security Death Index (SSDI) In compliance with Section 203 ("Restriction on Access to the Death Master File") of the Budget Act of 2013, we are no longer able to display SSDI records for individuals who have dled within the previous 3 years. You can learn more here. Discover Your Family's Past in: Liebrum family in Newspaper Archives (1690-20101 1 Llebrum family Historical Obituaries (1704-19 Search 90 of GenealoqvBank f r the Jebrum family .1.iebrum family Recent Obituaries (1977-Todayl Your search for Arthur Liebrum did not match any Items In Social Security Death Index. Suggestions • Search again without the first name "arthur" Searching with only a family narne should open up your search, and may even yield new family history discoveries. • Search wain without date requirements If you're sure your ancestor Is in the Social Security Death Index but can't locate him or her, there may be a discrepancy In recorded dates. Try removing the birth and death years from your search. nother search! Last Name First Name Need Help Searching Your Ancestors? 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Terms Of Privacy Policy Contact Us Service uvunthouovon|mo.com.a better way to accepublic recordsTM Website and Services Copyright ©2000 CourthouseOnline,Com, Inc. Copyright and ownership of courthouse data is held by each respective courthouse. All information provided on this site 15 believed to be reliable but is not guaranteed and should be independently verified. 1 AGREE that my use of this site is governed by the Terms of Service and Privacy Policy. http://www.courthouseonline.com/A0PropertyRec.asp?State=PA&County=Cumberland&... 8/15/2014 / r_1e I _ f is Fri Q1.`F C PROIH ,'. 0 A[; ; . SEP 19 PM 12: 514 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant Cumberland County Court of Common Pleas Number 14 -4267 -Civil ORDER AND NOW, this ri day o ' ,2014, the Plaintiff is granted leave to serve process in this quiet title action upon the Defendant, Arthur Liebrum, by certified mail, return receipt requested, to his last -known addresses of 3 Teejay Drive, South Middleton Township, Mount Holly Springs, Pennsylvania 17065 and 801 Sandbank Road, Lot 17, Dickinson Township, Mount Holly Springs, Pennsylvania 17065 and 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. copy,-,2.,L;c1, J .=01.t 9n4frf B J. THE IC:.' H E PROTNONOTAL`, 21.1k SEP 24 PQM 1: G14 CUMBERLAND COU'NT'S FCNNSYLV,ANIA McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Cumberland County Plaintiff Court of Common Pleas Attorneys for Plaintiff v. Number 14 -4267 -Civil Arthur Liebrum Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above -captioned matter. McCAB . " EISBER t AND BY: ter/ .C. [ ] Terrence J. cCabe, Esq. [ arc S. Weisberg, Esq. [ ] Edward 0. Conway, Esq. [ ] arg. et Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. , ] Lena Kravets, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff am If II 75?a,116 Ck4 ;D)i O THE- PRO TIIJ1; U 2014 OCT- 4:11,:: CUHL3ERLAND Cop.,T'' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - I.D # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14 -4267 -Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF PHILADELPHIA The undersigned attorney being duly sworn according to law, deposes and says that the following is true and correct to the best of his / her knowledge and belief: 1. That he / she is counsel for the above-named Plaintiff; 2. That on September 29, 2014, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Quiet Title upon the Defendant, Arthur Liebrum, by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his last - known addresses of 3 Teejay Drive, South Middleton Township, Mount Holly Springs, Pennsylvania 17065, 801 Sandbank Road, Lot 17, Dickinson Township, Mount Holly Springs, Pennsylvania 17065, and 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. A true and correct copies of the letters and certified receipts, are attached hereto, made a part hereof, and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS )DAY OF • AR PBLIC •1„u Lef. TH OFPENNISTIMMA NOTARIAL SEAL S TRAVASCIO, Notavy Pic City Com inn f alfa 19,2018 E, WEIS D RG ANWCONWA BY: [ ] T- ence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff P.C. [ Jlvlarc S. Weisberg, Esq. [ -LIM garet Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ]-Joseph I. Foley, Esq. [ ] Lena Kravets, Esquire `/.7.i; if SEP 19 C W'IDERL. AND CIANC PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant ,64Af‘ AND NOW, this 0 day o Cumberland County Court of Common Pleas Number 14 -4267 -Civil ORD R •-1'61d 1 , 2014, the Plaintiff is granted leave to serve process in this quiet title action upon the Defendant, Arthur Liebrum, by certified mail, return receipt requested, to his last -known addresses of 3 Teejay Drive, South Middleton Township, Mount Holly Springs, Pennsylvania 17065 and 801 Sandbank Road, Lot 17, Dickinson Township, Mount Holly Springs, Pennsylvania 17065 and 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. J. ' LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 210 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914) 636-8901 SUITE 201 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 130 DELAWARE CORPORATE CENTER I ONE RIGHTER PARKWAY WILMINGTON, DE 19803 (302) 409-3520 FAX 855-425-1980 Arthur Liebrum 801 Sandbank Road, Lot 17 Dickinson Township Mount Holly Springs, Pennsylvania 17065 SUITE 1400 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 September 29, 2014 Re: Wells Fargo Bank, N.A. v. Arthur Liebrum Cumberland County; CCP; Number 14 -4267 -Civil Dear Arthur Liebrum: SUITE 800 312 MARSHALL AVENUE LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also scrvicing the District of Columbia SUITE 203 722 E. MARKET STREET LEESBURG, VA 20176 (571) 449 9350 FAX: (855) 845-2585 SUITE 2S06 1 HUNTINGTON QUADRANGLE MELVILLE, NY 11747 (631) 812-4084 FAX: (855) 845-2584 Enclosed please find a true and correct copy of Complaint in Quiet Title, along with a copy of the signed Order dated September 19, 2014, the original of which has been filed against you in regard to the above -captioned matter. Very truly yours, Rachel Weres Legal Assistant for: McCabe, Weisberg and Conway, P.C. SENT VIA CERTIFIED MAIL NUMBER 7013 1090 0001 5957 1515 RETURN RECEIPT REQUESTED Exhibit A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. SUITE 210 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914) 636-8901 SUITE 201 216 HADDON AVENUE WESTMONT, NJ 08108 (856)858-7080 FAX (856) 858-7020 SUITE 130 DELAWARE CORPORATE CENTER! ONE RIGHTER PARKWAY WILMINGTON, DE 19803 (302) 409.3520 FAX 855-425-1980 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 1400 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 September 29, 2014 Arthur Liebrum 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 Re: Wells Fargo Bank, N.A. v. Arthur Liebrum Cumberland County; CCP; Number 14 -4267 -Civil Dear Arthur Liebrum: SUITE 800 312 MARSHALL AVENUE LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 203 722 E. MARKET STREET LEESBURG, VA 20176 (571) 449 9350 FAX: (855) 845-2585 SUITE 2S06 1 HUNTINGTON QUADRANGLE MELVILLE, NY 11747 (631) 812-4084 FAX: (855) 845.2584 Enclosed please find a true and correct copy of Complaint in Quiet Title, along with a copy of the signed Order dated September 19, 2014, the original of which has been filed against you in regard to the above -captioned matter. Very truly yours, Rachel Weres Legal Assistant for: McCabe, Weisberg and Conway, P.C. SENT VIA CERTIFIED MAIL NUMBER 7013 1090 0001 5957 1522 RETURN RECEIPT