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HomeMy WebLinkAbout14-5570 Supreme Ca Co 'Pen nsylvania R COLIC PC 0-M _0 leas For Prothonotary Use Only: (f I l C sber��S�he tt Docket No: tIf S CUMB,�RLND County �n -- I SS The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S x❑ Complaint ❑ Writ of Summons « Petition 0 Transfer from Another Jurisdiction Ui Declaration of Taking E C Lead Plaintiff s Name: Lead Defendant's Name: HOUSEHOLD FINANCE CONSUMER DISCOUNT CO. MICHAEL S. FAKE AND SUSAN G. FAKE IST Dollar Amount Requested: O within arbitration limits I Are money damages requested? ❑ Yes [9 No (check one) ❑outside arbitration limits O N Is this a Class Action Suit? Q Yes E3 No Is this an MDJAppeal? 13 Yes El No A Name of Plaintiff/Appellant's Attorney: ANDREW J. MARLEY Check here if you have no attorney(are a Self-Represented [Pro Sel Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS Intentional ❑I Buyer Plaintiff Administrative Agencies El Malicious Prosecution ❑ Debt Collection:Credit Card El Board of Assessment Ej Motor Vehicle 0 Debt Collection: Other Board of Elections 0 Nuisance Dept.of Transportation S FLjj Premises Liability Il Statutory Appeal:Other F Product Liability(does not include Emass tort) I� Employment Dispute: ❑ Slander/Libel/Defamation Discrimination C ❑❑ Other: 0 Employment Dispute:Other Ej Zoning Board T ❑ Other: I I� Other: O MASS TORT 0 Asbestos N ❑i Tobacco Toxic Tort-DES r Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste Other: � Ejectment © Common Law/Statutory Arbitration B ❑ Eminent Domain/Condemnation Cd Declaratory Judgment Ground Rent - Mandamus Landlord/Tenant Dispute J Non-Domestic Relations n Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial I Quo Warranto Dental ® Partition 01 Replevin J Legal © Quiet Title 0 Other: 0 Medical © Other: n Other Professional: Updated 1/1/2011 ti. r FICL Steven K. Eisenberg, Esquire(75736) ol- THE PRO7H0N0 TErtnk`, M. Troy Freedman, Esquire(85165) 2011It SES' 19 AM 0. 28 Leslie J. Rase, Esquire(58365) ITY Andrew J. Marley(312314) CflP�iB�r�L��P�D C PENNSYLVANIA Stern&Eisenberg, PC 1581 Main Street, Suite 200 Warrington,Pennsylvania 18976 Telephone: (215) 572-8111 Facsimile: (215) 572-5025 (Counsel for Plaintiff) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL ACTION NUMBER: 1 �- 636 GRAND REGENCY BLVD. BRANDON,FL 33510 COMPLAINT IN Plaintiff, MORTGAGE FORECLOSURE V. MICHAEL S. FAKE AND SUSAN G. FAKE 511 OLD ORCHARD LANE CAMP HILL,PA 17011-1829 Defendant(s). CIVIL ACTION/MORTGAGE FORECLOSURE 1. This is an action to foreclose a mortgage brought on behalf of Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY. 2. The Defendant(s), MICHAEL S. FAKE AND SUSAN G. FAKE ("Mortgagor(s)") are the real owner(s) of the mortgaged property hereinafter described. The last known address of Mortgagor(s) is 511 OLD ORCHARD LANE, CAMP HILL,PA 17011. a �SPaR PA Complaint 1-A(CML Owner) 04JUN14 ,\l x i 3. Attached hereto as Exhibit A is a true and accurate copy of the promissory note and/or loan agreement ("Note") bearing the date of 09/20/2006, in which MICHAEL S. FAKE and SUSAN G. FAKE promised to pay the sum of$182,819.04 ("Loan"). 4. Attached hereto as Exhibit B is a true and correct copy of the mortgage ("Mortgage"), dated 09/20/2006 and bearing the names of Mortgagors, as the mortgagors, on real estate together with all improvements thereon, located at 511 OLD ORCHARD LANE, CAMP HILL, PA 17011 ("Real Estate"). The Mortgage was duly recorded on 09/25/2006, as Book 1967 and Page 147, in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania. 5. The Real Estate subject to the Mortgage is described in the legal description attached hereto as Exhibit C. 6. The Mortgage is in default because the payments due and secured by the Mortgage have not been made. The Loan is currently due for the OCTOBER 2009 payment and all payments thereafter. 7. The business records maintained by Plaintiff demonstrate that the Notice of Intention to Foreclose was mailed, by registered or certified mail, to Mortgagor(s) at Mortgagor(s)' last known address and, if different, to the address of the Real Estate ("Notice") on the date set forth in the Notice. A true and accurate copy of the Notice is attached as Exhibit D. A Notice of the Homeowner's Emergency Assistance Program was not mailed to the Mortgagor(s) because Mortgagor(s) are more than 24 months delinquent and more than $60,000.00 in arrears. PA Complaint 1-A(CML Owner) 04JUN14ver4.0 2 f � 8. As of 09/03/2014, there is due and owing amounts secured by the Mortgage in the sum of$211,986.04, which amount due includes the following: Principal Balance: $142,397.07 Interest through 09/03/2014 at the Current Rate of 9.10000%: $66,388.48 Advances for Taxes: $4,743.22 Advances for Hazard Insurance: $0.00 Advances for Private Mortgage Insurance: $0.00 Total: $213,528.77 Less Suspense Balance or Escrow surplus, if any: $1,542.73 Less Restricted Escrow Balance, if any: $0.00 Total Amount Due or Owed: $211,986.04 The per diem interest due from 09/04/2014 is $35.5017. These itemized amounts may not include all fees currently due and owing under the Note and secured by the Mortgage, including certain late fees, inspection charges, property preservation expenses, and attorney's fees, since Plaintiff has decided to forgo collecting those fees, but that decision does not indicate that such fees were not properly due and owing at the time of any prior communications to the borrower(s) on the Note. PA Complaint I-A(CML Owner) 04JUN14ver4.0 3 c WHEREFORE, Plaintiff demands in rem judgment against the Defendant in the sum of $211,986.04, together with the current interest at the rate of 9.10000% and other costs and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged property. o By: STEW&EISENBER , P ANDREW J. MARLEY, E IRE, #312314 Attorneys for Plaintif VERIFICATION I am a VP and Asst Sec of the Administrative Services Division of the Plaintiff and do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff and the facts set forth in paragraphs 1 through 8 of the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties relating to unsworn falsification to authorities. By: JJ)Jt D /fit Signaturl-luWA (Dar] Printed Name Signatory On behalf of HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY vP and Asst.Sec, Its: Admin Serv.Div Signatory's Title PA Complaint 1-A(CML Owner) 04JUN14ver4.0 4 LOAN AGREEMENT Including Truth-in-Lending Disclosure Lender:(Called"We", "Us", "Our") HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 25 GATEWAY DRIVE GATEWAY SQUAREISUITE 107 MECHANICSBURG, PA 17055 Borrowers: (Called"You","Your") MICHAEL S. FAKE SUSAN G. FAKE 511 OLD ORCHARD LN CAMP HILL, PA 17011 Date of Loan: 09/20/2006 Loan Number In this agreement, "you", "your"mean the Borrowers)who signs this agreement. "We","us"and"our" refer to the Lender.This agreement covers the terms and conditions of your loan. It is important to us that you clearly understand the features of your loan.Please read this agreement carefully, and ask us any questions you may have. Truth-In-Lending Disclosure ANNUAL FINANCE CHARGE Amount Financed Total of Payments PERCENTAGE RATE The dollar amount The amount of The amount you will The cost of your credit the credit will cost credit provided to have paid after you have as a yearly rate. you. you or on your made all payments as behalf. scheduled. 9.864% $102,094.13("e") $176,999.47 $279,093.60("e") Your payment schedule will be: Number of Payments Amount of When Payments are Due("e") Payments 1 $2,325.78 Day 20 of each month thereafter. 