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'Supreme Cour) ennsylvania COUrIt�Of COmmoh Pleas For Proth on otary Use Only: 0yJ1 Cbver,tSh'eet Docket No: S j CUMBERLAND r County - 38 al"11—Fem till, The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: El Complaint ® Writ of Summons ® Petition ® Transfer from Another Jurisdiction ® Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: C GREEN TREE SERVICING LLC PATRICK T. LEONARD and MARLENE LEONARD T` Dollar Amount Requested: ®within arbitration limits 4I: Are money damages requested? El Yes ® No (check one) poutside arbitration limits Off: Is this a Class Action Suit? ®Yes D No Is this an MDJAppeal? ® Yes El No A, Name of Plaintiff/Appellant's Attorney: GREGORY JAVARDIAN Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) z 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. i TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS Intentional ® Buyer Plaintiff Administrative Agencies i ® Malicious Prosecution 13 Debt Collection:Credit Card ® Board of Assessment j © Motor Vehicle ® Debt Collection: Other [3 Board of Elections ® Nuisance 13 Dept.of Transportation S ® Premises Liability ® Statutory Appeal:Other ` ® Product Liability(does not include E mass tort) 13 Employment Dispute: ® Slander/Libel/Defamation Discrimination C ® Other: ® Employment Dispute:Other 13 Zoning Board T ® Other: 1 ® Other: li O MASS TORT E3 Asbestos N ® Tobacco i ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ' © Other: ® Ejectment ® Common Law/Statutory Arbitration Bi 13 Eminent Domain/Condemnation ® Declaratory Judgment ® Ground Rent 13 Mandamus ® Landlord/Tenant Dispute ®Non-Domestic Relations El Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure:Commercial 13 Quo Warranto ® Dental [3 Partition ®Replevin ® Legal ® Quiet Title ®Other: 0 Medical 13 Other: ® Other Professional: i Updated 1/1/2011 LAW OFFICES OF GREGORY JAVARDIAN s1" GREGORY JAVARDIAN, ESQUIRE Id.No. 55669 MARY F. KENNEDY,ESQUIRE Id.No. 77149 �;°i � �� MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS,ESQUIRE Id No. 307518 r, , 1310 INDUSTRIAL BOULEVARD � L Y JA it l i 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215)942-9690 ATTORNEY FOR PLAINTIFF GREEN TREE SERVICING LLC COURT OF COMMON PLEAS 345 ST. PETER STREET 1100 LANDMARK TOWERS CIVIL DIVISION ST. PAUL, MN 55102 PLAINTIFF CUMBERLAND COUNTY VS. NO. N - Jr5—=�B niv i 1—tem PATRICK T. LEONARD MARLENE LEONARD COMPLAINT IN 120 LINN DRIVE MORTGAGE FORECLOSURE CARLISLE, PA 17013 DEFENDANTS NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages,you must take action within twenty(20)days after this Complaint and notice are served,by entering a written appearance personally or by attorney and filing in writing with the court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle,PA 17013 717-249-3166 800-990-9108 *115,175 P a A-rH �$fOR 311 a49 {00118201} a IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.0 § 1692 et seq. (1977), DEFENDANT(S)MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S)DO SO IN WRITING WITHIN THIRTY(30)DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S)WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE,IF REQUESTED WITHIN THIRTY(30)DAYS OF RECEIPT OF THIS PLEADING,COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR,IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30)DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY(20)DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE,NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY(30)DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER,IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30)DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS(THROUGH LITIGATION OR OTHERWISE)TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. {00118201} x 4. The Mortgage secures the indebtedness of a Note executed by the Defendants on May 4, 2007 in the original principal amount of$209,000.00 payable to Plaintiff in monthly installments with an interest rate of 6.625%. A copy of the Note is attached and made a part hereof as Exhibit `C'. 5. The land subject to the mortgage is 120 Linn Drive, Carlisle, PA 17013. A copy of the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated herein. 6. The Defendants are the Record Owners of the mortgaged property located at 120 Linn Drive, Carlisle,PA 17013. 7. The Mortgage is now in default due to the failure of Defendants to make payments as they become due and owing. As a result of the default,the following amounts are due: Principal Balance $193,866.25 Interest 1/1/13 to 7/28/2014 $20,215.71 Accumulated Late Charges $133.82 Negative True Escrow $6,051.37 TOTAL $220,267.15 plus interest from 7/28/2014 at$35.19 per day, costs of suit and attorney's fees. 8. A copy of the Negative True Escrow is attached and made a part hereof as Exhibit `D'. 9. In the event of a third party purchase at a Sheriff sale, attorney fees and costs will be collected in conformity with the Mortgage documents and Pennsylvania Law. If the Mortgage is reinstated prior to the Sale,reasonable attorney's fees will be charged. 10. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor with a Notice of Intention to Foreclose("Act 6 Notice")41 P.S. Section 403 and Notice of Homeowners' Emergency Mortgage Assistance("Act 91 Notice")35 P.S. Section 1680.403c. {00118201} 11. The Notice of Intention to Foreclose and Notice of Homeowners' Emergency Mortgage Assistance were required and Plaintiff sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to the Defendants by regular and certified mail on June 25,2014. A copy of the Notice is attached and made a part hereof as Exhibit `E'. WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the mortgaged property in Plaintiff's favor and against the Defendants, in the sum of$220,267.15 together with the interest from 7/28/2014 at$35.19 per day, costs of suit and attorney's fees. LAW OFFICES OF GREGORY JAVARDIAN BY: Greg Javardia Es uireUdNo. 