REQUESTED Exhibit A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. McCABE, WEISBERG AND CONWAY, P.C. BY: Joseph I. Foley, Esquire Attorney ID # 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. v. Arthur Liebrum Attorney for Plaintiff Cumberland County Court of Common Pleas No. 14 -4267 -Civil MOTION FOR RELIEF IN QUIET TITLE `), CD Plaintiff, Wells Fargo Bank, N.A., by and through its attorneys, McCabe, Weisberg and Conway, P.C., files this Motion for Relief in Quiet Title pursuant to Rule 1066 Pa. R. C. P. against the Defendant, Arthur Liebrum, and in support thereof avers the following: 1. This is an Action in Quiet Title by which Plaintiff requests that a certain deed transferring title to the subject property, on which Plaintiff now holds a mortgage, be deemed a valid transfer of the entire property and all interests existing in the property at the time the deed was delivered, notwithstanding that an attorney in fact executed said deed on the Defendant's behalf and no power of attorney agreement appears in the land records of Cumberland County. Attached as Exhibit "A" is a copy of Plaintiff's Complaint in this matter. 2. Attached as Exhibit "B" is an affidavit stating that a Complaint containing a Notice to Defend has been served upon the Defendant and that no response has been filed. 3. Pa. R.C.P. 1066(a), governing the form of judgment or order in actions in quiet title, states the court shall grant appropriate relief upon affidavit that a complaint containing a notice to defend has been served and that the Defendant has not filed an answer. 4. Pa. R.C.P. 1066(b) further states that "upon granting relief to the plaintiff, the court. .. (2) shall enter a final judgment that a document, obligation or deed affecting a right, lien, title or interest in the land is cancelled or is valid, invalid or discharged or that a copy of a lost plan, document, obligation or deed is an authentic copy..." 5. In accordance with Rule 1066 Pa. R. C. P., Plaintiff requests the court enter judgment for Plaintiff and against Defendants and to grant the relief requested in Plaintiff's complaint. 6. No attorney has entered an appearance in this matter on behalf of Defendant and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion 7. Judge Edward Guido has previously rule a Motion for Alternate Service in this matter. WHEREFORE, Plaintiff requests that this Court enter an Order granting final judgment in favor of Plaintiff, Wells Fargo Bank, N.A. and against the Defendant, Arthur Liebrum, for such relief as was requested in Plaintiff's Complaint. Respectfully submitted, cCabe, W isb Attorney for Plaintiff . Joseph I. Foley, Esquire ay, P.C. EXHIBIT A McCABE, WEISBERG AND CONWAY, P.C. By Joseph I. Foley, Esquire Attorney Identification Number 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. 3476 Stateview Boulevard Fort Mill, SC 29715 Plaintiff, v. Arthur Liebrum 3 Tee Jay Drive Mount Holly Springs, PA 17065 CIVIL DIVISION No. Defendant. CIVIL ACTION / COMPLAINT TO QUIET TITLE Plaintiff, Wells Fargo Bank, N.A., hereby complains of defendant Arthur Liebrum, as follows: The Parties 1. The Plaintiff is Wells Fargo Bank, N.A., a national banking association duly organized and doing business at the above captioned address. 2. The Defendant is Arthur Liebrum, a prior owner of the property which is the subject of this action and his last known address is 3 Tee Jay Dr., Mount Holly Springs, PA 17065-1142. The Property 3. The real property which is the subject of this action is located in the County of Cumberland, and Commonwealth of Pennsylvania and is known as 309 Sandbank Road, Mt. Holly Springs, PA, 17065, and is more particularly described in the deed attached hereto and marked as Exhibit "A". The Deeds 4. Title to the property is vested in Ronald E. Jumper and Linda C. Jumper, by virtue of a Deed from Raymond J. Gregory and Linda B. Gregory, his wife, and Arthur Liebrum and Emily Liebrum, his wife, dated May 21, 2006 and recorded on June 2, 2006 in the Office of the Recorder of Deeds for Cumberland County in Mortgage Book 274, Page 4529 (the "Jumper Deed"). A true and correct copy of the Jumper Deed is attached as Exhibit "A". 5. Prior to the delivery and recording of the Juniper Deed, title to the property was vested in Raymond J. Gregory, who held a 3/4 interest in the property, and Arthur Liebrum and Emily Liebrum, who together held a 1/4 interest in the property as tenants by the entireties, by virtue of a deed dated August 24, 2000 and recorded on August 28, 2000 in the Office of the Recorder of Deeds for Cumberland County in Mortgage Book 227, Page 1121 (the "Liebrum Deed"). The relationship between the interest of Raymond J. Gregory and the interest of Arthur and Emily Liebrum was a tenancy in common. A true and correct copy of the Liebrum Deed is attached hereto and marked as Exhibit "B". 6. The Jumper Deed was executed by Raymond J. Gregory, Linda B. Gregory, Emily Liebrum, and Arthur Liebrum by Emily Liebrum as Attorney -in -Fact for Arthur Liebrum, her husband. See Exhibit "A". 7. Although the Jumper Deed was executed by Emily Liebrum on behalf of Arthur Liebrum as his attorney in fact, no power of attorney was ever recorded in the Office of the Recorder of Deeds of Cumberland County. 8. The Jumper Deed was acknowledged before a notary public who stated that the signatories to the Jumper deed had satisfactorily proven that they were persons whose names were subscribed on the instrument and had acknowledged that they executed the same for the purposes therein stated. 9. Upon information and belief, a power of attorney between Arthur Liebrum and Emily Liebrum was duly executed and it was intended by all parties that such power of attorney would be recorded at the same time as the Jumper Deed. 10. Upon information and belief, said power of attorney was produced for the notary public before whom the deed was signed and acknowledged as satisfactory proof that Emily Liebrum was, in fact, acting on behalf of Arthur Liebrum under a power of attorney. 11. Upon information and belief, the Jumper Deed was intended by all parties, including Arthur Liebrum, to be a valid transfer of the entire property to Ronald E. Jumper and Linda C. Jumper. The Wells Fargo Loan 12. On May 14, 2009, Wells Fargo Bank, N.A. extended to Ronald E. Jumper and Linda C. Jumper a loan in the amount of $153,000.00 (the "Wells Fargo Loan"). 13. Settlement in connection with the Wells Fargo Loan occurred on May 14, 2009. 14. The Wells Fargo Loan was intended to be secured by a first -position mortgage against the entire property. 15. To secure payment of the Wells Fargo Loan, on May 14, 2009, Ronald E. Jumper and Linda C. Jumper, husband and wife, executed and delivered a mortgage in favor of Wells Fargo Bank, N.A., Plaintiff herein, against the property ("the Mortgage"). 16. The Mortgage was thereafter recorded in the Office of the Recorder of Cumberland County as Instrument Number 200919727. A true and correct copy of the Mortgage is attached hereto as Exhibit "C" and incorporated herein by reference 17. The failure to record the power of attorney between Arthur and Emily Liebrum at the same time as the Jumper Deed was recorded creates a cloud upon title and adversely affects plaintiffs interest in the property. Count 1 - Quiet Title 18. All paragraphs above are incorporated herein by reference. 