119 $2,325.78 Day 20 of each month thereafter. "e"means an estimate i YOU ARE GIVING US A SECURITY INTEREST IN THE REAL PROPERTY AS DESCRIBED IN THE MORTGAGE AND LOCATED AT: 511 OLD ORCHARD LN CAMP HILL, PA 17011 09/20/2006 13:00 Page 1 of 6 IIIIIIfllll�l�I�I�IIIi��lll�llllllllE 'B'T I lllllllllllllil�lilllll�ld�ll 'F62089AE9A-96-C E^ORIGINAL Late Charge If your monthly installment is not paid in full within 10 day(s)after it is due, you will be charged a late charge equal to 5%of the full amount of the monthly installment. Prepayment You may prepay your loan in full or in part at any time. If you pay off your loan early, you may have to pay a penalty and you will not be entitled to a refund of that part of the Finance Charge consisting of any prepaid finance charges. See your contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date, and prepayment refunds and penalties. The Settlement Statement provides your disbursements and the itemization of the Amount Financed. ABOUT THE SECURITY: Your Obligation to Insure You shall keep the structures located on the real property securing your loan insured against damage caused by fire and other physical hazards, name us as a loss payee and deliver to us a loss payable endorsement. If insurance covering the real property is canceled or expires white your loan is outstanding and you do not reinstate the coverage,we may obtain,at our option, hazard insurance coverage protecting our interest in the real property as outlined below. Real Property Taxes and Homeowners Insurance covering fire and other hazards on the real Homeowners Insurance property security is required,naming us as a loss payee for the term of your loan. You shall pay us on the day that monthly installments are due under this agreement, an additional sum(the"Funds")to be used to provide for payment of amounts due for: (a)taxes and assessments and other items which can attain priority over the Mortgage as a lien or encumbrance on the real property;(b) leasehold payments or ground rents on the real property,if any;(c) premiums for any and all insurance required by us under this agreement and the Mortgage("Escrow Items"). You will pay us the Funds for Escrow Items unless we waive your obligation to pay the Funds for any or all Escrow Items. We may waive your obligation to pay us Funds for any or all Escrow Items at any time. Any such waiver must be in writing. In the event of such waiver, you will be solely responsible for paying the amounts due for any Escrow Items directly and, if we require,you shall furnish us with receipts evidencing such payment within such time period as we may reasonably require. Title Insurance Title insurance on the real property security is required, naming us as a loss payee. You must purchase title insurance or its local equivalent protecting our lien on the real property as a condition to obtaining your loan. You may purchase title insurance from any title insurance provider you choose that we reasonably believe provides sufficient financial protection to us. You request such title insurance 09/20/2006 13:00 Page 2 of 6 _ f IIIIII III ISI IIU I ll1111 loll lll�111�lll(lll 111111111 NI 111ill11111111111 IN Ifs IN 1111111116111111111 I 'F82089AE9A-90-CET-8-000-0315LE-Z-2-0"FAKE A ORIGINAL r and authorize us to deduct the costs of the title insurance from your loan proceeds in order to pay the title insurance provider. Lender's Right to Place You authorize us,at our option,to obtain hazard insurance coverage Hazard Insurance on the real property in an amount not greater than the outstanding balance of principal and interest on your ban or,if known to be less, the replacement value of the real property, in the event that you fail to maintain the required hazard insurance outlined above or fail to provide adequate proof of its existence. You authorize us to charge you for the costs of this insurance. We may choose to add the insurance charges to the unpaid balance of your loan,which will accrue interest at the Contract Rate, or bill you for the annual premium on a periodic basis. The addition of the insurance charges due might increase the amount of your final monthly installment. The cost of lender-placed hazard insurance might be higher than the cost of standard insurance protecting the real property. The lender-placed insurance will not insure the contents of the real property or provide liability coverage. The insurance might not be the lowest cost coverage of its type available and you agree that we have no obligation to obtain the lowest cost coverage.We or an affiliated company might receive some benefit from the placement of this insurance and you will be charged for the full cost of the premium without reduction for any such benefit. If at any time after we have obtained this insurance, you provide adequate proof that you have subsequently purchased the required coverage, we will cancel the coverage we obtained and credit any unearned premiums to your loan, ABOUT YOUR LOAN REPAYMENT: SCHEDULED MATURITY DATE 09/20/2016 PRINCIPAL $182,819.04 MONTHS OF CONTRACT 120 CONTRACT RATE(per year) 9.100%u AMOUNT FINANCED $176,999.47 PREPAID FINANCE CHARGES $5,619.57 Promise to Pay You agree to the terms of this agreement and promise to pay us the principal (Amount Financed plus prepaid finance charges consisting of Origination Fee/Points and Closing Fee)plus interest which is computed at a rate of 9.100%(the "Contract Rate"). You agree to pay us in monthly installments as stated in the Payments provision of this agreement. You also agree to pay us:(a)other charges as provided in this agreement;(b)credit insurance charges, if any;(c)collection costs permitted by applicable law,including reasonable attomeys'fees otherwise due under your Mortgage and(d)any other charges reflected in your settlement statement. 09/20/2000 13:00 Page 3 of 0 I IINIi�i 1(NI ISI 1111 Ili 911111111111111111111110 111111111111III 1111 oil 111111111111111111111111111111111191111111111 'F82089AE9A-08-CET-8-000-0315LE-Z-3-0"FAKE^ORIGINAL Interest Interest will be charged on the unpaid principal until the full amount of principal has been paid. You will pay us interest at a yearly Contract Rate of 9.100%. The interest rate required by this provision is the rate you will pay both before and after any default as described in this agreement. Payments Time and Place of Payments You will pay us principal and interest by paying your monthly installments. You will make your monthly installments to us on the same day of each month beginning on or about 10/20/2006. You will make these monthly installments every month until you have paid all of the principal and interest and any other charges described herein that you may owe under this agreement. Your monthly installments will be applied to interest before principal. If,on the Scheduled Maturity Date, 09/20/2016,you still owe amounts under this agreement, you will pay those amounts in full on that date, which amount will include interest at the then current Contract Rate or any such other rate as required by law. You will make your monthly installments at the address shown on page one or at the address shown on your monthly billing statement or at a different place that we may give you, Amount of Monthly Installments Your monthly installments will be in the amount of$2,325.78, plus the amount of any optional insurance you elected. Prepayment Subject to the prepayment penalty described below, you may prepay your loan in full or in part at any time. If you pay off your loan early, you may have to pay a penalty and you will not be entitled to a refund of that part of the Finance Charge consisting of any prepaid finance charges_ Prepayment Penalty Your loan contains a prepayment penalty. If you prepay the entire outstanding balance of your loan at any time within 24 months of the Date of Loan, 09/20/2006, you agree to pay a prepayment penalty equal to 6 months interest calculated at the Contract Rate in effect at the time of prepayment on the unpaid principal balance. No prepayment penalty will be imposed; (a)if your loan is refinanced by another loan with us;(b)after 24 months;(c)it your loan is prepaid from the proceeds of any insurance;or(d)if we sue you. Late Charge If your monthly installment Is not paid in full within 10 day(s)after it is due,you will be charged a late charge equal to 5%of the full amount of the monthly installment. 