HomeMy WebLinkAbout14-5595 Supreme Court of Pennsylvania
Court of Common Pleas
Civil Cover Sheet For Prothonotary Use Only:
Cumberland County Docket No:
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 0 Complaint El Writ of Summons ❑ Petition ❑ Notice of Appeal
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T Members 1 st Federal Credit Union Dean P. Kennedy,Jr. &Michelle Kennedy,a/k/a Michelle L. Kennedy
I ❑ Check here if you are a Self-Represented (Pro Se)Litigant
0 Name of Plaintiff/Appellant's Attorney: Kari M.Ledebohm,Esq.
N
Are money damages requested?: MYes ❑No Dollar Amount Requested: within arbitration limits
(Check one) N/A outside arbitration limits
A
Is this a Class Action Suit? ❑ Yes 0 No
Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim,check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections
❑ Nuisance ❑ Dept.of Transportation
❑ Premises Liability ❑ Zoning Board
S ❑ Product Liability(does not include ❑ Statutory Appeal:Other
Emass tort) Employment Dispute:
E] Slander/Libel/Defamation Discrimination
C El Other: ❑ Employment Dispute:Other
T+ Judicial Appeals
❑ MDJ-Landlord/Tenant
I ❑ Other: ❑ MDJ-Money Judgment
O MASS TORT ❑ Other:
❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort-DES
❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration
B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations
0 Mortgage Foreclosure Restraining Order
PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto
❑ Dental ❑ Quiet Title ❑ Replevin
❑ Legal
❑ Medical ❑ Other: ❑ Other:
❑ Other Professional:
PmR.C.P.205.5 212010
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FIL EID-GFFrCE
0, I•lE P O T HONG TAr�y
0 14 SEP 22 Ari I 1: S 7
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Karl M.Ledebohm,Esquire CUEIMBERLANO COUNTY
� 1''E N ld S Y LVAN I A
P.O.Box 173
New Cumberland,PA 1.7070-0173
(717)938-6929
MEMBERS 1 ST FEDERAL t IN THE COURT,OF.COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF . . ,
Vs. NO.: 14 -
DEAN
4 -DEAN P. KENNEDY;JR.'and -
MICHELLE,KENNEDY a/k/a''.
MICHELLE'L. KENNEDY, .r CIVIL ACrTION—` LAW
s DEFENDANTS' MORTGAGE FORECLOSURE
NOTICE'TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE-ISA DEBT;COLLECTOR AND WE ARE
ATTEMPTING'TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION'OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE,DEBT., #
YOU HAVE BEEN SUED IN'COURT. If you wish to defend against the claims
set forth in the following pages,you must take action witliiri twenty(20) days after this
Complaint and Notice are served by entering'a written appearance personally or by
attorney and filing in writing with the Court your defenses or objections to the claims set
f forth against you. You are warned that if you fail to do so,the case may proceed without
you and a judgment may be entered against you by the Court without further notice for
any money claimed in the Complaint or for any other claims or relief requested by the
Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
115.'15 Pb A` TY
�#aa5a/aac��
0311,3S7
t
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C.
SECTION 1692 et seq.(1977), DEFENDANT(S)MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE THE
VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30)
DAYS OF THE RECEIPT OF THIS NOTICE, COUNSEL FOR PLAINTIFF WILL
ASSUME THE DEBT TO BE VALID.
IF DEFENDANT(S)NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WITHIN
THIRTY(30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN
VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S) PROVIDE
COUNSEL FOR PLAINTIFF WITH A WRITTEN REQUEST WITHIN THIRTY (30)
DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND
DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF
DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY
(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING
YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT
YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT
TIME. FURTHERMORE,NO REQUEST WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY(30) DAYS AFTER YOU
HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF
THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR
WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT
OF THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS
(THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE
MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS
IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND/OR RECEIVED A DISCHARGE, THIS
IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A
LIEN ON REAL ESTATE.
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS IST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
DEAN P. KENNEDY, JR. and
MICHELLE KENNEDY A/K/A
MICHELLE L. KENNEDY
DEFENDANT(S) : CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
COMPLAINT
1
AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1. Plaintiff, Members 1St Federal Credit Union ("Members 1St"), is a National Federal
Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA
17055.
2. Defendant, Dean P. Kennedy,Jr. (hereinafter"Dean Kennedy"), is an adult
individual having a last known address of 38 South York Road,Dillsburg, PA
17019.
3. Defendant, Michelle Kennedy a/k/a Michelle L. Kennedy (hereinafter"Michelle
Kennedy"), is an adult individual having a last known address of 263 Carlisle
Avenue., Enola, PA 17025. Dean Kennedy and Michelle Kennedy are collectively
referred to herein as "Defendants."
4. On or about June 13, 2008, Defendants borrowed from and agreed to repay to
Members 1St $38,000.00 (the "Loan"). The Loan is evidenced by a Closed-End Note,
Disclosure, Loan and Security Agreement dated June 13, 2008 (the "Note") executed
and delivered to Members 1St by Defendants. A copy of the Note is attached hereto as
Exhibit "A" and made part hereof.
5. As security for the Loan, Defendants executed and delivered to Members 1St a
mortgage ("Mortgage") also dated June 13, 2008, on all that certain real estate and
2
improvements erected thereon situate in East Pennsboro Township, Cumberland
County, Pennsylvania known and numbered as 263 Carlisle Avenue, Enola, PA
17025 (the "Property"). At all times relevant hereto, Defendants have been and
continue to be the record and sole owners of the Property. A description of the
Property is attached hereto as Exhibit`B" and made part hereof.
6. On or about June 26, 2008, the Mortgage was recorded in the Cumberland County
Recorder of Deeds Office at Instrument No.: 200821619. A true and correct copy of
the Mortgage is attached hereto as Exhibit"C" and made part hereof.
7. The Note and the Mortgage have never been assigned by Members 1 st and remain
held by it as a valid and subsisting obligation of Defendants.
8. Defendants obligations under the Mortgage and the Note are in default for failure to
make the bi-weekly payments of principal and interest due to Plaintiff as set forth in
the Note in the amount of$179.65 each for March 14, 2014 through August 29, 2014
as more particularly set forth and described, in part, in the Act 91 Notice attached
hereto as Exhibit"D" and made part hereof.
9. Members 1St gave written notice of its intent to foreclose Pursuant to the Act of
January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. SeMc., and in particular
section 403 thereof, and of Defendants' rights in accordance with the Homeowners'
Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35
P.S. Section 1680.401(c), et. seq., by letter dated June 5, 2014, addressed to Dean
Kennedy at the Property and the address set forth in paragraph 2 above and to
3
Michelle Kennedy at the Property, Defendants' last known addresses, via certified
mail, return receipt requested. A copy of the said notice is attached hereto as Exhibit
"D"and made part hereof.
10. Simultaneously, Members 1"forwarded to Defendants the same Notices and
addressed to Defendants at the same addresses as set forth in paragraph 9 by United
States mail, first class, postage prepaid, bearing the return address of Members 1st
The Notices forwarded in said manner have not been returned to the offices of
Members 1St as undeliverable or otherwise.
11. Defendants are indebted to Members 1St under the Mortgage in the amount of
THIRTY-TWO THOUSAND FIFTY-NINE and 81/100($32,059.81) dollars itemized
as follows:
a. Outstanding principal $29,641.73
b. Interest to September 19, 2014 1,101.34
c. Late charges 116.74
d. Attorney fees and expenses 1,200.00
e. Total due to Members 1St $32,059.81
12. Defendants also agreed under the terms and conditions of the Mortgage that in the
event of default there under Defendants would pay, in addition to the amounts set
forth in paragraph 11 above, costs incurred by Members 1St as a result of the
institution of these legal proceedings.