19. Pa. R.C.P. 1061(b) provides in part: "(b) The action [to quiet title] may be brought to: (1) to compel an adverse party to commence an action of ejectment; (2) where an action of ejectment will not lie, to determine any right, lien, title or interest in the land or determine the validity or discharge of any document, obligation or deed affecting any right, lien, title or interest in land; (3) to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land; or (4) to obtain possession of land sold at a judicial or tax sale." 20. Pa.R.C.P. 1066, relating to "form of judgment or order" in a quiet title action, provides: "(a) The Court shall grant appropriate relief upon affidavit that a complaint containing a notice to defend has been served and that the defendant has not filed an answer, or after a hearing or trial on the pleadings or merits. (b) Upon granting relief to the plaintiff, the court: (1) shall order that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the plaintiff set forth in his complaint, unless the defendant takes such action as the order directs within thirty (30) days thereafter. If such action is not taken within the 30 -day period, the prothonotary on praecipe of the plaintiff shall enter final judgment; (2) shall enter a final judgment that a document, obligation or deed affecting a right, lien, title or interest in the land is canceled or is valid, invalid or discharged or that a copy of a lost plan, document, obligation or deed is an authentic copy; (3) shall enter a final judgment ordering the defendant, the prothonotary, or the recorder of deeds to file, record, cancel, surrender or satisfy of record, as the case may be, any plan, document, obligation or deed determined to be valid, invalid, satisfied or discharged, and to execute and deliver any document, obligation or deed necessary to make the decree effective; or (4) shall enter any other order necessary for the granting of proper relief." 21. Pursuant to Pa.R.C.P. 1066, Plaintiff respectfully requests the Court to declare that the Jumper Deed, dated May 21, 2006, and recorded in the Office of the Recorder for Cumberland County in Mortgage Book 274, Page 4529, is deemed to be a valid transfer of the entire Property which is the subject of this action, including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order declaring the Jumper Deed to be a valid transfer of the entire property that is the subject of this action including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. Count II - Quiet Title 22. All of the preceding paragraphs are incorporated herein by reference as if more fully set forth. 23. Pursuant to Pa.R.C.P. 1066, Plaintiff respectfully request the Court to declare that the Wells Fargo Mortgage is a valid and perfected mortgage lien against the entire property which is the subject of this action, including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order declaring the Wells Fargo Mortgage to be a valid and perfected mortgage lien against the entire property which is the subject of this action, including that 1/4 interest in the property previously held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. Count III - Quiet Title 24. All of the preceding paragraphs are incorporated herein by reference as if more fully set forth. 25. Pursuant to Pa.R.C.P. 1066, Plaintiff respectfully requests the Court to order that Arthur Liebrum be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest held by Wells Fargo Bank, N.A. pursuant to the Wells Fargo Mortgage or any successor in interest to Wells Fargo Bank, N.A. thereunder. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order forever barring Arthur Liebrum from asserting any right, lien, title or interest in the land inconsistent with the interest held by Wells Fargo Bank, N.A. pursuant to the Wells Fargo Mortgage or any successor in interest to Wells Fargo Bank, N.A. thereunder. Respectfully submitted, McCABE, WEISBERG & CONWAY, P.C. By: J ph I. Foley, Es Attorneys for Plaintiff VERIFICATION Angelica Hernandez, hereby states that she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that she is authorized to make this Verification, and verify that the statements made in the foregoing Complaint in Quiet Title are true and correct to the best of her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. An cl i ca 1-1 iandez Vice President Loan Documentation Wells Fargo Bank, N.A. Date: EXHIBIT A Parcel #40-32-2334-054 THIS DEED THIS INDENTURE, MADE THE 4e/d9 day of of TWO THOUSAND SIX (2006). FtJ3ERT ?. ZIE .LER BETWEEN: RAYMOND J. GREGORY and UNDA B. GREGORY, his wife, of 243 Grayson Drive, Norwich, New York; and ARTHUR LIEBRUM and EMILY LIEBRUM, his wife, of Norwich, New York; hereinafter called the, GRANTORS AND RONALD E. JUMPER and LINDA C. JUMPER, his wife, of Cumberland County, Penrisylvania, hereinafter called the, GRANTEES WITNESSETH, that the said Grantors, for and in consideration of the sum of One Hundred Sixty -Five Thousand and 001100 ($165,000.00) Dollars, lawful money of the United States of America, unto them well and truly paid by the Grantee, at or before the sealing and delivery hereof, the receipt whereof is hereby acknowledged, have granted, bargained and sold, released and confirmed, and by these presents, grant, bargain and sell, release and confirm unto the said Grantee, their heirs and assigns: TRACT #1 ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: • BEGINNING at a point in the center line of Township Road T-473, said point being a spike in the center line of West Pine Street Extended, said point also being North 82 degrees 30 minutes West, 25 feet from the Zine of land now or formerly of Russell S. Starner, thence along said land now or formerly of Russell S. Starner, South 2 degrees 23 minutes East, 200 feet to a stake at line of land now or formerly of Samuel C. Garonzik, et al; thence along the latter, North 82 degrees 30 minutes West, 100 feet to a stake; thence stili along the same, North 2 degrees 23 minutes West, 200 feet to spike in the center line of Township Road T-473 (West Pine Street Extended); thence along the latter, South 82 degrees 30 minutes East, 100 feet to a spike, the place of BEGINNING. .QOK 2'd PAcc4529 CONTAINING .452 acres according to a survey of Thomas A. Neff, R. S., dated October 24, 1969. BEING improved with a five -room ranch type dwelling and carport, known as 309 Sandbank Road, Mount Holly Springs, Pennsylvania. TRACT #2 ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Carl David Bert, Registered Surveyor, dated March 11, 1983, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 43, Page 27, and being Lot No. 3B as shown on said Plan, as follows: BEGINNING at an existing iron pin at the Southwest comer of land now or formerly of Herbert J. George and Cathrine B. George, which point is also on the dividing line between Lot No. 3A and 3B on said Plan; thence along said dividing line between Lot No 38 and land of Herbert J. George and Cathrine B. George, South 88 degrees 45 minutes 04 seconds East, a distance of 100 feet to an existing iron pin on the dividing line between Lot No. 3B and 3C as it appears on said Plan; thence along said dividing line, South 08 degrees 59 minutes 37 seconds East, a distance of 25 feet to an iron pin in line of Lot No. 3A; thence along the dividing line between Lot Nos. 38 and 3A, North 88 degrees 45 minutes 04 seconds West, a distance of 100 feet to an iron pin; thence continuing along Lot No. 3A, North 08 degrees 59 minutes 37 seconds West, a distance of 25 feet to an existing iron pin, the place of BEGINNING. BEING the same premises which the Estate of Cathrine B. George by their Deed dated August 24, 2000, and recorded August 28, 2000, in Cumberland in Cumberland County Recorder