55669 ❑Ma . Kenned , E uire Id. No. 77149 ❑Meghan K. Boyl , squire Id. No. 201661 ]Sean P. Mays, E ire Id. No. 307518 Attorneys for Plaintiff {001 18201} EXHIBIT 4 {00046153) 4 11111 lll�lllll !• ":....,� �fj lllilllll �i _ !1111111111111 . . � .. . .. r lll111�111111111 � 4�., • T� 1111111111111 �� , ..^ 8 PM 12 5� Return To: HEARTLAND HOME FINANCE,INC. 1401 BRANDING LANE SUITE 300 DOWNERS GROVE,ILLINOIS 60515 LOAN NO.: ESCROW NO.: 7TTL1:NO.: premises: Parcel Number: 120 LM DR 04-23-0600-184 CARLISLE,PENNSYLVANIA 17013 MMNO-- [SPACE ABOVE TMS LINE FOR RECORDING DATA] 11'1C)ItTGAGE DEFT TIONS Words used in multiple sections of this document are del below and other words are ec 13, I8,20 and 21. Certain rules regarding the usage of words used in this document are Section 16. defined in Sections 3, also provided in (A) L3e` cty Instrument"means this document, which is dated MAY with all Riders to this document. 4 Z— 007 ,together PATRICK T LEONARD AND M ARLT;NE LEONARD HUSBAND AND WOE Borrower is the mortgagor under this Security Instrument. (C) "MERS" is Mortgage Electronic Registration Systems, Inc, M . solely as a nominee for Lender and Lender's successors and assigns.SecurityIn ERS is a separate Corporation that is acting Instrument, MERS is organized and existing under the laws fo DRelsawarthe mo gee under this telephone number of P.p. Box's Flint, MI 48501-2026, tel. (888)679-NIERS.' and has an address and PENNSYLVANIA-Single Family-Fannie MaelFreddie DocPREPS&?;,jcE.$INc. FORM_MITGPA1.1139 Mac IJNHFORK INSTR Page 1 of 17 , I ' NT'MERS Form 3039 1/01 ORIGINAL Bf� 1 9 91 P6 2 5 b 9 � Y c (D) "Lender" is HEARTLAND HOME FINANCE INC. AN ILLINOIS CORPORATION Lender is a AN ILLINOIS CORPORATION organized and existing under the Iaws of ILLINOIS Lender's address is 1401 BRANDING LANE SUITE 300;DOWNERS GROVE,ILLINOIS 60SIS (E) "Note"means the promissory note signed by Borrower and dated MAY 4 2007 . The Note states that Borrower owes Lender TWO HUNDRED NINE THOUSAND AND 001100 Dollars (U.S. $ 209 000.00 )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 , 2037 (F) "Property"means the property that is described below under the heading "Transfer of Rights in the Property." (G) "Loan"means the debt evidenced by the Note,plus interest,any prepayment charges and late charges due under the Note,and all sums due under this Security Instrument,plus interest. (H) "Riders"means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower[check box as applicable]: ❑ Adjustable Rate Rider ❑ Condominium Rider ❑ Second Home Rider ❑ Balloon Rider ❑ Planned Unit Development Rider ❑ Assumption Rider ❑ 1-4Family Rider ❑ Biweekly Payment Rider ❑ Inter Vivos Trust Rider ❑ Other(s) [specify]: (X) "Applicable Law"means all controlling applicable federal, state and local statutes,regulations, ordinances and administrative rules and orders(that have the effect of law)as well as all applicable final, non-appealable judicial opinions. (J) "Community Association Dues, Fees and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (R) "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. (L) "Escrow Items"means those items that are described in Section 3. LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Rvddie Mac UNIFOFFSTR -MFRS Form 3039 1101 DocP"Sr&wcES ,va FORM-?vO1TGPAIJ139 Page 2 0l'17 ORIGINAL B9159 1 PG 2.5 9 a .4 Y (M)"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 Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (N) "Mortgage Insurance"means insurance protecting Lender against the nonpayment of,or default on, the Loan. (0) "Periodic Payment"means the regularly scheduled amount due for (i) principal and interest under the Note,plus(ii)any amounts under Section 3 of this Security Instrument. (P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. § 2601 et seq.) and its implementing regulation,Regulation X(24 C.F.R.Part 3500), as they might be amended from time to time,or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA"refers to all requirements and restrictions that are imposed in regard to a "federally related mortage Ioan" even if the Loan does not qualify as a"federally related mortgage loan" under RESPA. (ty "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 MFRS (solely as nominee for Lender and Lender's successors and assigns)and to the successors and assigns of MFRS, the following described property located in the COUNTY of CUMBERLAND ['[ape of Recording Jurisdiction] [Name orRecording Jurisdiction] LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF PARCEL NO.: 04-23-0609-184 which currently has the address of 120 LINN DR [street] CARLISLE ,Pennsylvania 17013 ("Property Address"): [City/Area) [Zip Code] LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM STR -AIERS Form 3039 1101 DOCPREPSERVICES.INC. FORM-MMTGPA13139 Page 3 of 17 ORIGINAL BK1991PG257I , a t T 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 understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument;but, if necessary to comply with the law or custom,MFRS (as nominee i for Lender and Lender's successors and assigns)has the right: to exercise any or all those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including,but not limited to, releasing and canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to 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 binds 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 payment 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. LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie MaeUNIFORM STR�NT-MFRS Form 3039 1/01 DccPmPSERV1c".TNG FORM-MM4cPAi-mg Page 4 of 17 ORIGINAL eft 1991 PGZ572 } 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2,all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note;(b)principal due under the Note; (c)amounts due under Section 