4
13. The obligation owed to Members 1St on the Mortgage continues to accrue interest at
the rate of$5.6360 per day, through the date of payment.
14. Members 1St is not seeking a judgment of personal liability(or an in personam
judgment) against Defendant(s); however, Members 1St reserves the right to bring a
separate action to establish that right, if such right exists. If one or more of
Defendant(s) have received a discharge of personal liability in a bankruptcy
proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such
personal liability discharged in bankruptcy, but only to foreclose the mortgage and
sell the Property in accordance with Pennsylvania law.
15. As set forth above, Members 1St has made demand upon Defendants to pay to
Members 1 St the amounts due under the Mortgage and the Note. However, as of the
date hereof, Defendants continue to refuse and fail to make payment of such amounts
to Members 1St
WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment, IN
REM, against Defendants, Dean P. Kennedy,Jr. and Michelle Kennedy a/k/a Michelle L.
Kennedy, in the amount THIRTY-TWO THOUSAND FIFTY-NINE and 81/100($32,059.81)
DOLLARS plus interest at the rate of$5.6360 per day, through the date of entry of judgment on
this complaint and at the legal rate thereafter through the date of payment, additional legal fees
and costs of suit as well as other costs and charges collectable under the Mortgage and for
foreclosure and sale of the mortgaged property.
5
Respectfully submitted,
Date:
arl M. Le ebohm, Esq.
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
6
Ni
81 LOAN A CLOSED-END NOTE,DISCLOSURE
LOAN AND DN IRITV DISCLOSgW
URE,
Eppy LOU Drive Pa BOX 40 nORROWER'S NAME Mb ADDRESS
Me ion PA 17055 DEAN P KENNEDY,LE IR
63 RLI SVEN 2
MrF'.MBo ERS P u muni NUMn
ent
E 94 CO-aORROWER's NAME
PM M.AMOMW LOµNUNRER MICHELLE KENNEDY
CO.ROnROWEITS NAME
0 0 MAi 1
el%Ee VARIABLE
ANNUAL PERCENTAGE FINANCE CHARGE: Arnoure Financed:The amoumot TaaldPayments;The amoum
RATE:The COSI d your c ed t es a The dollar amount the credt YAII aed8 provided to you or on your you 1vd1 have paid after you have
yearly rale.' tORyou. beha((. made O9 a
p ymems as schaduted. I
8.94% 0 5 24,320.05 o $38,0D0.00 $ 70,739.05 e
Variable Rab.II Via roan nos a,aliabla rate as Indicated fib"the Anrcual Parentage Rote may Irvaeaso drrrkg Uro taml of this pansaOlon Ir�.he Ondo*chelgas,Tne _
aadN lnkn MAI gide a margin of to the Index valva.The rate wD change mortMyon the firs:day d the mush.Tho Talo YNI neYer pe hlgha then Ilio maximum rete allowed by
low,and b will never be loss u+on, Any Imagist late Increases W nasus M More pa mans or n u same amwn,For E%amfde,Y your loan was fur 55,000 M 15%late
moons and mo AMNI POraraage RMo Incr oo by 2%aRa ono yea,tho torts of yaus ken woad Inrnaso by two momhs
aRA•rod RMo:Gdleratd,el0(d n s(ofwrkaC
AmgnaUe Payment plsr:avrNed pati:Bocatlsa you have oppteed m make ya%requred nc,ahly ya�rmns thrwgh nn eummatk aeducUcn aom your CneckNygeNngs
AceaHL year ANN AL PERCENTAGE RATE nes been dlsoounnedAy 20'16.Th8 ANNUAL PERCENTAGE M7E dlecbwd above Mlhe ANNUAL l" RCENTAO"e 11 Ebo%Is
the Automltic Paappnnma DivalMed Roca TMs rote vA0 4umaso OY.2095 G yea ta0se em omamaU[peynrMt errangnmeM a rNl k malnmk wrhlnm km0s k your attoot to
cava the automalk peymems.k such a ease.the onoL7d IM(nuoaso will bo m esmnd Nelarm atyour ken.Rae%empk,G yart AuomeUc Prm phmumod Redo Is 10%
on a SS,000.Oo ben kr 00 mmNs ane youc¢ase tAa paomak geyman acre your ratewlNlncreese to 10.2076,resul0rlg In 1 adodonot(Hymen.
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tnibl CpmrerraA ANMfM PERGEN'fAGE RATE Hill Nen vary accpdhm to charges b UH kdek las disclosed abavat,Fa r.%arnMo.
Jr.mloWe rote ban's Initial ANNUAL
PWICFNTAOfi RATE lo 71%M led Uml yogi mYo(h0 kart,y0V 4Utlaf pmfara0 ANNIUv.PERCENTAGE RATE.ed be NlA%,Yea IIRW preferred ANNUAL PERCENTAGE
IUTf wla UHn vay accoreug ro the Intek b dbelotad In alp lenaab Rola•(YpNeran akaW.
Flsed Rau Pralared Loans,II your leen Is a mmd tele ben and yell QtHWY lo•a prefaced roar,your ANNUAL PERCENTAGE RATE YA be the pmlarad ANNUAL
PERCENTAGE MTE 6scbsodabova for as es okrred alMVa romMniN adoµ
Numbaolpayments AmountofPnymmnts Payment Fmgansy WTlon payments pre Due rppppecrr((yy lnslrAnee:YOU may Obtain pro0erty
rocs IIUUrefl. (ftyll an4ane I WnnI thot N atCo 1lable to
aymalt 389 1179.88 81-Weeldy•Beginning 07/77/2008 Cr crtj1union,if�+ou e(theInslttancerrat�the
creel t un(on you ME pay
eau 1 317357 Finn[$lire-On OtY09/2023 SN/A
ww so tY:GOWN saeurkg other bons wk UH t'AaW Vion opr0pegy Omer
sWN also secue dds tan Yw ae k.uq a socrdt kaerest In sod - D(poscd(kF•
year Alkrat andla dnpask utaH c�adn TlNon.ami" % mortgnge
'Late C�hhwerO�ee:U a 0oymalt is[me by 10 days a more you will Rogvked Deposit Solana;The An nut)Percantege Rede does Flling Foes: Non.Fllinp Msuroece:
On ehmgmla Into loo d 5%or your sc poymem. rot take Into comet year rlquved dnposA anNneo,G any. f N! N NM
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�HOONeaMpepgmaA Nhxgs WM pnneum.