of Deeds in Book 227, Page 1121, granted and conveyed unto Raymond J. Gregory, Linda B. Gregory, joins in this deed to convey any interest she may have in the within described property as the spouse of Raymond J. Gregory, and Arthur Liebrum and Emily Liebrum, husband and wife, Grantors herein. TOGETHER with all and singular ways, waters, water -courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto belonging, or in anywise appertaining, and the reversions and remainders, rents; issues and profits thereof; and also, all the estate right, title, interest, use trust, property, possession, claim and demand whatsoever, in law, equity or otherwise howsoever, of, in, to or out of the • same. TO HAVE AND TO HOLD, the said hereditaments and premises hereby granted and released, or mentioned and intended so to be, with the appurtenances, unto the said GRANTEES and their heirs and assigns, to and for the only proper use and behoof of the said GRANTEES their heirs and assigns, forever. pl?rllf 274 rAGE4530 AND the said grantor/grantors do hereby SPECIALLY WARRANT the property hereby conveyed. IN WITNESS WHEREOF, the said Grantors have hereunto set their hands and seal the day and year first above written. SIGNED, SEALED AND DELIVERED IN THE PRESENCE OF (SEAL) ISH OF COUNTY OF CA5 C/A 61-70 ON THIS, the ?5"� day of May , 2006, before me, the undersigned office, personally appeared Raymond J. Gregory, Linda B. Gregory, Arthuf Liubru n and Emily Liebrum, known to me (or satisfactorily proven) to be the persons whose names are'subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. -.e,6cij 371 kit, Notary Public DEBORAH A. TRYTHALL )IO?A*Y PUBLIC, STATE OF NEN YOLK aJA<.FTED MI CHENANGO COUNTY RM. NO.OITR509126d :1ff CCIMMISIKS t tltiAFIN. *4.2y7 �iBl't 274AtcE I do hereby certify that the precise residence and complete post office address of the within me s Grantee is *1 S. 40. air Attomeyf Grantee Certify this 10 be recorded in Cumberlan County PA Cumberland County tecorder of feeds Instrument Filial teceipti 614180 Instil 2006-1019250 6/02/2006 15:01:19 Remarks: DACUS JUMPER DEED 12.50 DEED - MIT .50 DEED -111 STATE 1651.00 gum murex moo SOUTH MIDDLETON 925.00 DEED - i/H 11.50 J.C.S. / A.T.I. MOO CO DIRMillir FAD 2.00 REC. IMPRINT FUND 1.00 Medi 1856 11,339.00 Medi 1835 1.50 Total Receiyed $37359.50 Recorder of Deeds RiU 224 fAcE4532' EXHIBIT B MADE thi THIS INDENTURE day of August 2000. BETWEEN Parcel M0424334-054 JOSEPH L. YORLETS & PAMELA K YORLETS, Co -Executors of the Leat WM and Testament of Cathrine B. George,' late of South Mlddielon Township, Cumberland County, Pennsylvania; GRANTOR AND RAYMOND J. GREGORY, a married man, of 243 Grayson Drive, Norwich, New Yodc ARTHUR LIEBRUM & EMILY LIEBRUM, husband and wife, of Carlisle, Penneylvanla; GRANTEES WHEREAS Cathrine B. George dled January 27, 2000, testate seized of certain land situate In South Middleton Township, Cumberland County, Pennsylvania; and WHEREAS the WIII of the said Cathrine 8. George dated July 31, 1897, was duly probated In tho Woo of the Register of Wills In and for Cumborinnd County, Ponnsylvanla, on Fobivary 28, 2000, and Letter: Testamentary were granted to Joseph ,L Yodels ond,Parneta K. Yorteb, the above named Co -Executors to /121-00-114; end 'WHEREAS Section 3351 of the Probate, Estates end Fiduciaries Code (20 PS. 3351) confers upon Exotulor(e) the power to sell at public or prtvate sale, any real estate not specifically devised; end WHEREAS the hereinafter described premises were not specifically devised; and WHEREAS the said Co-Executore were not required to file any bond 10 secure faithful performance of their duties. NOW THIS INDENTURE WITNESSETH that Joseph L Yoriets and Pamela K. Yoriets, Co-Executore of the Estate of Celhdne B. George, deceased, for and in consideration of the sum of Ninety Thousand end 00/100 Dollars ($90,000.00) In lawful money of the United States, to them In hand paid by tho sold GRANTEES at and before, the sealing and dativery hereof; the receipt whereof Is hereby acknowledged they have granted, bargained, sold, aflened, released and confirmed, and by these presents does grant, Newlin, soil, alien, release and confirm unto the said GRANTEES, their heirs end assigns: too 227 faa1i21 It is the Intention of this Deed that Raymond J. Gregory, marled man, shall own an undivided M Interest therein end that Arthur Llebrum and Emily Uebnim, husband 'and'wtfe, shell own an undivided 14 Interest as tenants by the entireties. The relation between the owners. of the respective undlvIdedtnterests shall be tenants In common, TRACT # t, ALL THAT CERTAIN treat of land with the Improvements thereon erected situate In South Middleton Township, Cumberland County, Pennsytverla, bounded end described as follows; :BEGINNING at a point In the rentor line of ;Township; Road 7473, aaid'polnt being a cplko In the centerline of West Pine Street' Extended sold point else .beln0 North 82 de0reas:30 minutes West. 25 feat iromthe fno,of land now or formerly of Ruosell S. Sterner, the 'nee along said land now er formerly 01 Russoli S, Starn r; South. •2 degrees 23 minutes EABl. 200 feet tea stake atilno of wand now or formerly of Samuel C.'Genanzik, et al; thence along the tatter; North 82 degrees 30 Mantes West; 100'fast; • o a stake; thenee',ah(I along the sams,,North 2 degreas 23;m1nutea.Wost, 200 feet to o, Spike In•the center line of Township Read T-473 (Weet Pine Street Extended); thence along the tetter, South 82 degrees 30 minutes East, 100 feet to a spike, the place of BEGINNING. ;CONTAINING .452 soros awarding to.et surrey of Thomas A. Neff, RS., dated Ociobsr 24,'1969, 'BEING Irnproved.1a five room ranch type dwelling 'end carport, known as 309 Sandbank:Road, Mourd Holly: Springs. Pennsylvania. ' BEING the Rams property which Mark C. Snyder and Linda tC,Snyder, Na wile,. by their Med dated January 18,1979; and re'oonied in Cumbertand'County Recorder of Deeds Book `G", Vol: 20, Page 218, Bremer and coniveyod urge Herbert J: Gene and Cathrina B;_ George, hte wife. The ;Sold Herbert:J. George•dle&December 18, 1996, thereby vesting lull dila in Cathrina B. -George. All'thal'cartaln tract of lend situate In;Soulh Middleton Township,-Curnbedand Couhty, :Pennsytvsnle, bounded and descrtbed:in: accordance *flys storey by Cad David Bert. Registered Surveyor, dated March 11 1083, and femrd©d. In thoOfflce of. tho Recorder of Deeds In settler Cumberland County'fn Pion Soak 43; Pegs :b.oing•Lot No, 3R os Shown on;oski �tan,as folkiure: BEGINNING et an existing Iron pin at the :Southwest corner of land now or formerly of Harbert J. George and_ Cathrtne B. George, which point Is also on the dlvidtng"!lyse between Lot No. 3A and 30 dn aatd Plan;chance"along Bald dividing Ilno between Lot:No 30 and lend :of Herbert J.• Georgo •and :Cathrine B George, South' 88 degrees 45 minutes -04 seoonde East, a dletance of 106 feet'lo•en, existing iron pin on tha,•dMding line between LotNo,'38 ,and 3C a§'11 appears on said Plan; thence along sell dividing`Ilrie,•Scwtti08 det)reoe 50 mtnutec'3? eeoonds East,.a'distance of :25 (sot 2 MN 227 (ce1:i22 to en Iron pin In line of Lot No. 3A; thence along the dividing Ilne between Lot Nos. 3B and 3A, North 88 degrees 45 minutes 04 seconds West, a distance of 100 feet to an Iron pin; thence oontlnutng along Lot No. 3A, North 08 degrees 69 minutes 37 seconds West, a distance of 26 feet to an existing Iron pin, the place of BEGINNING. BEING the eamo property whleh Jenny Lee Shue, by her Deed dated May 18, 1983, end recorded In Cumberland County Recorder of Deeds Book'E', Vol. 30, Page 729, granted and conveyed unto Herbert George and Calhitne George, hie wtfe. The said Herbert George died December 18, 1998, thereby vestlng full Me In Cathrine George. TOGETHER with all and singular ways, waters, water -courses, rights, privileges, heredilarnsnts and appurtenances whatsoever thereunto belonging, or In anywise appertalnina, end the reversions and remainders, rents, Issues and profits thereof; end also, :ali the agitate ri ht,110e, Interest, use truss, property, posoea&on, !Alm and demand whetooevor, In.