09/20/2006 13:00 Page 4 of 6 I�Illl llJl ll}Il llll llll11111 1111111111111111111111111111111111111111111 II IIIA IIII/1111111 I I1111)1111111 I IIII II�II Ii 'F62089AEDA-g6-CET-a-000-M15LE-Z-4-0—FAKE^ORIGINAL Bad Check Charge You agree to pay$20.00 each time any check or payment is made on your loan by any means, including but not limited to, a check or ACH (our Authorization to Debit Account),which is returned unpaid by your bank or other financial institution for any reason. Additional Charges You agree to pay any amounts actually incurred by us for services rendered in connection with the opening and servicing of your loan, as allowed by law.These amounts may include fees for appraisals,title examination, title insurance or its local equivalent, fees and taxes paid to public officials in connection with recording, releasing or satisfying the Mortgage and other taxes as shown in the Settlement Statement incorporated herein by this reference, You also agree to pay any other amounts incurred by us in connection with the servicing of your loan including any amounts that we may(but need not)pay or that are otherwise due under the Mortgage,incorporated herein by this reference. Default If you fail to make any monthly installment after it becomes due or fail to comply with the terms of the Mortgage,we may require that you pay us, at once and without prior notice or demand,the unpaid balance of your loan plus accrued interest and any applicable charges in this agreement as authorized. Security Interest You agree to give us a security interest in the real property as described in the Mortgage. ABOUT OUR RELATIONSHIP: Exchange of Information You understand and agree that we will call you from time to time to discuss your financial needs and any loan products that may be of interest to you as may be permitted by applicable law. For more information regarding our privacy practices,please refer to our Privacy Statement,which is included with your loan documents_You agree that the Department of Motor Vehicles(or your state's equivalent of such department)may release your residence address to us, should it become necessary to locate you. Credit Bureau Reporting If you fail to fulfill the terms of your loan, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. Telephone Monitoring You agree that we may listen to and/or record telephone calls between you and our representatives for quality assurance purposes. Insurance Credit insurance is optional.Any applicable insurance disclosures are included with this agreement and are incorporated herein by this reference. Alternative Dispute The terms of the Arbitration Rider signed by you as part of your loan Resolution transaction are incorporated herein by this reference, 09/20/2006 13:00 Page 5 of 6 (I I Ill!I111�111111II111111101111II III�I111111111111111 m 111111111611111 IN 011111111111111111111111111(1111111[II 'F02088AEBA-0-CET-8.000.0315LE-Z-5-0"FAKE A ORIGINAL Applicable Law If you do not pay the full amount of an installment when it is due, and we intend to foreclose on the Mortgage,we must comply with the provisions of Section 403 and 404 of the Act of January 30, 1974, which is known as Act No. 6, and the provisions of the Homeowner's Emergency Mortgage Assistance Act(Act No. 91 of 1983). If this loan is a first mortgage, it is a federally related loan made at an agreed rate authorized by Section 501(a), Part A, Title V, Public Law 96-221, also known as Section 1735f--7(a), Title 12, United States Code. If any provision of this agreement is finally determined to be void or unenforceable under any law, rule, or regulation, all other provisions of this agreement will remain valid and enforceable. Our failure to enforce any provision(s)to this agreement shall not be deemed to constitute a waiver of such term(s). In order for any amendment to this agreement to be valid,it must be agreed to by you and us. You acknowledge that before signing this agreement,you have read and received this agreement which includes the Federal Truth-in-Lending disclosure and,as applicable, any other riders and/or disclosures incorporated herein by reference. By signing below,you agree to observe the terms and conditions of this agreement. ANY ADVANCE OF FUNDS PURSUANT TO THIS LOAN AGREEMENT AND THE MORTGAGE WHICH SECURES THE AGREEMENT MAY, IN THE EVENT OF ANY DEFAULT,RESULT IN THE LOSS OF YOUR HOME OR OTHER REAL PROPERTY PLEDGED AS SECURITY FOR YOUR LOAN. Borrower. MICHAEL S. F E Date; Borrower; SUSAN G. FAKE Date:—2-- 2-0 -p Witness: 09/20/2006 13:00 Page 6 of 6 111111 111111 II�II�I[I�IIIIIIalilflltllt(IIII�I 'F02089AE9A-90-CET-8-000-0315LE-Z-0-0'•FAKE^ORIGINAL -runty of CUMBERLAND q a-bert P Ziegler,Recorder,dohffft••• • for _ ert4 that the foregoing is a#Wand 1 In ness tness my This instrument was prepared by: r �d 2.. !;iEMM D Rl1TlC)N eo er of Deed 25 r", 8uft 107 X t r. F� OF DEEDS 'F�?( AIIO Mu T'f-f . Return To: Records Processing Services M SEP 25 Ptd 1.2 23 577 Lamont Road `1\ Elmhurst,IL 60126 `� (800) 547-8776 lmmw� UPI# ago MORTG AGE! F7 IF BOX IS CHECKED, THIS MORTGAGE IS AN OPEN-END MORTGAGE AND SECURES FUTURE ADVANCES. THIS MORTGAGE is made this day 20TH of SEPTEII ER 2006 , between the Mortgagor,M I CHAEL S. FAKE AND SUSAN 0. FAKE, RJSBAM AND WIF� (herein 'Borrower") and Mortgagee a corporation organized and existing under the laws of PENNSYLVANIA whose ad is 25 GATEWAY DRIVE, GATEWAY SQUARE/SUITE 107, A 17056 errnnn er . The following paragraph preceded by a checked box is applicable. x I WHEREAS, Borrower is indebted to Lender in the principal sum of$ 1Q.91$ 04 evidenced by Borrower's Loan Repayment and Security Agreement or Secondary Mortgage Loan Agreement dated SEPIEMBE13 20 = and any extensions or renewals thereof (herein "Note"),providing for monthly insWiments of princlpai and interest, including any adjustments to the amount of payments or the contract rate if that rate is variable, with the balance of the indebtedness, if not sooner paid,due and payable on SEP.TF1eER 20. 2Q16 ; WHEREAS, Borrower is indebted to Lender in the principal sum of$ or so much thereof as may be advanced pursuant to Borrower's Revolving Loan Agreementdated and extensions and renewals thereof (herein "Note"), providing for monthly installments, and interest at the rate and under the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a credit limit stated in the principal sum above and an initial advance of$ ; TO SECURE to Lender the repayment of (l) the indebtedness evidenced by the Note, with interest thereon, including any increases if the contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the payment of all other sums, with interest thereon, advanced in accordance herewith to protect the security of this Mortgage; and (4) the performance of the covenants and agreements of Borrower herein contained, Borrower does hereby mortgage, grant and convey to Lender and Lender's successors and assigns the following described property located in the County of CLU ERLAND Commonwealth of Pennsylvania: SEE EXHIBIT A—LEGAL DESCRIPTION MF62089AE9A9WT08000PA0013010MUFAKE " ORIGIWIL 11-11-05 MTG PAGO1301 BK 1967PGO 147 JE:SE] 11/1512012 11:30:38 AM InstA 200534999-Paye 1 of 10 -2- TOGETHER with all the improvements now or hereafter erected on the property, and all casements, rights,appurtenances and rents, all of which shall be doomed to be and remain a part of the property covered by this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if.this Mortgage isbn a leasehold)are hereinafter referred to as the"Property." Borrower covenants that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property, and that the property is unencumbered, except for encumbrances of record.Borrower covenants that Borrower warrants and will defend generally the title to the Property against all claims and demands,subject to encumbrances of record. 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(including any variations in interest resulting from changes in the Contract Rate that may be specified in the Note)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 chock, treasurer's chock or cashier's check, provided any such chock is drawn upon an institution whose deposits are insured by a federal agency,instrumentality,or entity;or(d)Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 12. Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted.If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower.If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds.Except as otherwise described in this Section 2 or as may be required by the Note and/or applicable law,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 11-11-05 MTG !! PA001302 ■F62089AE9A96MTG8000PA0013020""FAKE " ORIGIML BK 196 7P60148 11/15/2012 11:30:38 AM CUMBERLAND COUNTY Inst.#200634999-Page 2 of 10 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. Volunatary 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 Peridic 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; (e) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any. 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 7. 