TE 12A PION 0
AMOUNT FINANCED S 35.000,00 AmoUrKPaid loothersonyourbehat((Describe)
$ TO f TO
AMOUNT GIVEN TO YOU DIRECTLY$ 6,124.23 ; To 3 To
S TO
TO 1
f To
TO
$ To
AMOUNT PAID ON YOUR ACCOUNTS 31.875,77 s To $ To
f S T
Too
S To
f
PREPAID FINANCE-CHARGE TO f To
$ 0.00 f TO $0.00 To teas
To mm samb i To Area sdwans
1 _ � '"SECURITYINFORMA ION � "' -'"—' - •I
MAKE MODEL YEAR ID.NUMSER TYPE VALUE
OTHER(Describe):263 CARLISLE AVNUE ENOLA PA 7702E
YOU Hedge,ShaMQVNT ACCQUNT NI1MaER AMOUNT ACCOUNT NUMBER
enDeposits of $
i
�You agree met the terms nndeondabm In leo disclosure smtercOnt and the ran and seeuNy egrenmems located on pago 2 M this document sMll apply to 09 ben.d to Is more
W¢e bmmwer,we WOO mat an Uk dondNions d tha ban ON security agreemems 90varnng tis leen seen OF Fy le b&Ajdnlly and soveroliy,Yw ocbtovMidgo 1hM you h d
I N10d on pa a La leen and wacky agreements end dhclnsvro statement.Ca-signer:G you are 3lgnbg as ca sl9ner.you ec%na Aedge ret 1p1 of IM Hello b w.slgnor
SIGN E (SGDAT •1 n •OTHER OWNER❑••COSIGNER OATC
(SEAL)
❑ CO-MAKER 0'07HER CR(]'•CO•SiONER DATE C
O-MAKER ❑• M NERC]"COSIGNER DATE (�
X (SEAQ (SEAL)
❑ CO-MAKER ❑•OTHER OWNER❑'•CO•SIONER DATE
X (SEAL) ❑ OO.MAKER ❑•OTHER OWNER❑ ••COSIGNER PATE
X CSEAQ
atlmtaPMEniMryp�'pnwp4+aA%a'IYMAapn elle Urn.Y..aaaalxrel Llauamwaorpeeega,w,rs4m M,.}M Marawm,uYeq aharaom•Mr,em q'9r.a wY.Y wa AaM,am aMeruMr,lut
aW UNarparauMYIAIRauwYla mlawNata,elagaanW SaWayM a.+ler."Ga.pGNEN Wad H1Nl.ppaliMluMO Mysaasm„eats.AYe'wt acro Wewaweraa,p.rM lr Ymf aYrwll,rMn1M
pwaaawiw.wmpalaWY,hlraYrwpJealowaeNppaW qI
NOTICE TO CO•^IGNER
rnu ere in(7 esked� tmrerNoo Ihls debt.T Itlnk carefLAly!1p(ore yea dO,if 0w borrower doasnT pay the debt you vAll have to.Ba surd you Wn Mord(O
pay Il ynv Jaye a,a t`f<at you want to accept Nls responsfulgty.
mmeYaI may Cleve to pay tg1 t0 ilia 1tNi nmounl or the debt If the bdrrovrer does not pny.Yau may also have to pay late fees a cMlenlbn tORa,whkb hlwoasO Nls
c eUAa qn collect 011a deed Iron u without fkst 1 #�t cogrzd Iran Ilia baro>Per.Tile creditor tan lase the same�ollauhn mahods stns you tool
Can be LrseNd aealrlSt dre borrower,nuc l�ps su� 4�rn hPn9 Y�lt wagon,Ott.(Ilhlls tlobl(s aver InderaulL Ilial tad may tlewme a part oal�Oa credit
remrtl,1 ids Halite I91ta the OorWatt t{Ht make �ou I tele tar the OabL
Page 1 of 2
Exhibit "A"
r 0w6RlrrwE 1,00 OBER ASCU WT mWeER GATE OI LaaN
DEAN P KENNEDY,Jn 0611177
LNa�j,%W T5,1'NE WORDS'CREDIT UNIOM h1EANS MEMBCRS IST FEDERAL CREDIT UNOR.THE WOROS'YOU;'YOUR'AND'YOURS•MEAN THOSE
LOAN AGREEMENT SECUPJTY AGREEMENT
PaymarUs7f-•Iry'mCO�iarygy;Fa vahn received. praMse to p°,m 1. to 0 or s erW en ez es Irxurr W the credit
Um Credit UNORS all errtourrta due.AU is shall ba luaarlln ��a b r�a R on a sac�Q��1
"U,.b Itat msc 0 Statement tet nnDo 1� lyds doaenem.You ye!n vc.c�t "","'rcy rmrvnsl t l9ZV on
suntl Inas Um f nee an a o tot".1.
l M shown on t w u� s k loos,nc uta aKfne otos,
pr, ao s w r to slcw�raod poTaty pro�nodyNA .
I e ed on a SUm)AIOrI A aA ancel0°orsilM xnaotl property erdMl Q,rrmgl iQcelued from them
w1 bo m o on to scheataed dro a ari?9=.,:a a socu�e°progeny.
preferred rete ro Vou ao)p(nua to s Ilsly th0 ltrel preferted dosz•cakewrelusll I as IN ra this I n a ra any
1 you (DaalY asry.IstertmBrtf�uw mno it LS due,you 1nR pay o�1au kwn Bunn 4rott pr rAHxewrn olimalm. y
addkbRN IrIwr06 Uf0 Ov«dua a RL Gorr ores an now In the r�lttAi Ha+
Alia.of payrnems and Addltfonef Payments:Payments and �ocr° 9rot�er ret l nnott�s(cc s s bon 6 . It ro
cradle shall Fin applied H Ih0 fd ord.:arty amotugsmafwsl dug>mY Rhen ofd e a IeRel s�wementl ae sa t kat a a e man pu rRese
lass OrUuuflesowFF4trlck". any promfierrs•oces(tu Iflleresl "'�r��)'sous Uooas•
o�atm)ceu tees:ouls(Arr�ng prirdpel.Payments made In edition l0 2• You+ii �ror ma I ration d.soli a uansM Ate mRaael unless you tmYo
ttlany Mia Payments shng be BMW in the some ardor. ole n s r m conw so
ll
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e�so.Uler enendlnpt7te to of y0ur ban.You aantlse t°cag- a m.ret rot az sp c�1s yen�m
maklrgya s aM htrtfee[all ITnns under dts ngre=,.own aP r is WmCnOmerts�m,t msadl1'~,r etlt an0 eA�do mf a t1t�progeny
You Agar roc Iho pr ometl ro e, you 6, crit msuro to cyanitlea b whkn dro
ala Pharppos:KYou make a(�e piryrtwn6 You a9rce to pay a(oto charge at�as a song r urRr�l Ica `�n nMd alh
one s Ulffdmadan pogo 1 d llt5 t(ocume6d, o e ec to a aadA Cain.you pryp(
� IF
Pr IMurence;if yyooUu obtain a loan seamed by a Motor vehicle a atm Sksa ir�lyyeooy�I,�s o tr[cre0ii e pr tMs
Pr
( °M f�sUranCnWn(Ch aUIOC(s UIC aadil trot b9mv°e apLtn°biro�e °r' a aAd acre rrrtl6n may'Ma
m a T arnotmt an aOVera a (Is0 el o�wu sureUaa a ou own Dost d o7rm
must
ustoeMB must 8CC W r0 lib a C s M eam st m the ConUOa rate uvttp a metra
ppee Vrd a a f� , n to Uq Cod Rilon mo M to fecdYa um acooes of an eau m
nrovldo al t Bra 1 mmbkred addlUmel nrM s n a avya oa1$i r a Naafi ocrnoee�ac to cny
alswarxIcPp..
fire io oIr o loss Payabb clause en nrAl rmfltkto the No ' 1'n ttnwancD, ap�»zo P caoas to o ° 0ov to
CFO%talionasOenI v0UmayoVM A1tInsu..hamanyaoamd tl1C
Vfrotm chdce end dkea the ag«a to send the acdk melon a co" thLt y NUS, a Ina ofod6�artn to oroNa�Our InsurmRe Senke Conk.
wrin'Itnr�emssmy miu A avaUkLWn aguaamvnr
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(Ohio canuaa rAe.