3. Such payments shall be applied to each 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 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 reasonable estimates of expenditures of future Escrow items or otherwise in accordance with Applicable Law, LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFOV INSTRUMENT-MERS Form 3039 1/01 DocPREPSEimc,u.1mc. FORM-mmTCPAt3og Page S of 17 ORIOINAI. BK199lPG2573 X 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 MPA. If there is a surplus of Funds held in escrow,as defined under MPA,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. Wither 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 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 LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mae I]NLI�ORNJ�INSTR NT-MERS Form 3039 1101 Docr�rSmrKuz1,vc, Posts-ausrerAwu9 Page 6 of 17 d��// ORIGINAL r"PA BK.i991P62574 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 insuianre 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 shalt 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 the restoration OF repair is not economically feasible or Lender's security would be Iessened, 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. LOAN NO.: PENNSYLVANIA-Single Family-Fannie Maelk?eddie Mac UNIFOINSTRTJMENI _MERS Form 3439 1/01 DccPREPSERF1cES.INc F0Rm.AA1TGPAi.309 Page 7 of 17 ORIGINAL OKI 991 P62575 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 ther than the right to any refund of unearned premiums paid by Borrower)under ab)any lleinsuranc policies coer of Borrower'sgveering 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 eireurnstances 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 rr the Property. Whether or not Borrower is residing in the Property,Borrower shall maintain the Property in order to pre the Property from deteriorating or decreasing in value clue to its condition. Unvless it is determined pursuant toent 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. bender 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. pon and inspections of the Property, If it has reasona Lender or its agent may make reasonable entries uble cause,bender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause. S. Borrower's Loan Application. Borrower shall be in default if,during the Loan application process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender with material information)in connection with the Loan. Material representations include, but are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest 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 LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFO STR DQCPRBP,SBRP7=AVa FORM.MMTGPAI3139 NT-MERS I''OL717 3039 /lll Page S of 17 ORIGINAL All 991PG2576 Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulations), or(c)Borrower has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and rights under this Security Instrument, including protecting and/or assessing the value of the Property,and securing and/or repairing the Property. Lender's actions can include,but are not Iinuted to: (a)paying any sums secured by a lien which has priority over this Security Instrument; (b)appearing in court;and(c)paying reasonable attorneys' fees to protect its interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes,but is not limited to, entering the Property to make repairs, change 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 Insuranceas 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 nort-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 amoun and for the period that Lender requires)provided by an un insurer selected by Lender again becomes available, obtained,and Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UN FQR]NiI1VSTR T-MERS Form 3039 1/01 D0CPWPSERr7CES INC FORM-NINITCMI-304 Page 9 of ORIGINAL OKI 991PG2577 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 into agreements with other parties force from time to time, and may enter ties that share or modify their risk,or reduce losses. These agreements are on terms and conditions that are satisfactory to t agreements. These agreements may require thhe mortgage insurer and the other party (or parties) to these e mortgage insurer to make payments using any source of funds that the mortgage insurer may have available (which premiums). may include funds obtained from Mortgage Insurance 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 bender 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 Borrowerwill owe for Mortgage Insurance,and they will not entitle Borrower to any refund. M Any such agreements will not affect the rights Borrower has-if an Insurance under the Homeowners protection Act of 1998 or any other law.yThese rights may-with respect to t 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 here unearned at the time of such cancellation or termination, 11• Assignment of Miscellaneous Proceeds;Forfeiture. to and shall be paid to Lender. All Miscellaneous Proceeds are hereby assigned 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, bender shall have the right to hold Proceeds until Lender has had an opportunity to inspect such Property such Miscellaneous to ensure the work has been completed to Lender's satisfaction,provided that such inspection shall be undertaken proraptIy, bender May restoration in a single disbursement or in a series of rothe Y pay for the repairs and agreement is made in writing or Applicable Law requires interest pto be paid on such Miscellaneous Proceeds, rk is P Unless an 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 Ioss in value of the property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security,Instrument, whether or n paid to Borrower. ot then due, with the excess, if any, LOAN N4.: II ppNNS'X'LVANIA-Single Family-Fannie Mae/Freddie Mac UNIT:p1 DoCPRFPS";7CB$j;;q FORM-101TCPAt-313P Page 10 