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 7 and pay such amount and Borrower shall then be obligated under Section 7 to repay to Leader 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 12 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 the Real Estate Settlement Procedures Act(12 U.S.C.Section 2601 et seq,)and its implementing regulation,Regulation X(24 C.F.R.Part 35000,as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this security instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan"even if the loan does not qualify as a"federally related mortgage loan" under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) 11-11-05 MTG {{ PA001303 1� *F62089AE9A9611TG8000PA0013030w"FAKE " ORIGIUAL 9X 1967PGO 149 11/15/2012 11:30:38 AM CUMBERLAND COUNTY Inst.#200634999-Page 3 of 10 -4- or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Funds,Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge,an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shalt 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. Prior Mortgages and Deed of Trust; Charges; Liens. Borrower shall perform all of Borrower's obligations under any mortgage,deed of trust or other security agreement with a lien which has priority over this Mortgage,including Borrower's covenants to make payments when due.Borrower shall pay or cause to be paid all taxes, assessments and other charges,fines and impositions attributable to the Property which may attain a priority over this Mortgage, and leasehold payments or ground rents,if any. 5. Hazard 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 such other hazards as Lender may require. The insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender; provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Lender and shall include a standard mortgage clause in favor of and in a form acceptable to Lender.Lender shall have the right to hold the policies and renewals thereof,subject to the terms of any mortgage,deed of trust or other security agreement with a lien which has priority over this Mortgage. 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. If the Property is abandoned by Borrower,or if Borrower fails to respond to Lender within 30 days from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender is authorized to collect and apply the insurance proceeds at Lender's option either to restoration or repair of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit impairment or deterioration of the Property and shall comply with the provisions of any lease if this Mortgage is on a leasehold.If this Mortgage is on a unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or 11-11-05 MTG PA001304 "F62089AE9AgWTGa000PA0013040M"FAKE R ORIGINAL ON 1967PGO 150 11/15/2012 11:30:38 AM CUMBERLAND COUNTY Inst.#200634999-Page 4 of 10 -S- governing the condominium or planned unit development, the by-laws and regulations of the condominium or planned unit development,and constituent documents. 7. Protection of Lender's Security. If Borrower fails to perform the covenants and agreements contained in this Mortgage,or if any action or proceeding is commenced which materially affects Lender's interest in the Property, then Lender, at Lender's option, upon notice to Borrower, may make such appearances,disburse such sums,including reasonable attorneys'fees,and takesuch action as is necessary to protect Lender's interest. Any amounts disbursed by Lender pursuant to this paragraph 7,with interest thereon,at the contract rate,shall become additional indebtedness of Borrower secured by this Mortgage. Unless Borrower and Lender agree to other terms of payment, such amounts shall be payable upon notice from Lender to Borrower requesting payment thereof.Nothing contained in this paragraph 7 shall require Lender to incur any expense or take any action hereunder. 8. Inspection.Lender may take or cause to be made reasonable entries upon and inspections of the Property, provided that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor related to Lender's interest in the Property. 9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property,or part thereof,or for conveyance in lieu of condemnation,are hereby assigned and shall be paid to Lender,subject to the terms of any mortgage. deed of trustor other security agreement with alien which has priority over this Mortgage. 10. 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 Mortgage granted by Lender to any successor in interest of Borrower shall not operate to release,in any manner,the liability of the original Borrower and Borrower's successors in interest.Lender shall not be required to commence proceedings against such successor or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's successors in interest.Any forbearance by Lender in exercising any right or remedy hereunder,or otherwise afforded by applicable law,shall not be a waiverof or preclude the exercise of any such right or remedy. 11.Successors and Assigns Bound;Joint and Several Liability;Co-signers.The covenants and agreements herein contained shall bind,and the rights hereunder shall inure to,the respective successors and assigns of Lender and Borrower,subject to the provisions of paragraph 16 hereof.All covenants and agreements of Borrower shall be joint and several.Any Borrower who co-signs this Mortgage,but does not execute the Note, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms of this Mortgage,(b)is not personally liable on the Note or under this Mortgage,and(c)agrees that Lender and any other Borrower hereunder may agree to extend, modify,forbear,or make any other accommodations with regard to the terms of this Mortgage or the Note without that Borrower's consent and without releasi ng that Borrower or modifying this Mortgage as to that Borrower's interest i n the Property. 12.Notice.Except for any notice required under applicable law to be given in another manner,(a)any notice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Borrower may designate by notice to Lender as provided herein,and(b)any notice to Lender shall be given by certified mail to Lender's address stated herein or to such other address as Lender may designate by notice to Borrower as provided herein.Any notice provided for in this Mortgage shall be deemed to have been given to Borrower or Lender when given in the manner designated herein. 13.Governing Law;Severability.The applicable law contained in the Note shall control.Where no applicable law is contained therein,the state and local laws applicable to this Mortgage shall be the laws of the jurisdictio pplicability 11-11-05 MT(; am- PA001305 "F62089AE9A9WTGS000PA00130SOMKFAKE " ORIGIML BK 1967PGO 1 51 11/15/2012 11:30:38 AM CUMBERLAND COUNTY Inst.#200634999-Page 5 of 10 of Federal law to this Mortgage. In the event that any provision or clause of this Mortgage or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting provision, and to this end the provisions of this Mortgage and the Note are declared to be severable. As used herein, "costs," "expenses" and "attorneys' foes" include all sums to the extent not prohibited by applicable law or limited herein. 14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgage at the time of execution or after recordation hereof. 15.Rehabilitation Loan Agreement.Borrower shall fulfill all of Borrower's obligations under any home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with Lender. Lender, at Lender's option, may require Borrower to execute and deliver to Lender, in a form acceptable to Lender,an assignment of any rights,claims or defenses which Borrower may have against parties who supply labor,materialsor services in connection with improvements made to the Property. 