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0.1 Uma M detetat b so This loon.lktce you ere In daetA din
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Oaln In Enforcer=I;Credk Unix n dc�ay enrwcIq arty orlho credit t
t eluents under th�agreementtr,�hlw�bstrty them. r
It for PoymeMs;The credit union may accept IDIOM s a partial
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trop a shell,ppty to en N stores which"y be held M a.IndMdutl
Ralrement Account to"Keogh Men,•
Page 2 of 2
OS/ £ 6£:L£:8O 60/60/bIOZ
Ala. MEE csNXA= lot or piece of 1x40 eitdate in Enola
Terrace East P6bgSbaro TOwnahip, Llnmbexland County, Pennoylvania
bounded And deStribed as follows, to grit: ,
tNACT so. 11 BX(#I'(ING At a point an the W09tern side of
Carlisle Avenue, said point ale* being 354 feat bogtb from the
Southern ling Of Church street and being the dividing line Of lot
herein convoyed and Lot no, 21 as shanrn d¢ Flan of Lots known as
"SUCLa Terrace", thence In a Soutborly direction along the WesterA
si4e of Carlisle Avenue s0 feet to a point on the northsra side of
an unnamed alley; tbeacs in a Keaterly diraotion along the Xorthern
aids of last maUtioned unnamed alley, 150 f*9t to a point on the
Eastern side of another unnOmod alleys theno• in a Northnrly
dir*ction along the Eastern side of 145t Mntianed unn-M 4 alley So
feet to a point dividing tae lot herein c=Vsyed and Lot No. 21;
tboncv in an Easterly direction along the Southam aide of 1.0t RQ,
21 e4 shown oa Flan of Lots har* n 2"ntioned ISO feet to a point au
the Western aide of Carlisle Avebue, the place of agGI€] ING.
HAVING T=== ESRD a 1 Story ces*At block dwelling
known as 263 Carlisle AV#ZUs.
%RgWO Lot No. 22, aloCk D on tbs Flan Of Lots known as
kdu*IA Verrace" laid out riy Arthar R. s.Kplsy said plan being
racordnd in the Cumberland County Racorder'a office in Plan book 1,
Page 3.
TRACT NO. 2- BEGIRNTUG at a point in the W&Otern line of
Carlisle Avenue, 50 feet Borth of tho NortlWeatorn corUcr of the
interseotion of Carlisle Avenue and an unnAftod allay; thence
aostwardly 41*au the NbrthOrn line Of Lot No. 22, A4ctiOn b Of the
h6taigafter ncentiQncd Flan of 1,ots 150 fact to a ,point in the
sastbrn line of another unnamed Allay, thence Northwardly along the
Eastern Brio of the lAtter unnamed, alley, 15 feet, to a point in the
center line of Lot lid. 21, Section D; thence Ustwardly Along the
center ILA* Of Lot leo_ 22, section p, 15o fast to a point iU
Western line of Carlisle Avenue; thence Southwardly Along the
WOOtarn line of Carlisle Avenue, 25 feet to a point the pX$cc of
$SQI$11I]t(i.
bblie the 804thern 1/2 of Lot No. 21, $eetiOU n an a Flan
Of Lots laid out by Arthur R. Rupeee�►►, and knvwu as °Enola Tarrace",
and said plan of Lots boiag record.ad in the aforetaid li8corder,s
Office in Flan 86ok 3, Page 3,
Known and numbered as 263 Carlisle Avenue, Enola, PA 17025.
Being the same premises which Steven L. Stubbins and Karen S. Stubbins by their deed dated
July 24, 1998, and recorded in the Cumberland County Recorder of Deeds Office at Deed Book
182, Page 184 granted and conveyed onto Dean P. Kennedy,Jr., and Michelle L. Kennedy.
Being Tax Parcel #: 09-14-0834-065
Exhibit "6"
Prepared By: Members 1st FCU
5000 Louise Drive
Mechanicsburg,PA 17055
WHEN RECORDED RETURN TO:
Equfty Loan Services, Inc,
1100 Superior Ave., Ste. 200
Cleveland, OH 44114
National Recording — FACT
CQi`[ 1=D-.
iy-oga�i-c»65 Q�
MORTGAGE
Made 06/13/2008
Between
DEAN P KENNEDY JR AND MICHELLE KENNEDY
ere "Mortgagor")
And
MEMBERS IST FEDERAL CREDIT UNION (hereinafter called"Mortgagee")
Whereas,Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note(hereinafter
called the"Note")a even date herewith,payable to the miler Mortgagee in theprincipal sum of
1 38,000.00 lawful money of the United States of America,and has provided therein
for payment of any additional moneys loaned or advanced theremider by Mortgagee,together with
Interest thereon at the rate provided in the Note,in the manner and at the times therein set forth,and
containing certain other terms and conditions,all of which are specifically incorporated herein by
reference;
Now,Therefore,Mortgagor,in consideration of said debt or principal sum and as security for the
payment of the same and interest as aforesaid,together with all other sums payable hereunder or under
the terms of the Note,does grant and convey unto Mortgagee,
All that certain property of the Mortgagor located In EAST PENNSBORO
TOWNSHIP _Cumbarianrl County, Pennsylvania
SEE ATTACHED EXHIBIT"A"
which currently has the address of__ 263 CARLISLE AVENUE
Enola Pennsylvania 17025
[Caryl [Street] (Zip Code)
Acct No APPm Page 1 of 4
Exhibit "C"
0
Together with the buildings and improvements erected thereon,the appurtenance.9 thereunto
belonging and the reversions,remainders,rents,issues and profits thereoff.
To Have and To Hold the same unto Mortgagee,its successors and assigns,forever.
Provided,However,That if Mortgagor shall pay to Mortga ee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note,together with interest thereon,and shall keep and perform each of the
other covenants,conditions and agreements hereinafter set forth,then this Mortgage and the estate hereby
granted and conveyed shall become void.
This Mortgage is executed and delivered subject to the following covenants,conditions and
agreements:
(1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any
future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
Intended by Mortgagor and Mortgagee to be so evidenced and secured,and such loans and advances shall
be added to the principal debt.
(2) From time to time until said debt and interest are fully paid,Mortgagor shall: (a)pay and
dischharge,when and as the same shall become due and payable,all taxes,assessments,sewer and water
rents,and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt
secured hereby,(b)pay all ground rents reserved from the mortgaged premises and pay and discharrgge all
mechanics'liens which maybe filed agalrut said premises and which s�rall or mi�lrt have priority in lien
or payment to the debt secured hereby,(c)pay and discharge any documentary Zp or other tax,
Including interest and penalties thereon,if any,now or hereafter becoming payable on the Note
evidencing the debt secured hereby,(d)provide,renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as D&rtgagee may from time to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
With loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear,
and(e}promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
charges;provided,however,that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges Ue paid in installments to Mortgagee,
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and
substantial repair as determined by Mortggaaggee. Mortgagee shall have the right to enter upon the
mortgaged remises at any reasonable hour for the purpose of inspecting the order,condition and repair
of the buildpings and improvements erected thereon.
Acct No ApplD_ Page 2 of 4
OS/ .L 6E:ZE:80 60/60/b LOZ
(4) In the event Morygor neglects or refuses to pay the charges mentioned at(2) above,or fails to
maintain the buildings ancc77 improvements as aforesaid.Mortgagee may do so,add the cost thereof to the
principal debt secured hereby,and collect the same as a part of said principal debt.
(5) Mortgagor covenants and agrees not to create,nor permit to accrue,upon all or any part of the
mortgaged premises,any debt,lien or charge which would be prior to,or on a parity with,the lien of this
Mortgage.