17 `5TR�mNT W -HERS Form 3039 I/ol rORIGINALAI. I BXI 199 1 PG2578 f 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 parry 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 grunted 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 cornmence 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. LOAN NO., PENNSYLVANIA-Single gamily-Fannie Mae/Freddie Mac UNIFORM STR T-MERS Form 3039 1101 DOCPRPPSeJ?;7CESINC FORM-DIMTGPA1-3139 Page 11 of 17 ORIGINAL BK 1991 PG2579 T • 11 k h 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 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(bat 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 bender'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 shaft 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 LOAN NO.: PENNSYLVANIA-Single Family Fannie Mae/Freddie Mae UNMRIVY. �riISTRUMENT-M ERS Form 3039 1/01 Docan�SERwn r,INc. FORM.MMrcPAl.3t39 Page 1Z of 17 `1�p ORIGINAL BK19-91 P62580 r ti f not be deemed to have been given to Lender until actually received by Lender. If any notice required by this Security Instrument is also required under Applicable Law,the Applicable Law requirement will satisfy the corresponding requirement under this Security Instrument. 16. Governing Law;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 Iimitations 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(e)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 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 LOAN NO.: PENNS'YL'VAN[A-Single Family-Fannie Mae/Freddie Mac UNIFORM I STR -MERS Form 3039 1/01 DocPREPSERvicabvc. PORM.MMTOPAW139 Page 13 of 17 ORIGINAL i R 1991 PG2 8 I i require to assure that Lender's interest in the Property p rty and rights under this Security Instrurrrent, 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 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. Sate 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 Iaws 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) LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie We UNIFORM STR NT-MERS Form 3039 1101 DocPREPSmcy1co,INc, roRM-lV7MTCPmanq Page 14 of 17 ORIGINAL 81{ 1991PG258-2 fi e which creates an Environmental Condition, or(c)which, due to the presence,use, or release of a Hazardous Substance,creates a condition that adversely affects the value of the Property. The preceding two sentences shall not apply to the presence,use,or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property (including,but not limited to,hazardous substances in consumer products). Borrower shall promptly give Lender written notice of(a) any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition, 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. NONUNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration;Remedies. Lender shall give notice to Borrower prior to accelerations 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 sheriff's sale or other sale pursuant to this Security Instrument. LOAN NO-- PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM I ST'RUME -MERS Forza 3039 1101 D0cPRQPSBR[7crs,. c.. Po[iu-?arrcrAiauv Page 15 of 17 ORIGINAL 19.91PG2583 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. 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) PATRICK T L>ONARD -Borrower C))� 0_ (Seal) MARLENE- LEONARD -BOrrOwer (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower LOAN NO.: PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mae UNIFORM INSTRUMENT-MERS Form 3039 1/01 DocPmPSERVICES,INC. PORM-T11,1TCPA1-3u9 Page 16 of 17 ORIGINAL 8K t 9 91 PG.2°5 8 4 r , s , a. [Space Below This Line For Acknowledgment] Certificate of Residence y do hereby certify that the correct address of the within-named Lender is 1401 BRANDING LANE SUITE 300•DOWNERS GROVEILLINOIS 60515 Witness my band this day of O () Agent of Lender COMMONWEALTH OF PNNSYLVANIA, C Et)AA COUNTY SS: On this, the lf day of j� ,����, before me, the undersigned officer, personally appeared PATRICK T LEONARD AND MARLENE LEONARD Imown to me(or satisfactorily proven)to be the person_ whose namec,-�-e,subscribed to the within instrument and acknowledged that executed the same for the purposes herein contained. IN WITNESS WHEREOF,I hereunto set my hand and official seal. My commission expires, t4 -XLf- '.?-t0 7 e4,TU 4F PWSYI-VA IA Notarial Sea! ��// ��rr Vo lom R.undsley.Notary Public � 9 JfJ� Simban TvipAdams County O�OT}4R.K i""U$Lt my commis.-,56n 8 3r]=Nov 24,2007' Title of Officer J&nber,peftro harts r t-o of htehzma (Notarial Seat) LOAN NO.: PENNSYLVANIA-Single family-Fannie Mae/Preddie Mae UNIFORM LN R T-ME RS Forth 3039 1/01 DacPREPSERV7ms INc PORT4.mm=pAI3139 Page 17 of 17 ORIGINAL, 1991 P6258:5 ' y ' EXHIBITA ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County,Pennsylvania,more particularly bounded and described as follows: BEING Lot No.32 of the Chapel Hill Plan of Lots No. 1,as recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book No. 6,Page 26,having a frontage on the North of 85 feet on Linn Drive,and an even depth of 140 feet. PARCEL#04-23-0600-184 DBV 132 PAGE 878 I Certify this to be recorded. Its Cumberland County PA a Recorder of Deeds > 99 :I P62396 r EXHIBIT `B ' {00046153} 1l Recording Requested By: Bank of America Prepared By: Hambeik Sepani - - 800-444-4302 101 S.Marengo Ave. Pasadena,CA 91i01 When recorded mail to: CoreLogic Mail Stop:ASGN 1 CoreLogic Drive Westlake,TX 76262-9823 IIIIIIIIIIIIlIIl11111llilllilllllillllllllllllillllllll Doc]D# Tax ID: 04-23-0600-184 Property Address: 120 Linn Dr Carlisle,PA 17013-4246 Property Location: Borough of CARLISLE This spacc for Recorders use .ASSIGNMENT OF MORTGAGE For Value Received,the undersigned holder of a Mortgage(herein"Assignor")whose address is 1800 TAPO CANYON ROAD,SEW VALLEY,CA 93063 does hereby grant,sell,assign,transfer and convey unto GREEN TREE SERVICING LLC whose address is 7360 S.KYRENE ROAD,TEMPE,AZ 85283 all beneficial interest under that certain Mortgage described below together with the note(s)and obligations therein described and the money due and to become due thereon with interest and all rights accrued or to accrue under said Mortgage. Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.,AS NOMINEE FOR HEARTLAND HOME FINANCE,INC.,AN ILLINOIS CORPORATION Mortgagor(s): PATRICK T LEONARD AND MARLENE LEONARD,HUSBAND AND'WIFE Date of Mortgage: 5/4/2007 Original Loan Amount: $209,000.00 Recorded in Cumberland County,PA on:5/8/2007,book 1991,page 2569 and instrument number N/A This Mortgage has not been assigned unless otherwise stated below: Assigned From: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. Assigned To: BANK OF AMERICA,N.A.,SUCCESSOR BYMERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP Recording Date: 7/24/2012 Book/Liber: Page: Instrument Number: 201222069 IN WITNESS WHEREOF,the undersigned has caused this Assignment of Mortgage to be executed on 7/Z9 /2 al 3 Bank of America,N-A. By= - SCJ-1--1— Senita Wagoner , Asslstant Vice President State of California County of on J U L Z 9 2013 before me, C.Wilson Senita Wagoner ,Notary Public,personally appeared who proved to me on the basis of satisfactory evidence to be the person(s)whose name(s)is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity (ies),and that by his/her/their signature(s)on the instrument the person(s),or the entity upon behalf of which the person(s)acted,executed the instrument. T certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Notary Public: C.Wilson (Seal} My Commission Expires: u y 5 I hereby certify that the address of the within named assignee is: O - C.WILSON 7360 S.KYRENE ROAD,TEMPE,AZ 85283 COMMISSIMn# 19W;.- Nr,--y Public-Califpr �,. a givcrside County M�Comm.Expires Jul 2,2016+ Signature y DoclD# -- _ - ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE a' CARLISLE, PA 17013 - y 717-240-6370 _ r Instrument Number-201326729 Recorded On 8/12/2013 At 2:12:51 PM *Total Pages-3 *Instrument Type-ASSIGNMENT OF MORTGAGE Invoice Number-144426 User ID-BMM *Mortgagor-LEONARD,PATRICK T *Mortgagee-GREEN TREE SERVICING LLC *Customer-CORELOGIC SOLUTIONS *FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $11.50 DO NOT DETACH RECORDER OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $55.50 I Certify this to be recorded in Cumberland County PA o¢cum O y a ° RECORDER O DEDS ryao *-Information denoted by an asterisk may change during the veri0ention process and may not be reflected on this page. 111111111110[111111111111 EXHIBIT ` U {000461531 CRPRDNRBS46b 6/15/2012 9:37 :08 AM PAGE 4/085 888-294-5658 NOT MAY 04 2007 DOWNERS GROVE ILLINOIS [Date] [City] [State] 120 LM DR CARLISLE,PENNSYLVANIA 1701.3 [Property Address] 1. BORROWER'S PROMISE TO PAY In remm for a loan that I have received, I promise to pay U.S. $� 7A9,000.00 (this amount is called"Principal"), plus interest,to the order of the Lender. The Lender is HEARTLAND 110:1&MANCE,INC.,AN ILLINOIS CORPORATION I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST ' Interest will be ehargon unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.625 -%. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6;B)of this Note. 3, PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1ST day of each month beginning on JULY 01 , 2007 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. U.o-ir-JUNE 01 2037 , I still owe amounts under this Note,I will pay those amounts in fidl on that date, which is called the "Maturity Date." I will make my monthly payments at 1401 BRANDING LANE,SHITE 300 DOWNERS GROVE,ILLINOIS 60515 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. S 1,33825 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment.", When I make a Prepayment,I will tell the Note Holder in writing(bat I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due tinder the Note. I may make a full Prepayment or partial Prepaymentswithout paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal.that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unle% the Note Holder agrees in writing to those changes. LOAN NO.: WN NO.: MULTISTATE FIXED RATE NOT"ingle Family-Fannie MaeiFreddto Mae UNWORM INSTRUMENT FORM 3240 1101 DOCPFEPSEr.F'tcAs,Ixc. Foaut-msnew-mna Page I of 3 ORIGINAL CRPRDNRBS46b 6/15/2012 9:37 : 08 AM PAGE 6/085 888-294-5658 5. LOAD CHARGES If a law,which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit;and(b)any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. DORlR.OWER'S)'AMURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notiee is mailed to me or delivered by other means. (ll) No Waiver By Note Holder Even if,at a time when I am in default,the Note Holder does not require me to pay immediately in full as described above,the Note Holder will still have the right to do so if I ant in default at a later time, (E) Payment of Note Holder's Costs and Expauses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example,reasonable attorneys'fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note WM be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to t£eep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor,surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations,including the obligations of a guarantor, surety or endorser of this Note, is also obligated to kelp all of the promises made in this Note. The Note holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of as may be required to pay all of the amounts owed under this Note. LOAF,NO.: MIN NO.: MULTMATE rIXED RATE NOTE SLu&Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT FORM 3200 1101 DocPnP SFxwcEslvc Paxu.-msnwN-sw+ Page 2 o€3 ORIGINAL CRPRDNRBS46b 6/15/2012 9:37: 08 AM PAGE 6/085 888-294-5658 . 