16. Transfer of the Property. If Borrower sells or transfers all or any part of the Property or an interest therein, excluding (a) the creation of a lien or encumbrance subordinate to this Mortgage, (b) a transfer by devise, descent, or by operation of law upon the death of a joint tenant, (c) the grant of any leasehold interest of three years or less not containing an option to purchase, (d) the creation of a purchase money security interest for household appliances, (e) a transfer to a relative resulting from the death of a Borrower, (f) a transfer where the spouse or children of the Borrower become an owner of the property, (g) a transfer resulting from a decree of dissolution of marriage, legal separation agreement, or from an incidental property settlement agreement, by which the spouse of the Borrower becomes an owner of the property, (h) a transfer into an inter vivos trust in which the Borrower is and remains a beneficiary and which does not relate to a transfer of rights of occupancy in the property, or (i) any other transfer or disposition described in regulations prescribed by the Federal Home Loan Bank Board, Borrower shall cause to be submitted information required by Lender to evaluate the transferee as if a new loan were being made to the transferee. Borrower will continue to be obligated under the Note and this Mortgage unless Lender releases Borrower in writing. If Lender does not agree to such We or transfer, Lender may declare all of the sums secured by this Mortgage to be immediately due and payable. If Lender exercises such option to accelerate,Lender shall mail Borrower notice of acceleration in accordance with paragraph 12 hereof. Such notice shall provide a period of not less than 30 days from the date the notice is mailed or delivered within which Borrower may pay the sums declared due. If Borrower fails to pay such sums prior to the expiration of such period, Lender may, without further notice or demand on Borrower, invoke any remedies permitted by paragraph 17 hereof. NON-UNIFORM COVENANTS.Borrower and Lender further covenant and agree as follows: 17. Acceleration; Remedies. Except as provided in paragraph 16 hereof, upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums secured by this Mortgage, Lender prior to acceleration shall give notice to Borrower as provided in paragraph 12 hereof specifying: (1) the breach; (2) the action required to cure such breach; (3)a date, not less than 30 days from the date the notice is mailed to Borrower, by which such breach must be cured; and (4) that failure to cure such breach on or before the date specified in the notice may result in acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property. The 11-11-06 WG IPA001306 MF62089AE9A96MYG8000PA0013060k"FAKE * ORIGINAL $K1967PGO152 11/1512012 11:30:38 AM CUMBERLAND COUNTY Inst.#200634999-Page 6 of 1( -7- notice shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in the notice, Lender, at Lender's option, may declare all of the sums secured by this Mortgage to be immediately due and payable without further demand and may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect in such proceeding all expenses of foreclosure, including, but not limited to, reasonable attorneys' fees and costs of documentary evidence, abstracts and title reports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums by this Mortgage due to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage discontinued at any time prior to entry of a judgment enforcing this Mortgage if: (a) Borrower pays Lender all sums which would be then due under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures all breaches of any other covenants or agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing the covenants and agreements of Borrower contained in this Mortgage, and in enforcing Lender's remedies as provided in paragraph 17 hereof, including, but not limited to, reasonable attorneys' fees; and (d) Borrower takes such action as Lender may reasonably require to assure that the lien of this Mortgage, Lender's interest in the Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired. Upon such payment and cure by Borrower, this Mortgage and the obligations secured hereby shall remain in full force and effect as if no acceleration had occurred. 19. Assignment of Rents; Appointment of Re:ceii%r. As additional security hereunder, Borrower hereby assigns to Lender the rents of the Property, provided that Borrower shall, prior to acceleration under paragraph 17 hereof, in abandonment of the Property, have the right to collect and retain such rents as they become due and payable. Upon acceleration under paragraph 7 hereof or abandonment of the Property, Lender shall be entitled to have a receiver appointed by a court to enter upon, take possession of and manage the Property and to collect the rents of the Property including those past due. All rents collected by the receiver shall be applied first to payment of the ooets of management of the Property and collection of rents, including, but not limited to, receiver's fees, premiums on receiver's bonds and reasonable attorneys' fees, and then to the sums secured by this Mortgage. The receiver shall be liable to account only for those rents actually received. 20. Release. Upon payment of all sums secured by this Mortgage. Lender shall release this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right of homestead exemption in the Property under state or Federal law. 22. Interest Rate After Judgment. Borrower agrees the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note. 23. Arbitration Rider to Note. The Arbitration Rider attached to and made a part of the Note is hereby incorporated by reference and made a part of this Mortgage. 11-11-05 MTG PA001301 ■F62099AE9A9WTGB000PA0013070""FAKE " ORIGINAL 8K 1 967PGO 153 11/15/2012 11:30:38 AM CUMBERLAND COUNTY Inst.#200834999-Page 7 of 10 -S- REQUEST FOR NOTICE OF DEFAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth on page one of this Mortgage, of any default under the superior encumbrance and of le or other foreclosure action. VIL Michael S Fake{ rr�o/w�er Susan G Fake Borrower I hereby certify that the precise address of the Lender(Mortgagee)is: 25 Gateway Drive Gateway Square/Suite 107 Mectanicaburg. PA 17055 On behalf of the Lender.By: Ran D Russell Title: Branch Manager COMMONWEALTH OF PENNSYLVANIA, Cumberland County ss: I. Lisa A Seay a Notary Public in and for said county and state, do hereby certify that M1chaq,3, personally known to me or proven satisfactorily to be the same persons whose name(s) subscribed to the foregoing instrument, appeared before me this day in person, and acknowlt1gCe that they signed and delivered the said instrument as their free voluntary act7or the uses and purposes therein"9et forth. Given under my hand and official seal, this 20th day of September J NOTARIAL SEAL . ei ! p USA A SEAM 0 on expires. Nom,P<t�c, cm of HARRODURG,DAUP w COUNTY blic ALTH OF PENNSYLVANIA, County ss: lie ;�. a Notary Public in and for said county and state, do hereby a known to me or proven satigfactoRly to be the same persons whose name(s) su robed to the foregoing instrument, appeared before me this day in person, and acknow geese tl at he signed and delivered the said instrument as free voluntary actor the uses and purposes therein set forth. Given under my hand and official seal, this day of , 20 My Commission expires: Notary Public 11-11-05 MT6 PAG01308 MF62089AE9A9WTG8000PA00130809*FAKE ■ ORIGINAL 8K 1967PGO 154 11/15/2012 11:30:38 AM CUMBERLAND COUNTY Inst.#200634999-Page 8 of 10 -9- (Space Below This Line Reserved Por Lender and Recorder) 11-11-05 WG PA001309 "F62089AE9A9WTG8000PA0013090""FAKE " ORIGINAL BK 1967PGO 155 11/15/2012 11:30:38 AM CUMBERLAND COUNTY Insl.#200634999-Page 9 of 10 EXHIBIT A (PAGE 1) ALL THAT CERTAIN PROPERTY SITUATED IN THEBOROUGH OF WORMLEYSSURG IN THE COUNTY OF CUMBERLAND AND CMUWALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A DEED DATED 06/28/1991 AND RECORDED 07/02/1991, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME 35—E AND PAGE 907, TAX MAP OR PARCEL ID NO. : 47-18-1302-088 I Certify this tc; he re..cw,-d cd In Cun,locrla.nd i.w.n,Ly I-,A Y ` V r^ t I, c..1-,- r L... .. 1 s ism MF62089AE9A96YTGH000PA0013000""FAKE w ORIGINAL 8KI967PGO156 11115/2012 11:30:38 AM CUMBERLAND COUNTY Insl.