(6) In case default be made for the space of thirty(30)days in the payment of any installment of
principal or interest pursuant to the terms of the Note,or in theperformance by Mortgagor of any of the
other obligations of the Note or this Mortgage,the entire unpaid balance of said prindpal sum,additional
loans or advances and all other suras paid by Mortga ee pursuant to the terms of the Note or this
Mortgage,together with unpaid interest thereon,sha�at the option of Mortgagee and without notice
become immediately due and payable,and foreclosure proceedings may be brought forthwith on this
Mortgage and prosecuted tojudgment,execution and sale for the collection of the same,together with
costs of suit and an attorney's commission for collection of five percent(5%)of the total indebtedness or
$200,whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said
proceedings,waives stay of execution,the right of inquisition and extension of time of payment,agrees
to condemnation of any party levied upon by virtue of any such execution,and waives all exemptions
from levy and sale of any property that now is or hereafter may be exempted by law.
(7) Upon payment of all sums secured by this Mortgage,this MortCage and the estate conveyed shall
terminate and become void. After such occurrence,Mortgagee shall discharge and satisfy this Mortgage. I
Mortgagor shall pay any recordation costs. Mortgaaggee may charge Mortgagor a fee for releasing this
Mortgage,but only if the fee is paid to a third party for services rendered and the charging of the fee is
permitted under Applicable Law.
The covenants,conditions and agreements contained in this Mortgage shall bind,and the benefits shall
Inure to,the respective parties hereto and their respective heirs,executors,administrators,successors and
assigns,and ifs Mortgage is executed by more than one party,the undertakings and liability of each
shall bejointand several
Aou No AppIDPage 3 of 4
OS/ 8 6E:ZF:8O 60/60/V LOZ
i
Witness the due execution hereof the day and year first above written.
DD ANP KENNEDY JR
M CH[LLE KENNEDY
Commonwealth of Pennsylvania
ss:
County of Cumberland. )
QO this,the 13th day of June ,2008 before me,
Me lssa Jrreeenwood .the undersigned officer,personally appeared
DFAN P KFNN D)Y IR AMID MIC HR 1 F KENNEDY
satisfactorily proven tome to be thepersons)whose name(s)Ware subscribed to the within Mortgage,and
acknowledged that he/she executed the same for the purposes therein contained.
In Witness Whereof,I hereunto set my hand and official seal.
L AZ,0,Z
My commission expires:
CON(MON•NFIaLTh!OF PENNSYLVANIA
Ma;t�J Gr&wmd,Notary Public
I aWpenrlsbom Tei..CMI)E Land County
My Camm�MVres May 10,2011
Cedti cote of Residence of Mortgagee Member,Pennsvivonla Asauclation of Notaries
Members in Federal Credit Union,Mortgagee within n d,hereby cerdG that its residence
Is 5000 Louise Drive,Mechanicsburg,PA 17055.
By
Acct No AppID_ _ Page 4 of 4
OS/ 6 6E:ZE:80 60/60/t7 LOZ
EXHIBIT "A"
LEGAL DESCRIPTION
A PARCEL OF LAND SITUATED IN THE STATE OF PENNSYLVANIA, COUNTY OF
CUMBERLAND, WITH A STREET LOCATION ADDRESS OF 263 CARLISLE AVE;
ENOLA, PA 17025-2206 CURRENTLY OWNED BY DEAN P. KENNEDY JR AND
MICHELLE KENNEDY HAVING A TAX IDENTIFICATION NUMBER OF
14-0634-0065-0000000-09 AND BEING THE SAME PROPERTY MORE FUL'L'Y
DESCRIBED IN BOOK/PAGE OR DOCUMENT NUMBER 182-184 AND FURTHER
DESCRIBED AS LOT 22 & PO 21 SEC D,
14-0834-0065-0000000-09
263 CARLISLE AVE; ENOLA, PA 17025-2206
E11II11011l1lo 1111 KENNEDY JR
37791858 1 PA
37791858/f FIRST AMERICAN ELS
MORTGAGE
lil l 11 l{IlI�I IIII!llllll1118f 111!�I I I I➢!Il
OS/ 01 6E:LE:80 60/60/ti 1W
- ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY ,
1 COURTHOUSE SQUARE
CARLISLE, PA 17013 - -
717-240-6370
i
Instrument Number-20082161.9
Recorded On 6/26/2008 At 11:12:23 AM *Total Pages-6
*Instrument Type-MORTGAGE
Invoice Number-23869 User ID-MSW
*Mortgagor-KENNEDY,DEAN P JR
*Mortgagee-MEMBERS IST FEDERAL CR UN
Customer-FIRST AMERICAN
FEES
STATE WRIT TAR $0.50 Certification Page
STATE JCS/ACCESS TO $10.00
JUSTICE DO NOT DETACH
RECORDING FEES — $13.50
RECORDER OF DEEDS now This page is art
AFFORDABLE HOUSING $11.50 P g P
COUNTY ARCHIVES FEE $2.00 of this legal document. ,
ROD ARCHIVES FEE $3.00
TOTAL PAID $40.50
I Certify this to be recorded
in Cumberland County PA
RECORDER 0 D EDS
t
"-Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
NOW
111111 fllffllllfll(lfffflll
OS/ L L 6�'ZE:80 60/60/t7 LOZ
(Rev.9/2008)
Date: June S,2014
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (REMAPJ
may be able to help to save lour home This Notice explains how the program works.
To see if HEMAP can help.you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with You
pvhen you meet with the Counseling Agency. ^�
The name address and phone number of Consumer Credit Counseling Agencies serving your
County are listed at the end of this Notice. If you have any questions,you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired
hearing can call(717) 780-186,99).
This Notice contains important Iegal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRtSTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERE CHO A REDIMIR SU HIPOTECA.
Pagel U5
os/ Exhibit "D"
HOMEOWNER'S NAME(S): DEAN P KENNEDY JR
MICHELLE KENNEDY
PROPERTY ADDRESS: 263 CARLISLE AVENUE
ENOLA,PA 17025
LOAN ACCT.NO.:
ORIGINAL LENDER: Members I"Federal Credit Union
CURRENT LENDER/SERVICER: Members l"Federal Credit Union
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIRI F FOR FIN AN IAL ASSISTAN F
A IICH CAN SAVE YO IR HOME FROM FORECLOSURE AND
HELP_YOU MAU FUTURE MORTGAGE PAYMENT,,,S
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORFCI O RF -- Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you
must arrange and attend a"face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST OCCUR WITHIN THT]ITY-THREF 03) j2AYS OF THE DATE OF THIS
NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CEL DIT COUNSELING AGENCIES_If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting.The names addresses and telephone numbers of designated consumer credit counseling agencies for the coun
jy
in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face
meeting.Advise your lender immediatelX of your intentions,
APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set forth later in this
Notice(see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign
and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice, Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA
and received within thirty(30)days of your face-to-face meeting with the counseling agency
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA.WITHIN 30 DAYS OF THAT MEETING,THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED
"TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE
STOPPED.