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require t11e Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Now Holder to give notice to other persons that amounts due have not been paid. 10, UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses whicb might result if I do not keep the promises which I make in this Note.That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions ase described as follows: 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. WI THE 'D(S)ANI ALIS) OF THE UNDERSIGN D. r (Seal) (Seal) Borrower -Borrower PATRICK T LEONARD MARLENE LEONARD (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower j5ipi Origin at Only] LOAN NO.: ASIN NO.: MMTIS€ATE ISD RATE NOTE-Shoe Family-Fannin Maofteddie Mac UNIFORM INSTRUMENT FORAi 3200 1f91 Do1PREPSmvrrE. INc r-ostm-mm mi-ssys Page 3 of 3 ORIGINAL CRPRDNRBS46b 6/15/2012 9:37 :08 AM PAGE 10/085 888-294-5658 ALLONGE TO NOTE ALLONGE TO NOTE DATED: MAY 4,2007 IN FAVOR OF: HEARTLAND HOME FINANCE, INC. EXECUTED BY: PATRICK T. LEONARD MARLENE LEONARD 120 LINN DR. CARLISLE, PENNSYLVANIA. 17013 LOAN AMOUNT: $209,000.40 LOAD NUMBER: PAY TO THE ORDER OF WITHOUT RECOURSE: Countrywide Bank, FSB BY: &J-34z'5— DAVELEONE VICE PRESIDENT HEARTLAND HOME FINANCE, INC. PAYTOTHEORDEROF PAYTOTHEMMOF C0UWRf I0E HOME LOINS,R;Q WITHOUT{BOURSE 1{aHM NEWUME COUrJTFIMEE BANI(,f= COUNTMV44DEHOMEUWANO LAURIE IJOER IACHE.ESJOLUM A v SEWRWEPREMM ;_ EAMMVIMPREMW EXHIBIT `D ' {00046153} Negative True Escrow Breakdown Legative True Escrovr Summary ;Beg Ba! $ 57.29 ;Payments � - ;Disbursements S 8,703.11 ;Ending,Bad S (8,645.82) Negative True Escrow Balances 57.29 Balance On 04/16/2013 Payment Disbursement hate Transaction Description Running Balance $ - 1.27.14 05/15/201' PPAI (69.35) $ - $ 127.14 06/2.5/2013 PIt1l $ (196.99) $ - $ 127.14 07/19/2013 PMI $ (324.1.3) $ - $ 1.2.7.14 07/19/2013 PMI (451.27) - 2,213.03 08/06/2013 Schoolrax $ (2,664.30) - $ 1.27.14 0°/07/2013 PMI $ (2,791.44) j $ - $ 127.14 09/17/201.3 PMI $ (2,918.58) - $ 127.14 10/04/2013 PMI $ (3,045.72) $ - $ 1.27.14 11/07/2013 Pall $ {3,172.86 - $ 127.14 1,2/06/201.3 PMI $ (3,300.00) $ - $ 819.00 12/09/2013 Haz/Eire Insurance $ (4,119.00) $ - $ 127.14 01/07/2014 PMJ (4,246.14) $ - $ 127.14 02/10/2014 PMl $ (4,373.28) $ - $ 127.14 03/06/2014 PMI $ (4,500.42) - $ 127.1.4 04/04/2014 PMI $ (4,627.56) $ - $ 1,042.39 04/05/2014 City Tax $ (5,669.95) $ - $ 127.14 1}5/06/2014 Pati/I $ (5,797.09) $ - $ 127.14 06/06/2014 PMI $ (5,924.23) $ $ 127.14 07/07/2014 PMI S (6,051.37) $ - $ 2,213.03 08/01/2014 School Tax $ (8,264.40) - $ 127.14 08/01/2014 MAI $ (8,391.54) $ $ 1.27.14 09/01/2014 PMI $ (8,518.68) - $ 127.14 10/01/2014 PMI $ (8,645.82) $ - 8,703.11 $ (5,645.82) EXHIBIT `E' {00046153} (Rev. 9/2008) DATE: June 25, 2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM r 111filied Article Number FORECLOSURE 9314 8699 0430 0004 0626 57 Via: First Class and Certified Mail SENDERS RECORD Patrick T. Leonard Marlene Leonard - . 151 . 120 Linn Drive 120 Linn Drive 9314 8699 0430 0004 0626 02 Carlisle, PA 17013 Carlisle, PA 17013 SENDERS� RECORD . This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies servingyourCounty are listed at the end of this Notice. If you have any questions, o�y call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. * (Must be at least 30 point type) {00097641} HOMEOWNER'S NAME(S): Patrick T. Leonard and Marlene Leonard PROPERTY ADDRESS: 120 Linn Drive, Carlisle, PA 17013 LOAN ACCT.NO.: ORIGINAL LENDER: Mortgage Electronic Registration Systems, Inc. ("MERS") as nominee for Heartland Home Finance, Inc. CURRENT LENDER/SERVICER: Green Tree Servicing LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to- face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE --Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY,AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE". . YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR {00097641) APPLICATION IS EVENTUALLY APPROVED AT ANYTIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE SLOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 120 Linn Drive, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Charges: 2/1/2013-5/1/2013 4 at$1,774.84 $7,099.36 6/1/2013-6/1/2014 13 at$1,800.02 $23,400.26 Late Charges: $66.91 TOTAL DUE: $30,566.53 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable.) N/A HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice (plus three (3) days for mailing) BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $30,566.53, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD(plus three (3) days for mailing). Payments must be made either by cash,cashier's check,certified check or money order made payable and sent to: Green Tree PO Box 94710 Palatine, IL 60094-4710 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) N/A {00097641} IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice (plus three (3) days for mailing), the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and.you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS (plus three (3) days for mailing), the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period (plus three (3) days for mailing),you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period (plus three (3) days for mailing) and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Green Tree Servicing LLC Contact Address of Lender (inquiries only, not for payments): 8200 Ih 10 West Suite 500, San Antonio,TX 78230-0000 Send Payment to Green Tree,PO Box 94710,Palatine,IL 60094-4710 Phone Number: 1-800-643-0202 Fax Number: 1-866-210-6192 Contact Person: Collections Supervisor EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You _ may or _X_ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. {00097641) 1 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY See attached list of the consumer credit counselinz agencies in your county See attached Notice Pursuant to the Fair Debt Collection Practices Act {00097641} NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT 1. This is an attempt to collect a debt and any information obtained will be used for the purpose. 2. Unless you dispute the validity of this debt, or any portion thereof,within thirty(30)days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within thirty(30) days of receipt of this notice that the debt, or any portion thereof, is disputed,our offices will provide you with verification of the debt or copy of the judgment against you,and a copy of such verification or judgment will be mailed to you by our offices. 4. If you notify our offices in writing within thirty(30) days of receipt of this notice,our offices will provide you with the name and address of the original creditor, if different from the current creditor. {00097641} b HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated:04/23/2014 05:44 PM Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg,PA 17102 Harrisburg,PA 17104 888-511-2227 717-232-9757 Housing Alliance of York/Y Housing Resources Maranatha 290 West Market Street 43 Philadelphia Avenue York,PA 17401 Waynesboro,PA 17268 717-855-2752 717-762-3285 Path5tone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg,PA 17102 Chambersburg,PA 17201 717-234-6616 717-264-5913 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg,PA 17325 Harrisburg,PA 17110 717-334-1518 717-780-3940 800-342-2397 TO: TO: Marlene Leonard i Patrick T.Leonard 120 Linn Drive 120 Linn Drive Carlisle,PA 17013 Carlisle,PA 17013 I f I SENDER: SENDER: TAS 1 TAS REFERENCE: REFERENCE: E Green Tree v.Leonard f Green Tree v. Leonard !' `S�r4 8�r9 0��0 0004 0626 57 � 14 $�� 0430 0004 0626 02 P Form 38 anua P orm 38 anua 12005 _ RETURN Postage RETURN Postage RECEIPT Certified Fee 0. 19RECEIPT Certified Fee SERVICE i SERVICE Return Receipt Fee Return Receipt Fee Restricted Delivery =- Restricted Delivery Total Postage&Fees Total Postage&Fees USPSI& POSTMARK OR DA LISPS® POSTMARK OR DATE .. Receipt for Receipt for f i Certified Mail' � Certified Mail- No No Insurance Coverage Provided No Insurance Coverage Provided Do Not Use for International Mail Do Not Use for International Mail VERIFICATION The undersigned hereby states that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904,relating to unsworn falsification to authorities. Name: 1-e e- Date: Title: 17�P cld'� '-*P 7 C Green Tree Servicing LLC RE: Leonard, Patrick T. &Marlene {00110253} LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id.No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id.No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215)942-9690 ATTORNEY FOR PLAINTIFF GREEN TREE SERVICING LLC COURT OF COMMON PLEAS 345 ST. PETER STREET 1100 LANDMARK TOWERS CIVIL DIVISION ST. PAUL, MN 55102 PLAINTIFF CUMBERLAND COUNTY VS. NO. PATRICK T. LEONARD MARLENE LEONARD COMPLAINT IN 120 LINN DRIVE MORTGAGE FORECLOSURE CARLISLE,PA 17013 DEFENDANTS NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action you may be able to participate in a court supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First within twenty 20 days of your receipt of this notice you must contact MidPenn Legal Services at 717 2439400 extension 2510 or 800 8225288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative you must promptly meet with that legal representative within twenty 20 days of the appointment date. During that meeting you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto the legal representative will prepare and file a Request for Conciliation Conference with the Court which must be filed with the Court within sixty 60 days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference {00118201} is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty 60 days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME YOU MUST ACT QUICKLY AND TAKE THESTEPS REQUIRED BY THIS NOTICE THIS PROGRAM IS FREE. LAW OFFICES OF GREGORY JAVARDIAN DATE: BY: 4GregJavar ian, uire Id. No. 55669 Kennedy, uire Id. No. 77149 ❑Meghan K. Boyle, 17squire Id. No. 201661 ❑Sean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff. {00 1182011 t Z Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale?Yes ❑ No ❑ Listing date: Price: $ Realtor Name Realtor Phone Borrower Occupied? Yes ❑ No ❑ Mailing Address(if different) City State: Zip: Phone Numbers:Home: Office: Cell: Other: Email: Number of people in household How long: CO-BORROWER Mailing Address: City: State Zip: Phone Numbers: Home: Office: Cell: Other: Email: Number of people in household How long: FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number Date You Closed Your Loan: Second Mortgage Lender: Type of Loan {00 118201 Loan Number Total Mortgage Payments Amount: $ Included Taxes Insu'ranceS Date of Last Payment: Primary Reason for default: Is the loan in Bankruptcy?Yes ❑ No❑ If yes provide names, location of court, case number&attorney Assets Amount Owed: Value: Home: $ $ Other Real Estate $ $ Retirement Funds $ $ Investments $ $ Checking $ $ Savings $ $ Other $ $ Automobile#1: Model Year: Amount owed: $ Value: Automobile#2: Model Year: Amount owed $ Value: Other transportation(automobiles boats motorcycles Model)Model: Year: Amount owed$: Value: $ {00118201} MONTHLY INCOME Name of Employers 1. 2. 3. Additional Income Description(not wages): 1• monthly amount $ 2. monthly amount$ Borrower Pay Days: Co-Borrower Pay Days MONTHLY EXPENSES (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage $ Food $ 2nd Mortgage $ Utilities $ Car Payment(s) $ Condo/Neigh. Fees $ Auto Insurance $ Med not covered $ Auto fuel/repairs $ Other prop payment $ Install Loan Payment $ Cable TV $ Child Support/Alimony $ Spending Money $ Day/Child Care Tuition $ Other Expenses $ Amount Available for Monthly Mortgage Payments Based on Income Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes please provide the following information Counseling Agency: Counselor: Phone Office: Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)assistance Yes ❑ No ❑ If yes please indicate the status of the application: {00118201} Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency Yes ❑ No ❑ If yes please indicate the status of those negotiations: Please provide the following information if known regarding your lender's or lender loan servicing company Lender Contact(Name) Phone Servicing Company(Name) Contact: Phone AUTHORIZATION I/We authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date {001 18201) x Please forward this document along with the following information to lender and Gregory Javardian,Esquire, lender counsel: Proof of income Bank statements to cover the last 60 day period If self employed,we must have the last 3 bank statements from both their business and personal bank accounts. Proof of any expected income for the last 45 days Dodd Frank Certificate 4506T-EZ form Copy of last two months utility bill Letter explaining reason for delinquency and any supporting documentation Hardship letter Listing agreement if property is currently on the market Gregory Javardian, Esquire 1310 Industrial Boulevard, Suite 101 Southampton,PA 18966 (tel)215-942-9690 (fax)215-942-9695 Attention: Tami Kowalski (tel)215-942-9690 ext. 1309 tam i ,javardianlaw.com {00 118201} SHERIFF'S OFFICE OF CUMBERLAND COUNTY ' c F\C Ronny ��Amde�on '^~ - - � 8FTHE PAOTHONOT8�(, Sheriff ^~ Jody S Smith ��' ' ~°n� 20111OCTK3 AM 10: 03 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor nEw,THE sHsRIp PENNSYLVANIA Green Tree Servicing LLC vs. Patrick T. Leonard (et al.) Case Number 2014-5538 SHERIFFS RETURN OF SERVICE 1007/2014 06:09 PM - Deputy Jamie DiMartile, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Patrick T. Leonard at 120 Linn Drive, Carlisle Borough, Carlisle, PA 17013. 1E D1MARTILE, DEPUTY 10/07/2014 06:09 PM - Deputy Jamie DiMartile, being duly according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true coto a person representing themselves to be Patrick Leonard, Husband, who accepted as "Adult Person in Charge" for Marlene Leonard at 120 Linn Drive, Carlisle Borough, Carlisle, PA 17013. |ED|MARTLE.DEPUTY SHERIFF COST: $50.78 SO ANSWERS, October 08, 2014 RONNYRANDERSON, SHERIFF CountyStaite Sheriff, Teleosoft, Inc. dr LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN F. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 GREEN TREE SERVICING LLC 345 ST. PETER STREET 1100 LANDMARK TOWERS ST. PAUL, MN 55102 vs. PATRICK T. LEONARD MARLENE LEONARD 120 LINN DRIVE CARLISLE, PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 14-5538 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against PATRICK T. LEONARD and MARLENE LEONARD, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As Set forth in Complaint $220,267.15 Interest 07/29/2014 to 12/30/2014 5,419.26 TOTAL $225,686.41 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. Damages are hereby assesed as indicated. DATE: oal3l hv Are ry Javardi OM ay F. Kenned DMeghan K. Boyle'; Esquire Id. No. 201661 O Sean P. Mays, Esquire ld. No. 307518 Attorneys for P1 squire Id. No. 55669 squire Id. No. 77149 PRO PROTHY av,A4 CA_A- V?z>1.`""k kbrLo Noe P kir 31s6(10 y LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 GREEN TREE SERVICING LLC vs. PATRICK T. LEONARD MARLENE LEONARD COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 14-5538 VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he/she is attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) Defendant(s), PATRICK T. LEONARD and MARLENE LEONARD, is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C.S. Appx. §§ 501 et. seq. (b) Defendant, PATRICK T. LEONARD, is over 18 years of age, and resides at 120 LINN DRIVE, CARLISLE, PA 17013. (c) Defendant, MARLENE LEONARD, is over 18 years of age, and resides at 120 LINN DRIVE, CARLISLE, PA 17013. (d) Plaintiff, GREEN TREE SERVICING LLC, is an institution conducting business under the Laws of the Commonwealth of Pennsylvania with an address of 345 ST. PETER STREET, 1100 LANDMARK TOWERS, ST. PAUL, MN 55102. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 12/30/2014 Greg Javardian, quire Id. No. 55669 ❑M F. Kennedy, as quire Id. No. 77149 ❑Meghan K. Boyle, Esquire Id. No. 201661 ❑ Sean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 GREEN TREE SERVICING LLC 345 ST. PETER STREET 1100 LANDMARK TOWERS ST. PAUL, MN 55102 PLAINTIFF v. PATRICK T. LEONARD MARLENE LEONARD 120 LINN DRIVE CARLISLE, PA 17013 DEFENDANTS ATTORNEYS FOR PLAINTIFF In The Court of Common Pleas Cumberland County No. 2014-5538 TO: PATRICK T. LEONARD MARLENE LEONARD 120 LINN DRIVE CARLISLE, PA 17013 DATE OF NOTICE: DECEMBER 18, 2014 NOTICE, RULE 237.1 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims se forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 BY: BGre ry Javardi , Es vie Id. No. 55669 OM F. Kennedy, Es. re Id. No. 77149 OMeghan K. Boyle, E ire Id. No. 201661 OSean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff Listed se encuentra en estado de rebeldia por no haber tornado la accion requiida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de esta notificacion, el tribunal podra, sin necesidad de compararecer usted en corte o escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o Ilame por telpfono a la oficina, cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. "NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE" {00143904} OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: PATRICK T. LEONARD MARLENE LEONARD 120 LINN DRIVE CARLISLE, PA 17013 GREEN TREE SERVICING LLC COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY vs. No.: 14-5538 PATRICK T. LEONARD MARLENE LEONARD Defendant(s) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession by Default _ Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Law Offices of Gregory Javardian at this telephone number: (215) 942-9690. )64;)))11