#200634999-Page 10 of 10 All that certain lot situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, on the Plan of Lots of Riverview, as recorded in the Recorder's Office in and for Cumberland County, Pennsylvania, in Plan Book No. 11, Page 9, and being subject to utility easements and building and use conditions and restrictions of record, and more particularly bounded and described as follows, to wit: Being Lot No. 33, Section "D": Beginning at a point where the division line between Lots thirty-three (33)and thirty-four(34) intersects with the curving northwesterly side of Old Orchard Lane; thence north thirteen degrees forty-nine minutes eight seconds west (North 13 degrees 49' 8" W) along the division line between Lots thirty-three (33) and thirty-four (34) a distance of one hundred seventy-five and four one-hundredths (175.04) feet to a point; thence north sixty-two degrees fifty-three minutes east (N 62 degrees 53' E) along the division line between Lots thirty-three (33) and fifty-six (56), a distance of forty (40) feet to a point; thence south twenty-seven degrees of forty (40) feet to a point; thence south twenty- seven degrees seven minutes east (S 27 degrees 7' E) a distance of one hundred ninety (190) feet to a point; thence in a southwesterly direction, along the curving northwesterly side of Old Orchard Lane in an arc created by two hundred fifty-six and two tenths (256.2) feet radius, a distance of eighty-three (83)feet to a point, the place of beginning. Having thereon erected a two (2) story brick and frame dwelling known and numbered as 511 Old Orchard Lane. Fee Simple Title Vested in Michael S. Fake and Susan G. Fake,his wife by deed from Ronald H. Conrad and Kathryn S. Conrad, his wife, dated June 28, 1991,recorded July 2, 1991, in the Cumberland County Recorder of Deeds Office in Deed Book E 35,Page 907. fitEX BIT HOUSEHOLD FIN CONSUMER DISCOUNT CO P.O.Box 1231 Brandon,FL 33509-1231 7190 0005 4730 1055 5659 000085 3.78 MICHAEL S FAKE 511 OLD ORCHARD LN CAMP HILL, PA 17011-1829 XHIBIT HSBC /D HOUSEHOLD FIN CONSUMER DISCOUNT CO P.O.Box 31 F n Beneficial® C"rCl Brandon,FL 33509-1231 \i Member HSBC 4D C»un SENT BY CERTIFIED MAIL AND REGULAR MAIL Our hours of operation are Monday through Friday 8 am-10 pm ET. 000085 3.78 MICHAEL S FAKE 511 OLD ORCHARD LN CAMP HILL, PA 17011-1829 Re: 511 OLD ORCHARD LN 04/08/14 CAMP HILL, PA 17011-1829 Account#: NOTICE OF INTENTION TO FORECLOSE MORTGAGE The Mortgage held by HOUSEHOLD FIN CONSUMER DISCOUNT CO on your property located at 511 OLD ORCHARD LN CAMP HILL, PA 17011-1829 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $2325.78 for the months of 10/25/2009 through 04/08/14. Late charges and other charges have also accrued to this date in the amount of $8,656.86. The total amount now required to cure this default as of the date of this letter is $132,706.25. You may cure this default within THIRTY(30) DAYS from the date of this letter, by paying to us the above amount of$132,706.25 plus any additional monthly payment and late charges which may fall due during this period. Please remit such payment in the form of cash, cashier's check, certified check, or money order made payable to: HOUSEHOLD FIN CONSUMER DISCOUNT CO PO Box 5233 Carol Stream, IL 60197-5233 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means the balance due and owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the default amount is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to initiate legal proceedings to foreclose on your mortgaged property. If we foreclose on the mort agge your in, property will be sold by the Sheriff(or other similar official) to pay o, e mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney fees, actually incurred, up to $50.00. However, if we initiate legal proceedings against you, you will still have to pay the reasonable attorney fees even if they are over $50.00. Any attorney fees will be added to the balance due and owing; this may also include our reasonable costs. If you cure the default within the THIRTY(30) DAY period, you will not be required to pay the attorney fees. We, as lender, may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs (or other similar official)foreclosure sale. You inoy do so by paying the total amount of the unpaid monthly payments plus any late fees or other charges then due, as well as the reasonable attorney fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date a Sheriffs (or other similar official) sale could be held would be approximately four to six months from the date of this letter. A notice of the date of the Sheriffs (or similar official) sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. Please contact us at 1-877-601-7019 to receive the required payment amount. This payment must be cash, cashier's check, certified check, or money order and made payable to us at the address stated above. You should realize that a Sheriff's (or other similar official) sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's (or other similar official) sale, a lawsuit could be initiated to evict you. In the foreclosure proceedings, you shall have the right to assert the nonexistence of a default or any other defense that you may have to acceleration or foreclosure. You have additional rights to help protect your interest in the property. YOU 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. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY, SUBJECT TO THE MORTGAGE, TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES, AND ATTORNEY FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND OTHER REQUIREMENTS UNDER THE SALE ARE SATISFIED. PLEASE CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, HOUSEHOLD FIN CONSUMER DISCOUNT CO DMDPA6 Please Note: This notice is also given to you as a demand for payment pursuant to the terms of your mortgage obligation. However, under Pennsylvania law also known as Act 6, your particular loan may not be covered by the protections outlined above, based on the original loan amount. For the calendar year 2014, you are entitled to Act 6 protection if your original loan amount was $237,474 or less. HOUSEHOLD FIN CONSUMER DISCOUNT CO P.O.Box 1231 Brandon,FL 33509-1231 7190 0005 4730 1055 5666 000086 3.78 SUSAN G FAKE 511 OLD ORCHARD LN CAMP HILL, PA 17011-1829 HSBC /D HOUSEHOLD FIN CONSUMER DISCOUNT CO Beneficial® P.O.Box 1231 Brandon,FL 33509-1231 Member HSBC 4D Croup JI—L r IiSBC 6),Grout SENT BY CERTIFIED MAIL AND REGULAR MAIL Our hours of operation are Monday through Friday 8 am-10 pm ET. 000086 3.78 SUSAN G FAKE 511 OLD ORCHARD LN CAMP HILL, PA 17011-1829 Re: 511 OLD ORCHARD LN 04/08/14 CAMP HILL, PA 17011-1829 Account#: NOTICE OF INTENTION TO FORECLOSE MORTGAGE The Mortgage held by HOUSEHOLD FIN CONSUMER DISCOUNT CO on your property located at 511 OLD ORCHARD LN CAMP HILL, PA 17011-1829 IS IN SERIOUS DEFAULT because you have not made the monthly payments of$2325.78 for the months of 10/25/2009 through 04/08/14. Late charges and other charges have also accrued to this date in the amount of $8,656.86. The total amount now required to cure this default as of the date of this letter is $132,706.25. You may cure this default. within THIRTY(30) DAYS from the date of this letter, by paying to us the above amount of$132,706.25 plus any additional monthly payment and late charges which may fall due during this period. Please remit such payment in the form of cash, cashier's check, certified check, or money order made payable to: HOUSEHOLD FIN CONSUMER DISCOUNT CO PO Box 5233 Carol Stream, IL 60197-5233 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means the balance due and owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the default amount is not made within THIRTY (30) DAYS, we also intend to instruct, our attorneys to initiate legal proceedings to foreclose on your mortgaged property. If we foreclose on the mortgage, your mortgaged property will be sold by the Sheriff(or other similar official) to pay of he mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney fees, actually incurred, up to $50.00. However, if we initiate legal proceedings against you, you will still have to pay the reasonable attorney fees even if they are over $50.00. Any attorney fees will be added to the balance due and owing; this may also include our reasonable costs. If you cure the default within the THIRTY(30) DAY period, you will not be required to pay the attorney,fees. We, as lender, may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs (or other similar of foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late fees or other charges then due, as well as the reasonable attorney*fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date a Sheriffs (or other similar official) sale could be held would be approximately four to six months from the date of this letter. A notice of the date of the Sheriff's (or similar official) sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. Please contact us at 1-877-601-7019 to receive the required payment amount. This payment must be cash, cashier's check, certified check, or money order and made payable to us at the address stated above. You should realize that a Sheriffs (or other similar official) sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's (or other similar official) sale, a lawsuit could be initiated to evict you. In the foreclosure proceedings, you shall have the right to assert the nonexistence of a default or any other defense that you may have to acceleration or foreclosure. You have additional rights to help protect your interest in the property. YOU 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. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY, SUBJECT TO THE MORTGAGE, TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES, AND ATTORNEY FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND OTHER REQUIREMENTS UNDER THE SALE ARE SATISFIED. PLEASE CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default,, the mortgage will be restored as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, HOUSEHOLD FIN CONSUMER DISCOUNT CO DMDPA6 Please Note: This notice is also given to you as a demand for payment pursuant to the terms of your mortgage obligation. However, under Pennsylvania law also known as Act 6, your particular loan may not be covered by the protections outlined above, based on the original loan amount. For the calendar year 2014, you are entitled to Act 6 protection if your original loan amount was $237,474 or less. Household Finance Consumer Discount Company IN THE COURT OF COMMON Plaintiff PLEAS OF CUMBERLAND � Y COUNTY,PENNSYLVANIAN a Michael S. Fake and Susan G. Fake Defendant(s) COMPLAINT IN cP MORTGAGE FORECLOSURE Q , Z__ y �? Jq— evil 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 th is 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(7l 7)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty (20)days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative.However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conci liation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY TIDS NOTICE.TIDS PROGRAM IS FREE. Respectfully submitted: Date: [Signature of Counsel for Plaintiff) PA Complaint 1-A(CML Owner) 11 Dec 12Ver3.0 Household Finance Consumer Discount Company IN THE COURT OF COMMON Plaintiff PLEAS OF CUMBERLAND V. COUNTY,PENNSYLVANIA Michael S. Fake and Susan G. Fake Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification. to authorities. Signature of Defendant's Counsel/Appointed Date: Legal Representative Signature of Defendant Date: Signature of Defendant Date: PA Complaint I-A(CML Owner) 11 Dec12Ver3.0 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARYAPPLICANT Borrower name(s): Property Address: City: _-- -_ State: Zip: Is the property for sake? Yes❑ No r] Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes[1 No � Mailing Address(if different): City: State: Zip: Phone Numbers: Dome: Office: Cell: Other: Email: #of people in household: How long? Mailing Address: City: State: Zip:, Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: Hoy!long? INFORMATIONFINANCIAL First Mortgage bender: Type of Loan: Loan Number: 'Date You Closed Your Doan: Second Mortgage Fender: Type of Loan: T.nan Nnmht�r- If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Value: Home. $ $ I Other Real Estate: $ $ Retirement Funds: S $ Investments: $ Checking: $ S Savings: S S Other: $ - $ Automobile#1:Model: Year: Amount owed: Value: Automobile 42:Model: Year: Amount owed: Value: Other transportation automobiles boats,matorevcles : Model: Year: Amount owed: Value Monthly Income Name of Employers: l. 2. 3, Additional Income Description(not wages): I• monthly amount: 2, monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses:(Please only include expenses you are currently paying) I EXPENSE AMOUNT EXPENSE AMOUNT Mort a e Food Z" Mort a e Utilities Car Pa ment s Condo/Nei h.Fees Auto Insurance Med. not covert � Auto fuel/re-airs Other ro . a menu Install.Loan Payment Cable TV Child Su ort/Alim. _§pendmg_SpendingMone Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments'Based on Income&Expenses: i Have you been working with a Housing Counseling Agency? Yes[] No 1f yes,please provide the following information,- Counseling nformation:Counseling Agency: Counselor: Phone(Office): Fax: i Dec I2vers.o 2 Email: Have you made application for flonicoAmers Emergency Mortgage Assistance Program (HEMAP)assistance? Yes F1 Non If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes F] No[] If yes,please indicate the status of those negotiations: Please provide the following information,if know,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION Me, authorize the above named to use/refer this information to in),lender/servicer for the sole purpose of evaluating myfinancial situation for possible mortgage options. We understand that Mve am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement(it property is currently on the market) I I Dec I 2Ver3.0 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND �~������� ~�~�.w"�°~~u����.��� COUNTY . TriE PROTHONO|,sr(/ 2Ri[i0°T —\ PM 9: 31 CE OF r R ��D0GH�[Y ���*��� ���� ~`'- Household Finance Consumer Discount Company vs. Michael S Fake (et al.) Case Number 2014-5570 SHERIFF'S RETURN OF SERVICE 09/23/2014 07:56 PM - Deputy Shawn Gutshall, being dulyowomaccordingtokaw, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Ashley Fake, Daughter 21years old, who accepted as 'Adult Person in Charge" for Michael S Fake at 511 Old Orchard Lane, Wormleysburg Borough, Camp Hill, PA 17011. .m��m^� �m���^ GUTSHALL, DE ~.. 09/23/2014 07:56 PM - DepShawn Gutshallbeing duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Ashley Fake, Daughter 21years old, who accepted as "Adult Person in Charge" for Susan G Fake at 511 Old Orchard Lane, Wormleysburg Borough, Camp Hill, PA 17011. SHERIFF COST: $61.44 SO ANSWERS, September 24, 2014 (c) CountySuite Sheriff, Teleosaft. RONNYRANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Household Finance Consumer Discount Company VS. Plaintiff Michael S. Fake and Susan G. Fake Defendant Address: 511 Old Orchard Lane Camp Hill, PA 17011 TO THE PROTHONOTARY OF THE SAID COURT: ❑ Confessed Judgment ❑ Other File No. 2014-5570 Civil Amount Due 215,429.54 Interest 12/10/14-06/03/15 Atty's Comm @ $35.50 per diem =$6,248.00- - Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) See full legal description attached PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) 511 Old Orchard Lane, Camp Hill, PA 17011 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ❑ (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date_ —10-/14 cukx-1- ,§.(94k36 pc). a Cel. yy 10.5/1 Pia Signature: Print Name: Address: Attorney for: Telephone: illiam E. Miller, Esq. 1581 Main St., Ste 200 Warrington, PA 18976 Plaintiff 215-572-8111 Supreme Court ID No: 308951 CV. No51 ALL THAT CERTAIN lot situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, on the Plan of Lots of Riverview, as recorded in the Recorder's Office in and for Cumberland County, Pennsylvania, in Plan Book No. 11, Page 9, and being subject to utility easements and building and use conditions and restrictions of record, and more particularly bounded and described as follows, to wit: BEING Lot No. 33, Section "D": Beginning at a point where the division line between Lots thirty-three (33) and thirty-four (34) intersects with the curving northwesterly side of Old Orchard Lane; thence north thirteen degrees forty-nine minutes eight seconds west (North 13 degrees 49' 8" W) along the division line between Lots thirty-three (33) and thirty-four (34) a distance of one hundred seventy-five and four one -hundredths (175.04) feet to a point; thence north sixty-two degrees fifty-three minutes east (N 62 degrees 53' E) along the division line between Lots thirty-three (33) and fifty-six (56), a distance of forty (40) feet to a point; thence south twenty-seven degrees of forty (40) feet to a point; thence south twenty-seven degrees seven minutes east (S 27 degrees 7' E) a distance of one hundred ninety (190) feet to a point; thence in a southwesterly direction, along the curving northwesterly side of Old Orchard Lane in an arc created by two hundred fifty-six and two tenths (256.2) feet radius, a distance of eighty-three (83) feet to a point, the place of beginning. HAVING thereon erected a two (2) story brick and frame dwelling known and numbered as 511 Old Orchard Lane. BEING Cumberland County Parcel No.47-18-1302-088 KNOWN AS 511 Old Orchard Lane, Camp Hill, PA 17011 FEE SIMPLE TITLE Vested in Michael S. Fake and Susan G. Fake, his wife by deed from Ronald H. Conard and Kathryn S. Conard, his wife, dated June 28, 1991, recorded July 2, 1991, in the Cumberland County Recorder of Deeds Office in Deed Book E 35, Page 907. STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action: 2014-5570 Civil MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 511 Old Orchard Lane, Camp Hill, PA 17011. 1. Name and address of Owner(s) or Reputed Owner(s): Michael S. Fake and Susan G. Fake 511 Old Orchard Lane Camp Hill, PA 17011-1829 2. Name and address of Defendant(s) in the judgment: Michael S. Fake and Susan G. Fake 511 Old Orchard Lane Camp Hill, PA 17011-1829 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Tenant(s)/Occupant(s) 511 Old Orchard Lane Camp Hill, PA, 17011 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: v-Liq BY: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DIANE J. TLIRANO, Notary Public Warrington Twp., Bucks County My Commission Expires October 31, 2018 Sworrnd sub cribed before me this ' Day of , 2014 STERN & EISENBERG, PC STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ L SLIE J. RASE, ESQUIRE ■/ NDREW J. MARLEY, ESQUIRE WILLIAM E. MILLER, ESQUIRE Attorney for Plaintiff otary Public STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) r -. . IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action: 2014-5570 Civil MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michael S. Fake and Susan G. Fake 511 Old Orchard Lane Camp Hill, PA 17011-1829 Your real estate at 511 Old Orchard Lane, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, June 3, 2015 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $215,429.54 obtained by Household against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Stern & Eisenberg, PC the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern & Eisenberg PC, telephone (215) 572-8111. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern & Eisenberg PC, telephone (215) 572-8111. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call Stern & Eisenberg PC, telephone (215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW 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 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action: 2014-5570 Civil MORTGAGE FORECLOSURE RE: PREMISES: 511 Old Orchard Lane, Camp Hill, PA 17011 Dear Sir or Madam: Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, June 3, 2015 at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice). The sale is being conducted pursuant to the judgment in the amount of $215,429.54 together with interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff' s Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. BY: ST RN & E, ENBERG, PC STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LE LIE J. RASE, ESQUIRE ❑ DREW J. MARLEY, ESQUIRE WILLIAM E. MILLER, ESQUIRE Attorney for Plaintiff THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Vs. NO 2014-5570 Civil Term CIVIL ACTION — LAW MICHAEL S. FAKE AND SUSAN G. FAKE WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $215,429.54 L.L.: $.50 Interest 12/10/14-06/03/15 @ $35.50 PER DIEM = $6,248.00 Atty's Comm: Atty Paid: $222.19 Plaintiff Paid: Date: 12/12/14 Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: WILLIAM E. MILLER, ESQUIRE Address: STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PA 18976 Attorney for: PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No. 308951 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action Number: 2014-5570 Civil MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Michael S. Fake and Susan G. Fake, for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE $142,397.07 INTEREST accrued thru 09/03/2014 of $66,388.48 Interest after 09/03/2014 shall accrue at the per diem rate of $35.50.) ADVANCES FOR TAXES $4,743.22 LESS SUSPENSE (If any) ($1,542.73) Sub -Total Through Date of Complaint $211,986.04 ACCRUED INTEREST after 09/03/2014 shall accrue at the per diem rate of $35.50 to December 9, 2014 $3,443.50 TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT $215,429.54 BY: S E & ISENBERG, PC ❑ STEVEN K. EISENBERG, ESQUIRE O M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LE LIE J. RASE, ESQUIRE ( ❑ DREW J. MARLEY, ESQUIRE Q Iv• ) kms`-' 1 WILLIAM E. MILLER, ESQUIRE 1t' �Tty Attorney for Plaintiff l `l VS 12.-314914 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action: 2014-5570 Civil MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants': 1. Last -known address is: 511 Old Orchard Lane, Camp Hill, PA 17011-1829 2. Is over the age of twenty-one. SS 3. Is not now nor has been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers' Civil Relief Act of 1940,.as amended. GOMMO BY: p {� OF . . NO-Ti41Public DIANE 3.11)11010, Notari County My Commss onx� tren Twp„ yuda October 31, 2018 N y�rn11A Swo d subscribed before me this ilbay of + , 2014 otary Public & EISENBERG, PC ❑ STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ L LIE J. RASE, ESQUIRE ❑ NDREW J. MARLEY, ESQUIRE WILLIAM E. MILLER, ESQUIRE Attorney for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicernenthers Civil Relief Act. Last Name: FAKE First Name: MICHAEL Middle Name: Active Duty Status As Of: Dec -09-2014 Results as of : Dec -09-2014 07:39:53 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA . No NA Ibis response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA I. -., .� NA ,! ��- " :. 1 , No'7- Y' i NA This response reflects Were the individual left active duty status within 367 days preceding the Active Duty Status Date 111'.� The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA r. NA \. ,. + t ' "No %" .1r NA This response reflects whether the individual or his/her unit has received early notification to iepod for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: X012PE77614AU70 Department of Defense Manpower Data Center Status Report Pursuant to Serwicetuern cars Civil Relief Ac Last Name: FAKE First Name: SUSAN Middle Name: Active Duty Status As Of: Dec -09-2014 Results as of : Dec -09-2014 07:40:27 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ." - - No ' NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA + - NA _ ... - No .. I. NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date 111 The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA v ' ..- 'No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c), This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: COM74E67N14AJ10 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action: 2014-5570 Civil MORTGAGE FORECLOSURE CERTIFICATION UNDER RULE 237.1 I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. No. 237.1., a true and correct copy of which is attached hereto. BY: STERN & EISENBERG, PC William E. Miller Attorney at Law STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Household Finance Consumer Discount Company (Plaintiff) v. Michael S. Fake and Susan G. Fake (Defendant(s) TO: Michael S. Fake 511 Old Orchard Ln Camp Hill, PA 17011-1829 Docket #: 2014-5570 Civil TEN DAY NOTICE NOTICE PURSUANT TO Pa.R.C.P. 237.1 Date of Notice: November 24, 2014 Susan G Fake 511 Old Orchard Ln Camp Hill, PA 17011-1829 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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: 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 Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 STERN & EISENBERG, PC By: Edward J. McKee, Esquire Attorney for Plaintiff STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action: 2014-5570 Civil MORTGAGE FORECLOSURE CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriffs Sale scheduled in the above -captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because borrowers more than 24 months in default. STEVEN ' . EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ L .LIE J. RASE, ESQUIRE ❑ A NDREW J. MARLEY, ESQUIRE i WILLIAM E. MILLER, ESQUIRE Attorney for Plaintiff STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Michael S. Fake and Susan G. Fake Defendant(s) Civil Action: 2014-5570 Civil MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Household Finance Consumer Discount Company 636 Grand Regency Blvd Brandon, FL 33510 (Plaintiff) Michael S. Fake and Susan G. Fake 511 Old Orchard Lane Camp Hill, PA 17011-1829 (Defendant(s)) BY: STERN & EISENBERG, PC ❑ STEVEN'S EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE O JACQUELINE F. McNALLY, ESQUIRE O LESLIE J. RASE, ESQUIRE ❑�CNDREW J. MARLEY, ESQUIRE WILLIAM E. MILLER, ESQUIRE Attorney for Plaintiff