Page 2 of 5
OS/ S1 6£:L£:80 60/60/17 LOZ
AGENCY ATC ION-- Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty(60)
days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application,
(VOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have riled bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OFTHE + + --The MORTGAGE debt held by the above lender on your property located at:
263 CARLISLE AVENUE
ENOLA,PA 17025
IS SERIOUSLY IN DEFAULT because: !"—
A. YOU HAVE NOT MADE .MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:$179.65 for 03/14/14,$179.65 for 3/28/14,$179.65 for 04/11/14,$179.65 for 04/25/14,
$179.65 for 05/09/14,$179.65 for 05/23/14
Other charges(explain/itemize):
TOTAL AMOUNT PAST DUE: $1,077.52
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION(Do not use if not applicable}; i
HOW TO CURE THE DEFAULT__You may cure the default within THIRTY(30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,077.52
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY(30)
DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and
sent to:
Members 1"Federal Credit Union,ATTN: Laura Z
5000 Louise Drive
Mechaniesbure,PA 17055
You can cure any other default by taking the following action within THIRTY(30) DAYS of the date of this letter: (Do
not use if not applicable.)
Page 3 of 5
OS/ 91. 6E:ZE:80 60/60/ti 10Z
IF YOU DO NOT CURE THE DEFA 1i,T--If you do not cure the default within THIRTY(30) DAYS of the date of
this Notice, the lender_intends to exercise its rights to accelerate-the mortgage debt, This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged prgilerty,
IF THE MORTGACZF IS FORECLOSrip UPON--The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred,up to
$50.00. However,if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually
incurred by the lender even if they exceed $50,00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If you cure the default within the THIRTY(30)DAY p rere iod you will
not be reg uir d n Uay at orn .y's fees.
OTHER LENDER REMEDIES—The tender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage,
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALF, -- 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 agy time up to one hour before the Sheriffs Sale You may do so by p ing the total amount then past
due,plus any late or other charges then due,.reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other
requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSI3 E
SHERIFF'. A .E DATE -- It is estimated that the earliest date that such a Sheriffs Sale of
the mortgaged property could be held would be approximately Six(6)months from the date of this Notice. A notice of I
the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time exactly what the required payment or action will
be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Members lar Federal Credit Union
Address: 5000 Louise Drive
Mechanicsburg,PA 170$5
Phone Number* (717)7rvr 5134
Fax Djumbere (717)79.-L-5207
Contact Person: Laura
E-Mail Address: .immermanl0memberQl-rE -
EFFECT OF MERIFF'S $,ALF -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGF, -- You may or XX may not(CHECK ONE)sell or transfer your home to a
buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments,charges and attorney's
fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
Page 4 of 5
OS/ L l 6E:ZE:80 60/60/t,l0Z
YOU MAY ALSO_HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS.RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE,MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
(Fill in a list of all Counseling Agencies listed in Annendix C FOR THE COMY in which the propec&is
Gated. using additional pages X necessary .
I
I
i
Certified Mail # 9171082133393960099805
Page 5 of 5
OS/ 81 68:LE:80 60/60/t,LOZ
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO.HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT_COUNSELING AGENCIES SE RVINKQUR COUNNTY
(Fill in a list of all Counseling Agencies listed in Appendix a FOR THE COUNTY in which the nronerU it
located using additional pages if necessaIX).
Certified Mail # 9171082133393960099874
i
Page 5 of 5
OS/ 8Z 6E:ZE:80 60/60/t7 We
YOU MAY ALSO HAVE THE RIGI�T:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE .MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION .BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENC FS SERVING YOUR COUNTY
fal in a list of all Counseling Agencies liste4 in 4ppendix C FOR THE COUNTY in which the grogam is
located, itio e i
Certified Mail # 9171082133393960099799
Page 5 of 5
OS/ 8£ 6£:L£:80 60/60/t7 IOZ
Servicemembers Civil U.S. Department of OMB Approval 2502-
Relief Act Notice Disclosure Housing 0584
and Urban Development Exp 11/3012014
Office of Housing
Legal Rights and Protections Under the SCRA
Servicemembers on"active duty"or"active service,"or a spouse or dependent of such a servicemember may be
entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act(50 USC App.
§§501-597b)(SCRA).
Who May Be Entitled to Legal Protections Under the SCRA?
• Regular members of the U.S.Armed Forces(Army,Navy,Air force,Marine Corps and
Coast Guard).
• Reserve and National Guard personnel who have been activated and are on Federal active
duty i
• National Guard personnel under a call or order to active duty for more than 30 consecutive
days under section 502(f)of title 32,United States Code,for purposes of responding to a
national emergency declared by the President and supported by Federal funds
• Active service members of the commissioned corps of the Public Health Service and the
National Oceanic and Atmospheric Administration.
• Certain United States citizens serving with the armed forces of a nation with which the
United States is allied in the prosecution of a war or military action.
What Legal Protections Are Servicemembers Entitled To Under the SCRA?
• The SCRA states that a debt incurred by a servicemember,or servicemember and spouse jointly,
prior to entering military service shall not bear interest at a rate above 6%duringthe period of
militaryservice and one year thereafter,in the case of an obligation or liability consisting of a mortgage,
trust deed,or other security in the nature of a mortgage,or duringthe period of military service in the case
of any other obligation or liability.
• The SCRA states that In a legal action to enforce a debt against real estate that is filed during,or
within one year after the servicemember's military service,a court may stop the proceedings for a
period of time,or adjust the debt.In addition,the sale,foreclosure,or seizure of real estate shall
not be valid if it occurs during,or within one year after the servicemember's military service unless
the creditor has obtained a valid court order approving the sale,foreclosure,or seizure of the real
estate.
• The SCRA contains many other protections besides those applicable to home loans.
How Does A Servicemember or Dependent Request Relief Under the SCRA?
• In order to request relief under the SCRA from loans with interest rates above 6%a servicemember
or spouse must provide a written request to the lender,together with a copy of the servicemember's
military orders. [Note: Lender should place its name,address,and contact information here.]
• There is no requirement under the SCRA,however,for a servicemember to provide a written notice
or a copy of a servicemember's military orders to the lender in connection with a foreclosure or other
debt enforcement action against real estate. Under these circumstances,lenders should inquire about
the military status of a person by searching the Department of Defense's Defense Manpower Data
Center's website,contacting the servicemember,and examining their files for indicia of military
05/ 6L 6E:ZE:80 60/60/b LOZ
service. Although there is no requirement for servicemembers to alert the lender of their military
status in these situations,it still is a good idea for the servicemember to do so,
Now Does a Servicemember or Dependent Obtain Information About the SCRA?
Servicemembers and dependents with questions about the SCRA should contact their unit'sludge
Advocate,or their installation's Legal Assistance Officer.A military legal assistance office locator for all
branches of the Armed Forces is available at http://lesalassistance.law.af.mil/content/locator php
• "Military OneSource"is the U.S.Department of Defense's information resource.If you are listed as
entitled to legal protections under the SCRA(see above),please go to
www.militauonesource-com/scra or call 1-800-342-9647(toll free from the United States)to find
out more information.Dialing instructions for areas outside the United States are provided on the
webslte.
I
OS/ OZ 6E:ZE:8060/60/t7IOZ
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated:04/23/2014 05:44 PM
Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region
2000 Linglestown Road 1514 Derry Street
Harrisburg,PA 17102 Harrisburg,PA 17104
888-511-2227 717-232-9757
Housing Alliance of York/Y housing Resources Maranatha
290 West Market Street 43 Philadelphia Avenue
York,PA 17401 Waynesboro,PA 17268
717-855-2752 717-762-3285
PathStone Corporation PathStone Corporation
1625 North Front St
450 Cleveland Ave
Harrisburg,PA 17102 Chambersburg,PA 17201 i
717-234-6616 717-264-5913
PA Interfaith Community Programs Inc PHFA
40 E High Street 211 North Front Street
Gettysburg,PA 17325 Harrisburg,PA 17110
717-334-1518 717-780-3940 800-342-2397
OS/ lZ 6£:L£*80 60/60/t IOZ
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09/09/2014 15:04 7179320317 KARLLEDEBOHM PAGE 08/08
MEMBERS 1ST IaEDERAL 1N THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
DEAN P. KENNEDY,JR. and
MICHELLE KENNEDY A/K/A
MICHELLE L. KENNEDY
DEFENDANT(S) : CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
VERIFICATION
r
I,Jennifer Perry, Collateral Liquidation Specialist for Members I"Federal Credit Union,
being authorized to do so on behalf of Members 1st Federal Credit Union, hereby verify that the
statements made in the foregoing pleading are true and correct to the best of my infolmation
knowledge and.belief.. I understand that false statements are made subject to the penalties of 18
Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities.