$ow, equity or othonvino howsoever; of, In, to or out ofIbe same. TO HAVE ANDTOHOLD, the said heredilementa end premises hereby granted and released, or mentioned and Intended so to be; with the appurtenances, unto the said GRANTEE and his heirs and assigns; to and for the only proper use end behoof of the eald GRANTEE his holm end assigns, forever. AND the said Co -Executors of the Estate of Ca' Wine R. doorgo, deceased, covenant; promise; and agroe to and with the seld GRANTEE his helm 'and assigns, by those presents, Mal ha/she, the said Co -Executors have not done, committed, knowingly or willingly nulfared to be done or commgted, any .act, .matter or thing whatsoever whereby the promises hereby granted, or eny.part thereof, is, are, shell or may be impeached. charged or encumbered.:In Adie. charge, estate, or otherwise howaoevor. WITNESS the due execution hereof the day, month and year first above written. tried, Sealed: and Delivered Mille r°Proson��ce//of: r.:ee:lit 4Yv 1.r/ 3 Estate of CathrIne B. George 03 H L YOS, Executor owR 227 atst i23 COMMONWEALTH OF PENNSYLVANIA ) : SO COUNTY OF CUMBE ND On this, the day of 6uauet , 2000, before ma, the underskmed „tender, personally:appeared 'Joseph L Yorlets and, Pamela K Veneta, known tomo (or eatisfactorily.proveri)ta be the person whose. name Is sUbscrtbedle the wtthln instrument and eCknowladaed that they executed some ae Co4Executotsfor the or•Caihrine a George tor the purposes therein contained. , wiNiVITNES,S WHEREOF, 1 hereunto set my hand and o ••• • ' • • i do hereby certifythat the pros the within named Grantee Is: Date COMMONWEALTH OF PENNSYLVANIA ) as COUNTY OF•CUMBERLAND Y to - RECORDED on this 41 day of , 000, In the Recordear Office of the saki County, In Deed Book r) Page ;:• hi ,••••• 0-7 L2 Given under my hand and seal of the said omce, the date above written. : • ••• rt CJ 2, McKNIGHT & HUGHES A fforneys 4 000K 227 f':,ci,1414 th 227 m1i2.3 EXHIBIT C Prepared By: WELLS FARGO BANK, N.A. 111 CONTINENTAL DR, SUITE 114, NEWARK, DE 197130000 9-024 Core Settlement Services 3000 Market Street 4600 Camp Hill, PA 17011 Parcel Number: y o 3�' a3'�� ►- vs U Premises: 309 SANDBANK ROAD MT HOLLY SPRINGS !Space Above This Line For Recording Data! MORTGAGE DEFINITIONS Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 16. (A) "SecurityInstrument" means this document, which is dated MAY 14 , 2009 together with all Riders to this document. (B)"Borrower"is RONALD E JUMPER AND LINDA C JUMPER, HUSBAND AND WIFE Borrower is the mortgagor under this Security Instrument. ?Ei'JtV_SYLVANIla�SkijgId Family -Fannie Ma & addle Mac UNIFORM 1NSriiU 'el Services 9 (PALM) Rev 1!1009 Form 3039 1/01 P6(PA) (0906).00 Peen 1 of IT (C) "Len der" is WELLS FARGO BANK, N.A. Lender is a NATIONAL ASSOCIATION organized and existing under the laws of TSE UNITED STATES Lender's address is P.O. BOX 11701, NEWARK, NJ 071014701 Lender is the mortgagee under this Security Instrument. (D) "Note"means the promissory note signed by Borrower and dated NAY 14, 2009 The Note states that Borrower owes Lender ONE HUNDRED FIFTY THREE THOUSAND AND 00/100 Dollars (U.S. $ ******153 , 000.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than JUNE 01, 2039 . (E) "Property"means the property that is described below under the heading "Transfer of Rights in the Property." (F) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due under the Note, and all sums due under this Security Instrument, plus interest. (G) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicable]: El Adjustable Rate Rider n Condominium Rider EJ Second Home Rider Balloon Rider 0 Planned Unit Development Rider 1-4 Family Rider U VA Rider Biweekly Payment Rider Other(s) [specify] !'I (H) "Applicable Law" means all controlling applicable federal, state and local Statutes, regulations, ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final, non -appealable judicial opinions. (I) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (J) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or magnetic 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. (K) "Escrow Items" means those items that are described in Section 3. (L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the PEN ®YLVANIASIngle Family -Fannie MeefFreddle Mac UNIFORM INSTRUMENT PWollero Kumar Flnandal SeMces In(Uals: Form 3039 1/01 PB(PA) (0804.00 Pe9e 2 of 17 Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (M) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the Loan. (N) "Periodic Payment" means the regularly scbeduled amount due for (i) principal and interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument. (0) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA" refers to all requirements and restrictions that arc imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under RESPA. (P) "Successor in Interest of Borrower" means 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 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 Lender the following described property located in the COUNTY [Type of Recording Jurisdiction] of CUMBERLAND [Name of Recording Jurisdiction]: SEE ATTACHED LEGAL DESCRIPTION TAX STATEMENTS SHOULD BE SENT TO: WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 which currently has the address of 309 SANDBANK ROAD 309 SANDBANK ROAD MT HOLLY SPRINGS ('Property Address"): [City], Pennsylvania 17065 [Street] (Zip Code) PPEEP NSYLVANIASInple Femlly-Fannie Mea, ddle Mac UNIFORM INSTRUMENT Woheie Kluwer Flnan:MI Services Foran 3039 1/01 MPUipA (090e}O0 In is: .9e 3 of.tiT: TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. AU of the foregoing is referred to in this Security Instrument as the "Property." BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. 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 Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. • 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments PENNSYLVANIA -Single Famry.Fannla MaelFmddle Mac UNIFORM INSTRUMENT VMP Wolter* XIvwer Financial Service* Initieta • atm 3099 trot VMP6(PA)'(0804):Q0. `Page.4 0,11T shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3. Funds for Escrow hems. Borrower shall pay to Lender on the day Periodic Payments arc 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 Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all 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 Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is uscd in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required under 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 current data and PENNSYLVANIA -Single Family -Fannie Mae&Freddle Mac UNIFORM INSTRUMENT VMP Wolters Kluwer Financial Services Forth 3039 1/01 VMPe(PA) (06 00.00 of 1 Inhleby Pape S at 17 reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal 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 Funds as required by RESPA. if there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to 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 Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower; (a) agrees 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 performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4. Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service used by Lender in connection with this Loan. 5. Property Insurance. 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 PENNSYLVANIASInple Family -Fannie MeeIFreddle Mac UNIFORM INSTRUMENT VMP 119 Wafters Kluwer Financial Services InId,Is: Form 30391101 P6(PA) (DaoM100; Pape Co! 17 other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and certification services and subsequent charges each time remappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might.or might not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, harard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender 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 bold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If PENNSYLVANIA -Single Femllyfennle Mae/Freddie Mac UNIFORM INSTRUMENT VMP Wolters Kluwer Financial Swim* inS VMP6(PA) ((008804 00 Pape 7 0117 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 matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30 -day period will begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument, whether or not then due. 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shalt 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. PENNSYLVANIA -Single FemllyFennle Mae/Fniddla Mac UNIFORM INSTRUMENT VMP Wetter' Kluwer Flnendel Sambas Fol 3o59. iro! VMPO(PA7 Pane S.,cIJO_ InNtnl�,_,/_ pegeedl7 9. Protection of Lender's Interest in the Property and Rights ynder this Security Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this `SecurityInstrument, (b) there 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:'condenination 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 far 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, andfsccuring and/or repatrtng the ProPerty. Lender's actions can include, but are not limlted;to: (a) spaying any sums. secure d'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 locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Mortgage Insurance. If Lender required Mortgage insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coveragesubstantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. if substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were ,due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and PENNSYLVANIA -Shale FeniUy-Fannie Mee/Fieddle Mac UNIFORM INSTRUMENT - Fmm 3039:1/01 VMP' �j3 VMPG(PA):(050400: Wolters Kluwer Financial Senecec lekle F %!• go 9.0( 17 0 In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in value. Any balance 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, or loss in value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. 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 after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party that 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 tights under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's interest 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 Lender. All Miscellaneous Proceeds that arc not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any 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, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the 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 be joint and several. However, any Borrower who co-signs this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this PENNSYLVANIA -Single Family -Fannie MaefFreddle Mac UNIFORM INSTRUMENT Wafters Kluwer Financial Services J Kann 3039 len VMP6(PA) (0804).00 Pape 11 of 17 Security Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without the co-signer's consent, Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees 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 permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by 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 report a change of address through 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. PENNSYLVANIASInp1e Famlly.Fannle Mao/Freddie Mac UNIFORM INSTRUMENT VMP® Wolters Kluwer Financial Semkea Fenn 3039.1/01 'VNTp6(1?At ioa(M).00 Initeb: I l L Pogo 12 of 17 16. Governing Law; Severability; 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) words 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. 18. 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 purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of: (a) five days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration bad occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order, (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon Pry®YLVANIASinglo Runny -Fannie MedFreddie Mac UNIFORM INSTRUMENT Wollas Kluwet Financial Sanvoea meals Form 3039 1/01 AJ (rico J.00 Pape 13 at 17 an institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrowcr, this Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower. A sale might result in a change in the entity (known as the "Loan Servicer") that collects Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor 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 with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to 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 defined in Environmental Law; and (d) an "Environmental Condition" 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 (c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences shall not Apply to the presence, use, or storage on the Property of small quantities of ®YW/WIASInple Famlyfennle Ma&Freddle Mac UNIFORM INSTRUMENT VMP Wolters )Otmer Financial Services Initial Fane 30.39 IAt. VMPIIIPA) t09Qi)01 ,Pape 14 el 17 Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property (including, but not limited to, hazardous substances in consumer products). Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary • remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable Law. 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 Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale 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 after 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. PENNSVLVANIASIngle FnmllyFannla Mae/Freddle Mac UNIFORM INSTRUMENT VMP Wohere Kluwer Financial Services Inldal Form 3039 1/01 P6(PA) t� BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. Witnesses: (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower PN�glmll PENNSYLVANIA -Sine Fayfennie MedFreddie Mac UNIFORM INSTRUMENT VMWolters Kluwer Financial Services Initials; Form- son 1181 PAPA) (08O WOO COMMONWEALTH OF PENNSYLVANIA, et,44ALA County ss: On this, the / 'f day of / ' l e� ,before me, the undersigned officer, personally appeared RONALD E JUMPER AND LINDA C JUMPER satisfactorily proven) to be acknowledged that be/sh known to me (or perSon0. whose named are subscribed to the within instrument and Xecutedibe same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: COMMONWEALTH: OF PENNSYLVANIA Notarial Seal Karen L. Burch, Notary Public Metanicsburg gam; Cumberland County. MyCommis.ion Expires Nov. 24, 2009 Member, Pennsylvania Association of Notaries Certificate of Residence I, the correct address of the 071019701 Witness my hand this thin -named Mortgagee is .0. L1 day of , do hereby certify that OX 11701, NEWARK, NJ Agent of Mortgagee PENNSYLVANIA -Single Famlly.Fannle Mae/Freddie Mac UNIFORM INSTRUMENT VMP® Wolters Kluwer Financial Services in Foam 3039 101 P6jPA) (0804).00 Page 17 of 17 Commitment Number: 2009030054* f• • Stewart Title Guaranty Company SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: TRACT #1 ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-473, said point being a spike in the center line of West Pine Street Extended, said point also being North 82 degrees 30 minutes West, 25 feet from the line of land now or formerly of Russell S. Starner, thence along said (and now or formerly of Russell S. Stamer, South 2 degrees 23 minutes East, 200 feet to a stake at line of land now or formerly of Samuel C. Garonzik, et al; thence along the latter. North 82 degrees 30 minutes West, 100 feet to a stake; thence still along the same, North 2 degrees 23 minutes West. 200 feet to a spike in the center line of Township Road T-473 (West Pine Street Extended); thence along the latter, South 82 degrees 30 minutes East, 100 feet to a spike, the place of BEGINNING. CONTAINING .452 acres according to a survey of Thomas A. Neff, R. S., dated October 24, 1969. BEING improved with a five -room ranch type dwelling and carport, known as 309 Sandbank Road, Mount HoIIy Springs, Pennsylvania. TRACT #2 ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Cad David Bert, Registered Surveyor, dated March 11, 1983, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 43, Page 27, and being Lot No. 35 as shown on said Plan, as follows: BEGINNING at an existing iron pin at the Southwest corner of land now or formerly of Herbert J. George and Cathrine B. George, which point is also on the dividing line between Lot No, 3A and 3B on said Plan; thence along said dividing line between Lot No 38 and land of Herbert J. George and Cathrine B. George, South 88 degrees 45 minutes 04 seconds East, a distance of 100 feet to an existing iron pin on the dividing line between • Lot No. 38 and 3C as it appears on said Plan; thence along said dividing line, South 08 degrees 59 minutes 37 seconds East, a distance of 25 feet to an iron pin in line of Lot No. 3A; thence along the dividing line between Lot Nos. 3B and 3A, North 66 degrees 45 minutes 04 seconds West, a distance of 100 feet to an iron pin;•thence continuing along Lot No. 3A, North 08 degrees 59 minutes 37 seconds West, a distance of 25 feet to an existing iron pin, the place of BEGINNING. Parcel #40-32-2334-054 ALTA Commitment Schedule C (2009030054.PF0/2009030054/40) ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200919727 Recorded On 6/11/2009 At 12:59:30 PM * Instrument Type - MORTGAGE Invoice Number 45778 User ID - KW * Mortgagor - JUMPER, RONALD E * Mortgagee - WELLS FARGO BK N A *Customer - CORE SETTLEMENT SERVICES * FEES STATE WRIT TAX STATE JCS/ACCESS TO JUSTICE RECORDING FEES — RECORDER OF DEEDS PARCEL CERTIFICATION FEES AFFORDABLE HOUSING COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $10.00 $39.50 $10.00 $11.50 $2.00 $3.00 $76.50 *Total Pages - 19 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER of D EDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 11 1111 IIIIIIIIIUI EXHIBIT B McCABE, WEISBERG AND CONWAY, P.C. BY: Joseph I. Foley, Esquire Attorney ID # 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. V. Arthur Liebrum Attorney for Plaintiff Cumberland County Court of Common Pleas No. 14 -4267 -Civil AFFIDAVIT UNDER RULE 1066(a) Pa. R.C.P. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: I, JOSEPH I. FOLEY, ESQUIRE, being duly sworn according to law, hereby depose and say that: 1. I am counsel for Plaintiff in this matter. 2. A complaint containing a notice to defend has been served on the Defendant. 3 The Defendant have not filed an answer. 4. Attached hereto as Exhibit "1" is a true and correct copy of the Affidavit of Service Service filed in this matter indicating that service of original process was completed on September 29, 2014. 5. Since service was completed, Plaintiff's counsel has not been served with an answer or other response to the Complaint nor has o SWORN AND SUBSCRIBED BEFORE ME THIS 14111DAY OF NOVe hi) be , 2014 140116 6/L NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KELUE KELLER, Notary Public City of Philadelphia, Phila. County My Commission Expires February 7, 2018 B . oseph I. Fo ey, Esquire Attorney for Plaintiff EXHIBIT 1 �th: Pfl O T i f 0177_' ?'.Girl OCT -1 f CUP;.- Iif) McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff v. Arthur Liebrum Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14 -4267 -Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : :SS. COUNTY OF PHILADELPHIA The undersigned attorney being duly sworn according to law, deposes and says that the following is true and correct to the best of his / her knowledge and belief: That he / she is counsel for the above-named Plaintiff; 2. That on September 29, 2014, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Quiet Title upon the Defendant, Arthur Liebrum, by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his last - known addresses of 3 Teejay Drive, South Middleton Township, Mount Holly Springs, Pennsylvania 17065, 801 Sandbank Road, Lot 17, Dickinson Township, Mount Holly Springs, Pennsylvania 17065, and 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. A true and correct copies of the letters and certified receipts, are attached hereto, made a part hereof, and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF 'TARIAL TRAVASCIO, Nobjy City of Philadelphia, Phil Comptssion ExpireseFbnallpli_01 I., ....TO BY: RG [ ] T ence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff CONWAY/P.C. arc S. Weisberg, Esq. -"Margaret Gairo, Esq. ] Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. ] Ann E. Swartz, Esq. ...]-Joseph I. Foley, Esq. ] Lena Kravets, Esquire 7 L. `i.3111 SEP I 9 rs‘? f,;), r CUMBERLAND CO ON PENNS Y NIA Wells Fargo Bank, N.A. Plaintiff V. Arthur Liebrum Defendant litel AND NOW, this ri day o Cumberland County Court of Common Pleas Number 14 -4267 -Civil ORDER 1c6H -14) 2014, the Plaintiff is granted leave to serve process in this quiet title action upon the Defendant, Arthur Liebrum, by certified mail, return receipt requested, to his last -known addresses of 3 Teejay Drive, South Middleton Township, Mount Holly Springs, Pennsylvania 17065 and 801 Sandbank Road, Lot 17, Dickinson Township, Mount Holly Springs, Pennsylvania 17065 and 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. J. LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 210 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914) 636-8901 SUITE 201 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858.7080 FAX (856) 858.7020 SUITE 130 DELAWARE CORPORATE CENTER! ONE RIGHTER PARKWAY WILMINGTON, DB 19803 (302) 4093520 FAX 855-425.1980 Arthur Liebrum 3 Teejay Drive South Middleton Township Mount Holly Springs, Pennsylvania 17065 SUITE 1400 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 September 29, 2014 Re: Wells Fargo Bank, N.A. v. Arthur Liebrum Cumberland County; CCP; Number 14 -4267 -Civil Dear Arthur Liebrum: SUITE 800 312 MARSHALL AVENUE LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing this Dislnc of Columbia SUITE 203 722 E. MARKET STREET LEESBURG, VA 20176 (571) 449 9350 FAX: (855) 845-2585 SURE 2506 1 HUNTINGTON QUADRANGLE MELVILLE, NY 11747 (631)812.4084 FAX: (855) 845-2584 Enclosed please find a true and correct copy of Complaint in Quiet Title, along with a copy of the signed Order dated September 19, 2014, the original of which has been filed against you in regard to the above -captioned matter. Very truly yours, Rachel Weres Legal Assistant for: McCabe, Weisberg and Conway, P.C. SENT VIA CERTIFIED MAIL NUMBER 7013 1090 0001 5957 1508 RETURN RECEIPT REQUESTED Exhibit A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose, LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 210 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914) 636-8901 SUITE 201 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858.7080 FAX (856) 858-7020 SUITE 130 DELAWARE CORPORATE CENTER 1 ONE RIGHTER PARKWAY WILMINGTON, DE 19803 (302) 409-3520 FAX 855-425-1980 Arthur Liebrum 801 Sandbank Road, Lot 17 Dickinson Township Mount Holly Springs, Pennsylvania 17065 SUITE 1400 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 September 29, 2014 Re: Wells Fargo Bank, N.A. v. Arthur Liebrum Cumberland County; CCP; Number 14 -4267 -Civil Dear Arthur Liebrum: SUITE 800 312 MARSHALL AVENUE LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 203 722 E. MARKET STREET LEESBURG, VA 20176 (571) 449 9350 FAX: (855) 845-2585 SUITE 2S06 1 HUNTINGTON QUADRANGLE MELVILLE, NY 11747 (631) 812-4084 FAX: (855) 845.2584 Enclosed please find a true and correct copy of Complaint in Quiet Title, along with a copy of the signed Order dated September 19, 2014, the original of which has been filed against you in regard to the above -captioned matter. Very truly yours, Rachel Weres Legal Assistant for: McCabe, Weisberg and Conway, P.C. SENT VIA CERTIFIED MAIL NUMBER 7013 1090 0001 5957 1515 RETURN RECEIPT REQUESTED Exhibit A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 210 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914) 636.8901 SUITE 201 216 HADDON AVENUE WESTMONT, NJ 08108 (856)858-7080 FAX (856) 858.7020 SURE 130 DELAWARE CORPORATE CENTER I ONE RIGHTER PARKWAY WILMINGTON, DE 19803 (302) 409.3520 FAX 855.425-1980 Arthur Liebrum 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 SUITE 1400 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 September 29, 2014 Re: Wells Fargo Bank, N.A. v. Arthur Liebrum Cumberland County; CCP; Number 14 -4267 -Civil Dear Arthur Liebrum: SUITE 800 312 MARSHALL AVENUE LAUREL, MD 20707 (301)490.3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 203 722 E. MARKET STREET LEESBURG, VA 20176 (571) 449 9350 FAX: (855) 845-2585 SUITE 2S06 I HUNTINGTON QUADRANGLE MELVILLE, NY 11747 (631) 812.4084 FAX: (855) 845-2584 Enclosed please find a true and correct copy of Complaint in Quiet Title, along with a copy of the signed Order dated September 19, 2014, the original of which has been filed against you in regard to the above -captioned matter. Very truly yours, Rachel Weres Legal Assistant for: McCabe, Weisberg and Conway, P.C. SENT VIA CERTIFIED MAIL NUMBER 7013 1090 0001 5957 1522 RETURN RECEIPT REQUESTED Exhibit A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. McCABE, WEISBERG AND CONWAY, P.C. BY: Joseph I. Foley, Esquire Attorney ID # 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. v. Arthur Liebrum Attorney for Plaintiff Cumberland County Court of Common Pleas No. 14 -4267 -Civil MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR RELIEF IN QUIET TITLE Rule 1066 Form of Judgment or Order (Under the Heading of Action to Quiet Title), states, as follows: (a) The Court shall grant appropriate relief upon affidavit that a complaint containing a notice to defend has been served and that the defendant has not filed an answer, or after a hearing or trial on the pleadings or merits. (b) Upon granting relief to the plaintiff, the court (1) shall order that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the plaintiff set forth in the complaint, unless the defendant takes such action as the order directs within thirty days thereafter. If such action is not taken within the thirty -day period, the prothonotary on praecipe of the plaintiff shall enter final judgment. (2) shall enter a final judgment that a document, obligation or deed affecting a right, lien , title or interest in land is cancelled or is valid, invalid or discharged or that a copy of a lost plan, document, obligation or deed is an authentic copy; (3) shall enter a final judgment ordering the defendant, the prothonotary, or the recorder of deeds to file, record, cancel, surrender or satisfy of record, as the case may be, any plan, document, obligation or deed determined to be valid, invalid, satisfied or discharged, and to execute and deliver any documents, obligation or deed necessary to make the decree effective; or (4) shall enter any other order necessary for the granting of proper relief. In this instance, the accompanying Affidavit of Counsel shows that the complaint with a notice to defend has been served on the defendant and that the defendant has not filed any answer or other response to plaintiffs Complaint. As a result, it is submitted that plaintiff is entitled to an Order for judgment in quiet title by virtue of Rule 1066 Pa. R. C. P. An appropriate form of Order is attached hereto. Respectfully submitted, McCabe 'sberg & Conway, P.C. Jose I. Foley, Es AXerney for Plain McCABE, WEISBERG AND CONWAY, P.C. BY: Joseph I. Foley, Esquire Attorney ID # 314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. v. Arthur Liebrum Attorney for Plaintiff Cumberland County Court of Common Pleas No. 14 -4267 -Civil CERTIFICATION OF SERVICE I, Joseph I. Foley, Esquire, hereby certify that a true and correct copy of the within Motion for Relief in Quiet Title pertaining to the above -captioned matter was served on the 14th day of November, 2014, by first-class mail, postage prepaid, upon the following: Arthur Liebrum 3 Teejay Drive South Middleton Township Mount Holly Springs, PA 17065 Arthur Liebrum 309 Sandbank Road Mount Holly Springs, PA 17065 Date: i/) iU(iik1 Arthur Liebrum 801 Sandbank Road, Lot 17 Dickinson Twp. Mount Holly Springs, PA 17065 seph I. Foley, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. v. Arthur Liebrum Cumberland County Court of Common Pleas No. 14 -4267 -Civil ORDER C;l -.a N) AND NOW, this 20 day of 14 freWire/014, upon due consideration of the Motion of Plaintiff, Wells Fargo Bank, N.A., for relief in quiet title, it is hereby ORDERED, ADJUDGED, and DECREED that: 1. Final Judgment is hereby entered in favor of Plaintiff, Wells Fargo Bank, N.A., and against Defendants, Arthur Liebrum; and 2. The deed from Raymond J. Gregory and Linda B. Gregory, his wife, and Arthur Liebrum and Emily Liebrum, his wife, to Ronald E. Jumper and Linda C. Jumper, dated May 21, 2006 and recorded on June 2, 2006 in the Office of the Recorder of Deeds for Cumberland County in Book 274, Page 4529 is hereby deemed to be a valid transfer, as of the date of that deed, of the entire property described in that deed, including the 1/4 interest in the property at one time held by Arthur Liebrum and Emily Liebrum as tenants by the entireties. 3. Arthur Liebrum is hereby forever barred from asserting any right, lien, title or interest in the Property inconsistent with the aforementioned Deed or this Order; and 4. The Recorder of Deeds for Cumberland County is directed to accept for recording a certified copy of this Order and index the same against that Property located at 309 Sandbank Road, Mt. Holly Springs, PA 17065, such property being more particularly described in the aforesaid deed and having Tax Parcel ID No. 40-32-2334-054. BY THE Ge RT: J. Distribution: Joseph I. Foley, Esq., 123 South Broad Street, Suite 1400, Philadelphia, PA 19109 ✓Arthur Liebrum, 3 Teejay Drive, South Middleton Township, Mount Holly Springs, PA 17065 ✓Arthur Liebrum, 801 Sandbank Road, Lot 17, Dickinson Twp., Mount Holly Springs, PA 17065 �hur Liebrum, 309 Sandbank Road, Mount Holly Springs, PA 17065 irLa.; LQL /f/aa/If