Members 1st Federal Credit Union
Date: September iL 2014
By:
Je ,fer t Colla.tera.. Liquidation.
Specia.
7
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 14-5595
Vs.
DEAN P. KENNEDY and : CIVIL ACTION — LAW
MICHELLE KENNEDY a/k/a
MICHELLE L. KENNEDY
DEFENDANTS : MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
To the Prothonotary:
Please reinstate the complaint filed in the above captioned matter.
Date: October 24, 2014
Respe lly submitted,
Karl M. Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
r THE PRO THON5
ov 01 eimnb
f?"140..
YO|�NOV 17 PN �� M�
^"``..�, . .. " v"
CUMBERLAND COUNTY
PENNSYLVANIA
/
Members 1st Federal Credit Union
Dean PauI Kennedy, Jr (et aL)
Case Number
2014-5595
SHERIFF'S RETURN�������K��
SERVICE
00/23/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligentsearch and inquiry
for the within named Defendant to wit: Dean Paul Kennedy, Jr. but was unable to locate the Defendant in
the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within
Complaint in Mortgage Foreclosure according to aw,
1006/2014 Ronny R Anderson, Sheriff, being duly sworn according to |ow, states he made diligent search and inquiry
for the within named Defendant to wit: Michelle Lynn Kennedy, but was unable to locate the Defendant in
his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as
"Not Found" at 263 Carlisle Avenue, East Pennsboro Township, Enola, PA 17025. Deputies were advised
that the defendant now resides at 516 C Range End Road, Dillsburg, PA 17019.
�
0/06/2014 04:49 pyN' Deputy Jamie DiN1a�i|e. being duly sworn according Uu|avv. semedthe vequo��ed Complaint
'
in Mortgage Foreclosure by personaily handing a true copy to a person representing themselves to be
the Defendnnt, to wit: Dean Paul Konnody, Jr at 263 Carlisle Avenue, East Pennsboro Tmwnahip, Enm|a,
PA 17025.
1007/2014 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of York County, the within
named Defendant Dean Paul Kennedy, Jr, not found. Richard Keuerleber, Sheriff, Return of Service
attached to and made part of the within record. "
1007/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Michelle Lynn Kennedy, but was unable to Iocate the Defendant in
the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Perrsylvania to serve the within
Complaint in Mortgage Foreclosure according to Iaw.
10/08/2014 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of York County, the within
named Defendant Michelle Lynn Kennedy, not found. Richard Keuedebor, Sheriff, Return of Service
attached to and made part of the within record.
*York County Sheriff tried service at 616 C Range End Road, instead of 516 C Range End Road as
requested.*
1029/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Michelle Lynn Kennedy, but was unable to locate the Defendant in
the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff ot York, Pennsylvania to serve the within
Complaint in Mortgage Foreclosure according to Iaw.
1103/2014 10:19 AM - The requested Complaint in Mortgage Foreclosure served by the Sheriff of York County upon
Dian Knisley, who accepted for Michelle Lynn Kennedy, at 516 C Range End Road, Dillsburg, PA 17019.
Richard KeuoUeber, Sheriff, Return of Service attached to and made part of the within record.
(Ci) CiountySuite Sheriff, Teieiosoft
SHERIFF COST: $109.44 SO ANSWERS,
November 07, 2014 RONR ANDERSON, SHERIFF
(G) CountySuite Sheriff, Teleosoft, Inc.
SHERIFF'S OFFICE OF YORK COUNTY
Richard P Keuerleber
Sheriff
Michael S. Hose
Chief Deputy, Operations
MEMBERS 1ST FEDERAL CREDIT
vs.
MICHELLE LYNN KENNEDY
PETER J. MANGAN, ESQ.
Solicitor
Richard E Rice, II
Chief Deputy, Administration
Case Number
14-5595
SHERIFF'S RETURN OF SERVICE
11/03/2014 10:19 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED
THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) BY HANDING A TRUE
COPY TO A PERSON REPRESENTING THEMSELVES TO BE DIAN KNISLY, MOTHER, WHO
ACCEPTED AS "ADULT PERSON IN CHARGE" FOR MICHELLE LYNN KENNEDY AT 515C RANGE
END ROAD, DILLSBURG, PA 17019.
MICHAEL NOVAN, DEPUTY
SHERIFF COST: $44.28 SO ANSWERS,
November 06, 2014 IC ARD • KE R EBER, SHERIFF
Affirmed and subscribed to before me this
6TH day of NOVEMBER
NOTARY
2014
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sheila E. Cook, Notary Public
City of York, York County
My Commission Expires Feb. 1, 2017
ME4,18EN, PENNSYLVANIA ASSOCIATION OF NOTARIES
(c) CouritySuite Sheriff. Teleosoft, c.
SHERIFF'S OFFICE OF YORK COUNTY
Richard P Keuerleber
Sheriff
Michael S. Hose
Chief Deputy, Operations
MEMBER 1ST FEDERAL CREDIT UNION
vs.
DEAN P. KENNEDY, JR. (et al.)
PETER J. MANGAN, ESQ.
Solicitor
Richard E Rice, II
Chief Deputy, Administration
Case Number
14-5595 CIVIL
SHERIFF'S RETURN OF SERVICE
09/25/2014 11:43 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW,
ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: DEAN P. KENNEDY, JR. AT 38 SOUTH YORK
ROAD, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED.
10/07/2014 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES
HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: DEAN
P. KENNEDY, JR., BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE
SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN CIVIL ACTION (CICA)
AS "NOT FOUND" AT 38 SOUTH YORK ROAD, DILLSBURG, PA 17019.
DEFENDANT WAS SERVED BY CUMBERLAND COUNTY SHERIFF.
10/08/2014 i, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES
HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT:
MICHELLE LYNN KENNEDY, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK.
THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN CIVIL ACTION
(CICA) AS "NOT FOUND" AT 616C RANGE END ROAD, DILLSBURG, PA 17019.
NO SUCH NUMBER ON RANGE END RD.
SHERIFF COST: $46.89 SO ANSWERS,
October 24, 2014 RICHARD P KE RLEBER, SHERIFF
NOTARY
Affirmed and subscribed to before me this
24TH day of OCTOBER 2014
icy CountySt to Sheriff, T
Co
ONWEALTH OF PENNSYLVANIA
Notarial Seal
Sheila E. Cook, Notary Public
CIty of York, York County
YCommission Expires Feb. 1, 2017
ER, PENNSYLVANIA ASSOCIATION OF NOTARI
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
i
COUNTY
LVANIA
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND: COUNTY,
: PENNSYLVANIA
: NO. I4-5595
Vs.
DEAN P. KENNEDY, JR. and : CIVIL ACTION— LAW
MICHELLE KENNEDY a/k/a
MICHELLE L. KENNEDY
DEFENDANTS : MORTGAGE FORECLOSURE
PRAECIPE ..
TO THE PROTHONOTARY:
Please enter.judgment in the above -captioned ° proceeding in favor of Members 1st
Federal Credit Union, Plaintiff, and against the Defendants, Dean. P. Kennedy,
Jr. and Michelle 'Kennedya/k/a Michelle L. Kennedy, in the amount of
THIRTY-TWO THOUSAND FIVE HUNDRED NINETY-FIVE AND 23/100
($32,595:23) DOLLARS, plus interest at the rate of $5.6360 per day from
December 23, 2014 through the date .of judgment and at the legal rate thereafter
until the date of payment, additional attorney's fees and costs of suit as well as
other charges collectable under the mortgage and for foreclosure and sale of the
mortgaged property. Judgment is entered pursuant to Pa. R.C.P. 1037 for failure
to file an Answer on behalf of Dean P. Kennedy, Jr. and Michelle Kennedy a/k/a
Michelle L. Kennedy to Plaintiff's Complaint within twenty (20) days of service
thereof and after a 10 -day Notice was sent.
Date: December 23, 2014
Respectly bmitted,
arl M. Ledebo , Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I hereby certify that notices of intent to take a default judgment were forwarded to
Dean P. Kennedy, Jr. and to Michelle Kennedy a/k/a Michelle L. Kennedy by United
States Mail, First Class, postage prepaid on December 10, 2014. The aforesaid notices
were each contained within an envelope bearing the return address of the undersigned.
The notice sent to Michelle Kennedy a/k/a Michelle L. Kennedy addressed to 516-C
Range End Road, Dillsburg, PA 17019 has been returned as "no such number, unable to
forward". A copy of the returned envelope is attached hereto and marked Exhibit "A".
The other notices sent to the defendants have not been returned to the undersigned as
undeliverable or otherwise. A copy of the notices and Postal Fo t 3817 are attached
hereto and marked Exhibit "B".
arl M. Ledebohm, Esquire
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
Michelle Kennedy
a/k/a Michelle L. Kennedy
7.A.-7-13,9•0
516 -Ci
DIUSbI
E TURN TO S•EN.DEIZ
L11.1-.A•-aL Z.• - TO (;;R•V•4
sc.; 17 07 001737 B - • 1.`..!-,0 4 1— 10— 40
-1-11411.14-11,1111-41141:141 .
r-
1,1 1-1 IV V la L..
ark
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS l ST FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 14-5595
Vs.
DEAN P. KENNEDY, JR. and : CIVIL ACTION — LAW
MICHELLE KENNEDY afkla
MICHELLE L. KENNEDY
DEFENDANTS : MORTGAGE FORECLOSURE
IMPORTANT NOTICE
Date: December 10, 2014
TO: Dean P. Kennedy, Jr.
263 Carlisle Avenue
Enola, PA 17025
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY
SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE
CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A
DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON
REAL ESTATE.
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 DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
Exhibit "B"
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Date: December 10, 2014
Respectfully submitted,
Karl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
Y.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 14-5595
Vs.
DEAN P. KENNEDY, JR. and : CIVIL ACTION — LAW
MICHELLE KENNEDY a/k/a
MICHELLE L. KENNEDY
DEFENDANTS : MORTGAGE FORECLOSURE
IMPORTANT NOTICE
Date: December 10, 2014
TO: Michelle Kennedy
a/k/a Michelle L. Kennedy
516-C Range End Road
Dillsburg, PA 17019
Michelle Kennedy
a/k/a Michelle L. Kennedy
515-C Range End Road
Dillsburg, PA 17019
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY
SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE
CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A
DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON
REAL ESTATE.
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 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 PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Date: December 10, 2014
Respectful! bmitted,
arl M. L-debohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
UNITED STATES Certificate C
POSTAL SERVICE Maitin,
This form may be used for domestic and international dts4i1
From:
This Certificate of Mailing provides evidence that mail has been presented to USPS® for mailinc7: a 1111_.1
Karl M. Ledebohm, Esq.
P.O. Box 173 -
New Cumberland, PA 17070-017
To:
Dean P. Kennedy, Jr.
263 Carlisle Avenue
Enola, PA 17025
PS Form 3817, April 2007 PSN
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From
To:
_ Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
Michelle Kennedy
a/k/a Michelle L. Kennedy
516-C Range End Road
Dillsburg, PA 17019
PS Form 3817, April 2007 PSN 7530-02-000-9065
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This Certificate of Mailing provides evidence that mail has been presented to USPS® for mailing.
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From:
To:
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
Michelle Kennedy
a/k/a Michelle L. Kennedy
515-C Range End Road
Dillsburg, PA 17019
PS Form 3817, April 2007 PSN 7530-02-000-9065
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 14-5595
Vs.
DEAN P. KENNEDY, JR. and : CIVIL ACTION — LAW
MICHELLE KENNEDY a/k/a
MICHELLE L. KENNEDY
DEFENDANTS : MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned hereby swears and affirms on behalf of Members 1St Federal
Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff s
knowledge Dean P. Kennedy, Jr. and Michelle Kennedy a/k/a Michelle L. Kennedy are
not currently on active military service.
Date: December 231, 2014
Karl M. edebohrn, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
DEAN P. KENNEDY, JR. and
MICHELLE KENNEDY a/k/a
MICHELLE L. KENNEDY
DEFENDANTS
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 14-5595
: CIVIL ACTION — LAW
•
: MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS NOTICE AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE
TO: Dean P. Kennedy, Jr.
263 Carlisle Avenue
Enola, PA 17025
Michelle Kennedy
a/k/a Michelle L. Kennedy
515-C Range End Road
Dillsburg, PA 17019
You are hereby notified that on , 4 2014 the following
judgment has been entered against you in the above captioned case:
Judgment in favor of Members 1St Federal Credit Union, Plaintiff, and against the
Defendants, Dean P. Kennedy, Jr. and Michelle Kennedy a/k/a Michelle L.
Kennedy, in the amount of THIRTY-TWO THOUSAND FIVE HUNDRED
NINETY-FIVE AND 23/100 ($32,595.23) DOLLARS, plus interest at the rate of
$5.6360 per day from December 23, 2014 through the date of judgment and at the
legal rate thereafter until the date of payment, additional attorney's fees and costs
of suit as well as other charges collectable under the mortgage and for foreclosure
and sale of the mortgaged property. Judgment is entered pursuant to Pa. R.C.P.
1037 for failure to file an Answer on behalf of Dean P. Kennedy, Jr. and Michelle
Kennedy a/k/a Michelle L. Kennedy to Plaintiff s Complaint within twenty (20)
days of service thereof and after a 10 -day Notice was sent.
Dated 199
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236
is: Dean P. Kennedy, Jr.
263 Carlisle Avenue
Enola, PA 17025
Michelle Kennedy
a/k/a Michelle L. Kennedy
515-C Range End Road
Dillsburg, PA 17019
A: Dean P. Kennedy, Jr. and Michelle Kennedy a/k/a Michelle L. Kennedy
Por este medio se le esta notificando que el de
2014, el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el
caso mencionado en el epigrafe.
Fecha:
Protonotario
Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado
de residencia:
Dean P. Kennedy, Jr.
263 Carlisle Avenue
Enola, PA 17025
Michelle Kennedy
a/k/a Michelle L. Kennedy
515-C Range End Road
Dillsburg, PA 17019
Dated: December 23, 2014
Respec submitted,
arl M. ede . ohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff