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HomeMy WebLinkAbout14-6137 10/17/2014 FRI 11: 44 FAX X00-2/002 _ . Supreme C i nsylvania COu leas '�t Pr�tll p�rbjiryl 7y hl'• ,.;, CU ,I LA County `,s f,til „iii � I� •J• The information collected on this form is used solely for court administration purposes. This forth does not supplement or replace thefiling and service o leadin s or other papers as required Py law or rules of court. Commencement of Action: t Q Complaint Q Writ of Summons © Petition C) Transfer from Another Jurisdiction © Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: PENNSYLVANIA STATE EMPLOYEES CREDIT UNION RANDY S.ZIMMERMAN yt� Dollar Amount Requested: C)within arbitration limits Are money damages requested? Q Yes No (check one) (Z)outside arbitration limits �V f Is this a Class Action Suit? ❑Yes El No Is this an MDJ'Appeal? O Yes E) No Name of Plaintiff/Appellant's Attorney: SHAWN M_LONG, ESQUIRE Check here if you have no attorney(are a Self-Represented iPro Sel Litigant) >'e Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY WE. If you are malting more than one type of claim,check the one that you consider most important, ly;;ls4'' TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS Intentional Q Buyer Plaintiff Administrative Agencies Q Malicious Prosecution Q Debt Collection:Credit Card C) Board of Assessment `•a ; ,.I Q Motor Vehicle Q Debt Collection:Other © Board of Elections f, tjC+ir,, Nuisance Dept.of Transportation Premises Liability Statutory Appeal:Other Q Product Liability(does not include O Employment Dispute: mass tort) Discrimination © Slander/Libel/Defamation ©Other: © Employment Dispute:Other © Zoning Board [3 Other: M , © Other: a.ry MASS TORT / Asbestos Tobacco E2 Toxic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Y 'i;' Q Toxic Waste ® Ejectment Common Law/Statutory Arbitration Other: © Eminent Domain/Condemnation Q Declaratory Judgment © Ground Rent Mandamus <✓andlordrTenant Dispute 8 Non-Domestic Relations p 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY !�„�:�,�••, [3 Mortgage Foreclosure:Commercial 13 Quo Warranto Dental © Partition E3 Replevin Legal Quiet Title ©Other: Ori ;si © Medical Other: [3 Other Professional: Updated/111241 f CBCT 17 It: ?_ F'E '';5 I'i.VANIA t BARLEYSNYDER Shawn M. Long, Esquire Court I.D.No. 83774 126 E. King Street Lancaster, PA 17602 Attorneys for Plaintiff 717.299.5201 _ Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION—MORTGAGE V. FORECLOSURE RANDY S. ZIMMERMAN, No. Defendant NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this Complaint and Notice are served,by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice to you for any money claimed in the Complaint or for any other claim or relief requested by Plaintiff(s). You may lose money or property or other rights important to you. S �k-� SCoo► 2 a� oLf YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 Effective September 1, 2003 4457272-1 BARLEYSNYDER Shawn M. Long, Esquire Court I.D.No. 83774 126 E. King Street Lancaster, PA 17602 Attorneys for Plaintiff 717.299.5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION—MORTGAGE V. FORECLOSURE RANDY S. ZIMMERMAN, No. Defendant AVISO PARA DEFENDER Conforme a RCP No. 1018,1 del PA LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes,usted debe tomar la accion en el plazo de veinte (20) dias despues de esta queja y el aviso es servido, incorporando un aspecto escrito personalmente o por el abogado y archivando en escribir con la corte sus defensas u objeciones a las demandas dispuestas contra usted. Le advierten que si usted no puede hacer asi que el caso puede proceder sin usted y un juicio se puede incorporar contra usted por la corte sin aviso adicional a usted para cualquier dinero demandado en la queja o para cualquier otra demanda o relevacion pedida por Plaintiff(s). Usted puede perder el dinero o la caracteristica u otra endereza importante a usted. USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A O LLAME POR TELEFONO La OFICINA DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACION SOBRE EMPLEAR A un ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A un ABOGADO, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE LOS SERVICIOS JURIDICOS de la OFERTA de MAYO A LAS PERSONAS ELEGIBLES EN Un HONORARIO REDUCIDO O NINGUN HONORARIO. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 Telephone: (717) 249-3166 Efectivo 1 de Septiembre, 2003 Queja 4457272-1 BARLEY SNYDER Shawn M. Long, Esquire Court I.D.No. 83774 126 E. King Street Lancaster, PA 17602 Attorneys for Plaintiff 717.299.5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION - MORTGAGE V. FORECLOSURE RANDY S. ZIMMERMAN, No. Defendant COMPLAINT 1. Plaintiff, Pennsylvania State Employees Credit Union("PSECU"), is a Pennsylvania financial institution having an office at 1500 Elmerton Avenue, Harrisburg, PA 17110. 2. Defendant, Randy S. Zimmerman, is an adult individual with a last known address of 1017 Swarthmore Road, New Cumberland, Pennsylvania 17070-1730. 3. On or about December 14, 2000, Defendant executed and delivered to PSECU a, Note(the"Note") in the original principal sum of$64,600.00. A true and correct copy of the Note is attached hereto as Exhibit"A" and incorporated herein by reference. 10. On or about July 2, 2013, PHFA denied Defendant's application for assistance. A true and correct copy of the denial is attached hereto,made a part hereof and marked as Exhibit 11. On or about July 11, 2013, Plaintiff received notification that Defendant filed an appeal of the PHFA denial decision. A true and correct copy of the appeal notification is attached hereto, made a part hereof as Exhibit"E". 12. On or about October 18, 2013, Plaintiff received notification that the PHFA denial decision had been affirmed. A true and correct copy of the letter affirming PHFA's denial is attached hereto,made a part hereof as Exhibit"F". 13. Pursuant to the Note, in the event of Default, PSECU may, and hereby does, declare all amounts owed under the Note, including principal, accrued interest, late charges, and all other charges, including reasonable attorneys' fees, to be immediately due and payable. 14. Pursuant to the Note, in the event of Default, PSECU is entitled to be reimbursed for all costs and expenses, including reasonable attorneys' fees incurred in bringing any action to enforce the Note. 15. For purposes of this action, PSECU believes, and therefore avers, that$3,000.00 constitutes reasonable attorneys' fees for enforcing the Note. However, PSECU recognizes that it is restricted by law to those attorneys' fees that are actually incurred. If those fees are less than $3,000.00, PSECU agrees to adjust its demand for attorneys' fees, if applicable, at the time payment on any judgment is made. 4457272-I 16. As of October 1, 2014, the amount due on the Note and the Mortgage is as follows: Principal Balance ....................................................................... $56,147.36 Interest through 10/01/14 at a rate of$12.11 per diem ..................................................... 4,053.17 LateCharges............................................................................... 1,652.16 OtherBank Fees......................................................................... 67.50 Attorneys' Fees.......................................................................... 3,000.00 Total $64,920.19 plus continuing interest after October 1, 2014 at a rate of$12.11 per diem, plus continuing late charges, attorneys' fees and costs. 17. PSECU has demanded payment of the amount owed from Defendant but Defendant has failed and/or has refused to pay the same. 18. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in writing within thirty(30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty(30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant the name and address of the original creditor if different from the above. WHEREFORE, Plaintiff, Pennsylvania State Employees Credit Union demands judgment in mortgage foreclosure against Defendant, Randy S. Zimmerman, in the amount of$64,920.19, plus continuing interest after October 1, 2014 at a rate of$12.11 per diem, plus continuing late 4457272-1 charges, attorneys' fees and costs, and for the foreclosure and sale of the Premises located at 1017 Swarthmore Road, New Cumberland, Pennsylvania. BARLEYS v Date: OCAMnL� 1S 1By: .�` Shawn M. Long, Esquire Attorneys for Plaintiff, Pennsylvania State E loyees Credit Union Court I.D. No. 837 4 126 E. King Street Lancaster, PA 17602 717.299.5201 4457272-1 VERIFICATION PENNSYLVANIA STATE EMPLOYEES CREDIT UNION vs.RANDY S.ZIMMERMAN I, WILLIAM ZYSK, being duly affirmed according to law, depose and say that I am Chief Credit Officer, Credit Services for Pennsylvania State Employees Credit Union; that I am authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. To the extent that any of the averments in the foregoing document are based upon the understanding or application of law, I have relied upon counsel in making this Verification. This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: 4 Willi k EXIHIBIT . "A' , tC-14=2000 16:57 PSECU - t 17177722989 P.05i16 NOTE December 14th, 2000 New Cumberland PA [Data] [City] [3L1ce] 1017 Swarthmore Road New Cumberland, PA 17070 [Property Addmss] . ..a;..,1. BORROWER'S PROMISE TO PAY In return for a loan that I have reeeived,.I promise to pay U-S. $ 64,600.00 (this amount is called v: 'principal"), plus interest, to the order of the Lender. The Lender is Penasylv¢ai¢ State Employees Credit union P.O. Box 67013, Harrisburg, PA 17106-7013 1 understand that the. Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder, INTEREST ' aid. I will Interest will be charged on unpaid principal until the full amount of principal has been p pay interest ataearl =:rate of i 7.87500 ayearly The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. 1 Will make my monthly payments on the lot day of each month beginning on February 01 `2001 I will make these payments every month until I have paid all of the principal and interest and any other eharg4y _:.._ ` { ::described below .that I may owe under this Note, My monthly payments will be applied to interest before principal- If, on Jaauary`,01, 2031 , I still owe amounts under this Notc, I will pay those amounts in full on that date, which is called the "Maturity Date," I will make my monthly paymcrits at P.Q. sox 67 013 Harri'aburg, PA 17106-7013 or at a different place if required by the Note Holder. 0— = �? (B) Amount of Monthly Payments My monthly payment will be in the amount a(U.S. $ 468.39 BORROWER'S RIGHT TO PREPAY I have the right to make`payments of principal at any time before they are due. A payment of principal only is known as a fs prepayment." When I make a prepayment, I will tell the Note Holder in writing that I am doing so. :.: U. . i I,m{ay make a full prepayment or partial prepayments without paying any prepayment charge, The Note Holder will use all 'q of my pr-epayments to reduce the:amount of principal that I owe under this Note. If I make a partied prepayment, there will be no chai;gts in the duo date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. LORI CHARGES Ifj'alaw, which applies to this loan and which sets maximum loan charges, is final] ' g y interpreted so that the interest or other loan charges collected or to'be collected in connection with this loan exceed the permitted )imits, then: (i) any such loan charge shall be reduced by the'amount necessary to reduce the charge to the permitted limit; and ()i) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note I•Iolder may choose to make this refund by reducing the principal I owe under, this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 6, BQ.RROWE1,IR'S F,A7I,jJRE TO PAY AS REQU>;RED tLate Charge for Overdue ��: � Payments If fhe Note Holder has nofreceived the full amount of any monthly payment by the end of 15 calendar days after e date:it is due, I will pay,a laie charge to the Note Holder. The amount of the charge will be 5.00 . % of q my overdue payment of principal and interest. I will pay this late change promptly but only once on each late payment, (H) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be iv default. MULTISTATE FIXED RATE NOT Single Family-FNMAIFHLMC Uniform Instrument -6R i9To51,o4 A.Form 3200 12/83 Amended 5/91 ' VMP MORTGAGE FORMS•(800)621.7291 Pape 1 of 2 lnitiale,;J�JL__ .QEC-14-2000 16:57 PSECU 17177722989 (C)Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that F owe on that amount. That date must be at least 30 days after the date on which the notice is delivered or v-mailed to me. (D)No Waiver by Note Holder " Even if, at a time when I am in default, the Note Holder docs not require me to a q pay immediately in full as described above, the Note Holder will still have the right to do so if T am in default at a later time, (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be liven to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder!a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address, R. OBLIGATIONS OF PERSONS UNDER THIS NOTE If-more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed, Any person who is a guarantor, surety or endorser of this Note is , Y_W,,o obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its .t:''.:....r; ', .1...:....,,,e— ,., rights under this Note against each person individually or against all of us together. This means that any one of us may be __-required to pay all of the amounts owed under this Note. =' 9, WAIVERS I .and any other person who hay obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require the Note Holder to demand payment of unounts'due. "Notice of dishonor" means the P,,,right toixequire the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNUORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In Addition to the protections given to the ote Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date as •,; his`Note, protects the Note Holder from possible losses which might result if I do not keep the promises which 1 make in this :dote: That Security Instrument describes how and under what conditions I may be required to make immediate payment in full , of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. If all or an y part of the.Property or any interest in it is sold or transferred (or if a bmeficial interest in Borrower is sold or transferred and Borrower is not a natural person), without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument, Howcver, this option shall not be exercised ' rt by Lender if exercise is prohibited by federal law as of the date of this Security Instrument, If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall ; p period of not less than 30 provide a _;r�;_�F•-�, days from the date the notice is delivered or mailed within wttiGh r Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without ` further notice or demand on Borrower. WI S THE HA �(S) AND SEAL(5) OF THE UNDERSIGNED. d (Sear- (Seal) �'' �- f swan -Borrower Marion L. Zimmisn -Borrower SSN:201- -02 SSN:19 7-2 0-3 6 94 Z i T << (Seal) (Seal) i.•_..`. , SSN: -Burrower Rormwer [Sign Original Only] -5R (sios).oa Form 3200 12/83 EXHIBIT `B " N�� SPEC-14-2000 16 58 PSECU. 17177722989 P 09/16 �,0! �J - Pa Al . 'L�0 DFC 21 Nq 10 98 Parcel Number: 26-24-0809-279 [Space Above This Gine For Recording Data) MORTGAGE t x. THIS MORTGAGE ("Security Instrument") is given on December 14th, 2000 mortgagor is The Randy S. 2immer>aan `.. _ ("Borrower"). This Security Instrument is given to Pen4eylvania State Employees Credit Union ,.r�..... which is organized and existing under the laws of Pennsylvania address is and whose Sox 67013; Harrisburg, PA ("Lcndcr"), Borrower owes Lender the principal sum or SiXty Four Thousand six Hundred and This debt is evidenced by Borrower's note dated theDoslame( date ai has 64!th' 60 by Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on January 1st, 2031 Security Insrument (a) to the repayment .of the debt evidenced by the Note, wi hh1 nt st, alndtall renewalse9 exLendeA tensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the 90curity of. th}s Security Instrument; and (c) the performance of BQrmwcr's Fovenants and agreements under this Sec irity instrument and the Note. For this Purpose, ,Borrower does hereby mortgage, grant and convey .to Lender the following described property PENNSYLVANIA-Single Family-FNMATHLMC UNIFORM INSTRUMENT �-6R(PA) t000al Form 3039 9/90 ® Amended 6/ t P,ge ar 9 Inirieie; 7j VMP MORTGAGE FORM$ BOOK J659 PAGE 423 ��� 14-�b00 16 58 PSECU J 17177722989 P. 10i16 located in Cumberland SEE ATTAED L>3G County, Pennsylvania: L.. AL DESCRIPTION which has the s address of 1:017 Sw b Pennsylvania I7070. . artl�re Road New C erl�nd lip r..ed�l [senCr Cf TOGETHER ("Property `�]' WITH all easements appurtenances the i-mprovernents now or additions shaSeeove ed fixtures now. hereafter erected on the pro e ' = or hereafter a P rty, and all Security y this Security Instrument. All of the f rr ett ty Instrument as the 'Pro extthep P Y. All replacements and , Proper y ' -_ BORRO o egO'Pg is referred to in this the right WER COVENANTS.that Borrower is lawfully seised of F : to mortgage, graar and conve encumbrances of record. Borrower warrants propertythe estate hereby conveyed claims and demands, s and that the Property is unrrncu Y and.has I:... and will defend generally t mbered except for ub)001 to any encumbrances of record, g nerall the ti le to the Property,r.. -.4.FP Y against all -;; THIS SECURITY INSTRUMENT covenants with limited variations b eomh,nes unifo,,r cnven t P p rty, y jurisdiction to constitute a ani or7r,i.°r national use and non-uniform r� ro e ;,,. r { scetuit instrument covering ' UNIFORM COVENANTS. y 1; real * ' Borrower and `( 1• ymenf of PrMCI and Interest Lender covenant and agree as follows: ' pay when due the prineipai;of and interest st; Prd b F yment and Late Charges. charges due under the Noti; lr Borrower shall promptly t evidenced by the Note and any prepayment and late Z• Funds for Taxes. Borrower shall a and Insurance. Subject to in F Il, -(.-F p Y to Lender on the day monthly applicable law or to a written waiver u a sum ("Funds" Y Payments are due under the. Inst ) for: (a) yearly taxes and assessments which may attain hY Lender, Instrument as a Iien on the Property, (b)Yearly leasehold a Vote, until the Note is paid (c) yearly hazard or prope pay. or ground rents h Property,this Security mortgage insurance.property ansurance premiums; (d) yearly flood insurance pretnfuc th if an :;. with the provisions Dlrcmiums if anY; and if any; are called "Escrow'Itetrsra h (� any sums payable by Borrower to Y, (e) Yearly P 8, m lieu of the payment of mortgage insurance premiums. These maximum am may aC any time, collect and hold Funds in account under°the f d'eral lender for estate settlement mortgage lora, ma r eIll Procedures Act of 1974 as amen arryount not to exceed the U,S.C. Section 2601 et se Y Quirt; for Bvrrowcr' If so, Lender Y (`R!✓SPA" s escrow Y at an ` time, collect unless another law that applies to the Funds ecl sets aT lesser amo Lender ma aria hold Funds i 4, 12 y eftimur- the amount OF Funds due on the basis of current data and real ant expenditures of future Escrow Items or otherwise o acco n an amount not to exceed the lesser amount, rdauce with a unable estimates of -6R(PA) r000sj `� PPlicable law, - Pde?�pr 9 IglgeM; jA Form 3039 9/go PACE A24 DEC-14-2000 16:58 PSECU 17177722989 P.11i16 The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is such an institution) or in,any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items, Lender may 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. However, Lender may require Borrower to pay a one-time charge for an independent real estate tax reporting service used by Lender in connection with this loan, unless applicable law provides otherwise, Vnless an agreement is mark or applicable law rcqu res interest to be paid, Lerida shall not be required to pay Borrower any interest or earnings on the Funds.. Borrower and Lcnder*may 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, showing credits and debits to the Funds and the purpose for which.each debit to ..a, the Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument. 'l'.. If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower for the encess Funds in accordance with the requirements of applicable law, If the amount of the Funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more than twelvemonthly payments, at Lender's sole disccetion- ,� Upon payment in full of all sums-secured by this Security Instrument, Lender shall promptly refund t :. to Borrower any Funds held by Lender_ If, under paragraph 21, Lender shall acquire or sell the Property, 5 Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or-sale as a credit against the sums secured by this Security instrument. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs I and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest due; fourth, to principal due; and last, to any late charges due under the Note. 4. Charges;:Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold i N r payments or ground rents, if an Borrower shall y pay these obligations in the manner provided in th'' rf,4 paragraph 2, or.if not.paid in that manner, Borrower shall pay them on time directly to the person owed payment- Borrower sh;sll promptly furnish to );..ender all notices of amounts to be paid under,this paragraph. If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts = evidencing the payments. Borrower shall promptly discharge any lien'which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the Iien by, or defends against enforcement of the lien in, legal proceedings which;an .the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder.of the lien an.agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender:-detcrrrrines that any part of the Property is subject to a lien which may attain priority " over this Security Instrument, Lcndcr may give Borrower a notice identifying the lien. Borrower shall t:.:. satisfy the lien or:take one or more of the actions set forth above within 10 days of the giving of notice. r2 w• 5. Hazard.or.Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the PrrJperty insured against loss by (•ire, hazards included within the term "extended coverage" and any other hazards, including floods or flooding, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. The insuran:cc carrier providing the.insurance shall be chosen by Borrower subject to Lender's approval which shall not be -SR(PA) t000.a) Page a 01.9 Form 3039 9/90 aeor59 PAGE 425 DEC-14-2000 16:59 PSECU - - - 17177722989 P. 12i16 unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to protect Lender's rigbts in the Property in accordance with paragraph 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender- Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is.not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Seeuriry Instrument, whether or not then duc, with any excess-paid to Borrower. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not then due. The 30-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments: If under paragraph 21 the Property is acquired by Lender, Borrower's right to a any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to`the extent of the sums secured by this Security Instrument immediately prior to the acquisition, b. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall no[ be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair r the Property, allow the Property to deteriorate, or commit waste oil the Property. Borrower shall be. in default if any forfeiture action or proceeding, whether civil or criminal, is begun that in Lender's good "'..faith judgment could result in forfeiture of the Property or otherwise materially impair the lien created by '1=_ tllis.Security Instruttlenror Lender's security interest, Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding to be dismissed with a-ruling that, in Lender's.good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced.by the Notc, including, but not limited to, representations concerning Borrower's occupancy of the Property a5 a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires flet title to the Property, the leasehold and the foe title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Lender's Rights in the Property. If Borrower fails to perform the covenants and agreements contained.in.this Security Instrument, or there is :legal proceeding that may significantly affect Lender's rights`in.the Property (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce:laws or regulations), then Lender may do and pay for whatever is nCccSsary to protect the value:of:.the Property and Lender's rights in the Property- Lender's actions may include paying any sums secured.by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attorneys':fees and entering on the Property to make repairs. Although Lender may take action under this paragraph:?,.Lender does not have to do so initials: dM-6R(PA) (000m(:..; Pepe q or s Form 3039 9/90 BDOKi659FACE 426 l5 C=14-2000 16:59 PSECU 17177722989 P. 13i16 Z. Any amounts disbursed by Lender under tbis paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of paymetlt, thecc amounts shall bear interest from the date of disbursement at the Note.rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. S. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan t' secured by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect.- If, for any reason, the mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance previously in effect at a cost substantially equivalent to the cost to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. If substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Lender each A. month a sum equal to one-twelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in effect. Lender will aceopt, use and retain these payments as a loss reserve:in lieu of mottgagc insurance, Loss reserve payments may no longer be required, at the option of Lender' amount ane perLender re if mortgage insurance coverage (in the amt d for the that Ld requires) ) •' _::r,. provided by an insurer approved by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the * -> n requirement for mortgage insurance ends in accordance with any written agreement between Borrower and } t Lender or applicable law, :kms lf?' 9. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property, zf, � Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10, Condemn4tion. The proceeds of any award or claim for damages, direct or consequential, in connection with.any,condemnation or other taking of any part of the Property, or fvr conveyaa�ee in lieu of condemnation,:are:hereby assigned and shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument; whether or not then due, with any excess paid to Borrower, In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal '- to or greater than..the amount of the sums secured by this Sceurity Instrument immediately before the x:: :; . ,. ."S taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security : •. Instrument Shall;bc.reduced by the amount of the proceeds multiplied by the following fraction (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial k Y taking of the Profte y.in which the fair market value of the Property immediately before the taking is less ' than the amount of the sums secured immediate) before the taking, unless Borrower and Lender otherwise ` agree in writing or-unless applicable law otherwise provides, the proceeds shall be applied to the sums s: secured by this Security Instrument whcthcr or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the ;'. condemnor vfferg io.make an award or settle a claim for damages, Borrower fails to respond to Lender A7 g P within 30 days after the date the notice is given, Lcnder is authorized to collect and apply the proceeds, at its option, caller to restoration or repair of the Property or to the sums secured by this Security Instrument, "a ,... whether or not.their due. ' Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall `.' not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change `: ;. the amount o'f°such payments. n 5 -6R(PA) (=5) Page 5 of 9 Form 3039 9/90 BOO 659 PAGE 427 DEC-14-2000 17100 PSECU 17177722989 P. 14i16 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower qr . , Borrower's successors in interest, Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the suras rument by reason of any demand made by the original Borrower or Borrower's secured by this Security Inst successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12, Successors and Assigns Bound; Joint and Se verAl Liability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and t Borrower, subject .to the provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note,. (a) is co-signing this Stcurity Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to. extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent, 13, Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets mom. maximum loan charges, and that law is finally interpreted so that the int Tek or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; anti (b) any sums already.collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose .to make this refund by reducing the principal awed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note. 14. Notice-4—Any notice to Borrower provided for in this Security instrument shall be given by delivering it or.by mailing it by first class mail unless applicable law requires use of another method, The notice shall b.c directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to.Lender shall be given by first class mail to Lender's address stated herein Or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument La441 _ shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. _. 15. Governing .Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or,clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Now which can be given effect without the conflicting provision_ To this end.the provisions of this Security Instrument and the Note are declared to be severable, 16, Borrpwer's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instmment. ;. 17. Transfer'of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it.is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a..naturaP4l r.son) without Lender's prior written consent, Lender may, at its option, g" ,„ > require immediate.payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Sccurit :.: ;. Instrument. , IIIiiIAI6; m -6R(PA) Pop 0 of 9 Form 3039 9/90 BOOK J659 PAGE 428 :y DEC-14;=2000 17 00 PSECU 17177722989 P. 15i16 wi If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security lnsLra nent without further notice or demand on Borrower. 18. Borrower's Rigbt to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of Ibis Security Instrument discontinued at any time prior to the earlier of: (a) S days (or such other period as applicable law may .specify for reinstatement) before sale .of the Property VL pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would . L be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default otany other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takessuch action as Lender may 5 reasonably require to 'assure that the lien of this Security Instrument, Lender's rights in the Property and 777 Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under'paragraph 17. V 19, Sale of Note;,Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may ` result in a change in}the entity (known as the "Loan Servicer") that collects monthly payments due under the Note and ;this `Security Instiumenl. There also may be one or more changes of the Loan Servicer unrelated to a`sale'of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change:in accordance with paragraph 14 above and applicable law. The notice will state the .name and address of the new Loan Servicer and the address to which payments should be made. The notice V;). -will 4lsQ contain any other information required by applicable law. 20. Hazardous Substances, Borrower shall not cause or permit the presence, use, disposal, storage, _ or release of any1"Iazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything.affecting the Property that is in violation of any Environmental Law. The preceding s two sentences shall not. apply tq the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to. s 3 r maintenpoe ofthe Rrolierty, �- Borrower shall' rotnptly give Lender written notice of arty investigation, claim, demand, lawsuit or other action'by.:any-govetnmental or regulatory agency or private party involving the Property.and any t� Hazardous Substance°or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is nptified:by any`governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in:-accordance with Environmental Law, As used in:.this ara rah 20 "Hazardous Substances" are those substances defined as toxic or p g P , hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other t flammable or oue petroleum products, toxic pesticides and herbicides, volatile solvents, materials ;. containing asbestos:*:of formaldehyde, _and radioactive materials. As used in this paragraph 20, "Environmental LaW" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safetyor environmental protection. •fiRlPA1 cows) Pope 7 of 9 Form 3039 9/90 aooK.E59PAGE 429 DEC-14-2000 17 01 PSECU 17177722989 P. 16i16 NON-UNIFORM COVF-HANTS, Borrower and Lender further covenant and agree as follows: 21. Acceleration; Remedies, Lender shall give notice to Borrower prior to acceleration- following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 17 unless applicable law provides ptherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in - acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate.after acceleration >: and the right to .assert in the foreclosure proceeding the non-existence of a default or any other _defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender, . , at its option, may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 21, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by applicable law. 22. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void, After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 23. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defeats in proceedings to enforce this Security Instrument, and hurcby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, 't` = and homestead exemption: 24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to die Property, this Security Instrument shall be a purchase.money mortgage. Y'! 26, Inter"t .Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note, ok 27. Riders tothis Security Instrument, If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into, and shall amend and supplement the covenants and agreements of this Security yz:5- Instrument as if clic rider(s)were a part of this Security Instrument_ [Check applicable box(es)] F7 Adjustable Rate Ridcrr Q Condominium Rider 1A Family Rider Graduated Payment Rider E:1 Planned Unit Development Ridcr ❑ Biweekly Payment Rider ❑ Balloon Rider' ❑Rate Improvement Rider 0 Second Home Rider 0 VA Rider ® Other(s) [specify] Legal Description, I=-6R(PA) t000sf Paue'a of 9 Form 3039 9/90 BOOK1659PAGE 430 BY SIGNING BELOW, Borrower accepts and agrees to the terms and venants contained in this Security Instrument and in any-rider(s) executed by Borrower d corded Witnesses: -/ (Seal) R dy S. Z mme /an -Borrower 5 U (Seal) V ' -Borrower (Seal) (Seal) . -Borrower -Borrower Certificate of Residence I, Michael Cocciardi , do hereby certify that the correct address of the within-named Mortgagee is 1 Credit Union Place, Harrisburg, PA Witness my hand this 12th day of December 000 Michael Cocciardi Agent of Mortgagee COMMONWEALTH OF PENNSYLVANIA, C �I t ,. County ss: On this, the \ day of 10C)o , before me, the undersigned officer, n /personally appeared Randy S. Zimmerman known to me (or satisfactorily proven) to be the person whose name t 5 subscribed to the within instrument and acknowledged that �— executed the same for the purposes herein contained.. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: NOTARIAL•SEAL t JODY GOLDRING, Notary Public V.Osburg, Dauphin.County PA N i5.►)►t111SSIDR >� f$;,Nov(13;2W1 Tide of Officer v,. F 4, K -6R(PA) (000s! Page s of 9 Forth 3039s 9/90 � ""' BOOK 1659 PAGE 431 Description ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of New Cumberland, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING ata point on the northerly line of Swarthmore Road at the dividing line between Lots. Nos. 19 and 20, Block "A" on the hereinafter mentioned Plan of Lots; thence northeastwardly along the westerly line of Lot No. 20, Block "A"on the hereinafter mentioned Plan of Lots, one hundred forty-three and seventy-seven one-hundredths (143.77) feet to a point; thence south eighty-nine degrees forty-three minutes west(S 89° 43' W along the lands formerly of Elmer E. Zimmerman one hundred fifteen and forty-six one-hundredths (115.46) feet to a point; thence southwardly along the easterly line of Lot No. 18, Block "A" one hundred nine and eighteen one-hundredths (109.18) feet to a point on the northerly line of Swarthmore Road; thence along the latter line eastwardly by a curve to the right having a radius of three hundred five (305) feet and an arc distance of sixty-five (65) feet to a point, the Place of BEGINNING. BEING Lot No. 19, Block "A" on the Plan of Lots of Section'! of Highland Park Hills and Drexel Hills, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 7, Page 23. HAVING THEREON erected a brick and frame dwelling house known as 1017 Swarthmore. Road, New Cumberland, Pennsylvania. SUBJECT to restrictions and conditions as contained in prior deeds. BEING THE SAME premises which Samuel E. Jamieson, by his deed dated the 7 'clay of 2000 and to be recorded simultaneously herewith, granted and conveyed unto Randy S. Zimmerman, an adult individual and Marion L. Zimmerman, an adult individual, MORTGAGOR herein. B00K j65U PAGE 432 EXHIBIT " C " PSEC(ii April 8, 2013 RANDY ZINUMIERMAN 1017 SWARTHMORE RD NEW CUMBERLAND,PA 17070 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 (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME: RANDY ZEMMERMAN ADDRESS: 1017 SWARTHMORE RD NEW CUMBERLAND, PA 17070 . LOAN ACCT. NO.: 6767 ORIGINAL LENDER: PSECU CURRENT LENDER/SERVICER: PSECU 1 CREDIT UNION PLACE, HARRISBURG, PA 171 10-2990 800.237.7328 >>psecu.com 2459591-1 THIS CREDIT UNION IS FEDERALLY INSURED BY THE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. HOMEOWNER'S EMERGEN SISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later,in this Notice (see"following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure.action, your Iapplication 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." 1 CREDIT UNION PLACE, HARRISBURG, PA 1 71 10-2990 800.237.7328 >>psecu.com 2459591-1 THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. PSECC 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. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT: The MORTGAGE debt held by the above lender on your property located at: 1017 SWARTHMORE RD, NEW CUMBERLAND, PA 17070 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: You are past due November 2012 thru April 2013 payments Principal = $726.49 Interest = $2,267.39 Escrow = $1,607.79 and Late Fees = $ 367.46 Other charges = TOTAL AMOUNT PAST DUE _ $4,969.13 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 $4,96913 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: Pennsylvania State Employees Credit Union (PSECU) PO Box 67013 Harrisburg PA 17106-7013 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: 1 CREDIT UNION PLACE, HARRISBURG, PA 1 71 10-2990 800.237.7328 >>psecu.com THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. PSECO Make a payment of the total past due amount of$4,969.13 to re-instate your loan. IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up.to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable Attorneys' fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by . contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Pennsylvania State Employees Credit Union (PSECU) Address: P O Box 67013 Harrisburg, PA 17106-7013 Phone Number: 800-237-7328 X3120 Fax Number: 717-772-2273 Contact Person: Mary Whipple E-Mail Address: mwhipple(a).psecu.com 1 CREDIT UNION PLACE, HARRISBURG, PA 171 10-2990 800.237.7328 >>psecu.com 2459591-1 THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. SE(C' EFFECT OF SHERIFF'S SALE--You ou Sheriffs Sale-will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You may or 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. 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. Sincerely Mary W i ple Accoun Advisor 1 CREDIT UNION PLACE, HARRISBURG, PA 171 10-2990 800.237.7328 >>psecu.com 2459591-1 THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. HEMAP Con m it ling Agencies CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND County Report last updated:09/20/2012 03:40 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 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 1 CREDIT UNION PLACE, HARRISBURG, PA 171 10-2990 800.237.7328 >>psecuxom 2459591-1 THIS CREDIT UNION 15 FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. N DER:'COMPLETE TMIS SECTION CONIPCETE.THIS SECTION ON DELIVERY-SE . . : : _ : . • -. . _ _ • = _ ' Postal ServiceTM �. " . _ `•: .._ .. 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N FOnYYs-hOINy 0 A�(v'R.e�S —„ G Or�DEq EXPIRED CD NOT KNOWN --CLAIMED 4:. AJC SJ^ L1 REFJ�ED 1 REET NO SUCH NUMQER , INS IJFFiC;_r-NT � ADDRESS - t RANDY ZUVEWE .. 1017S RE RD ;:. NEW C RLAND,PA 170 f Wf RECE1 'i' 1 / COMPLETE THIS SECTION ON DELIVERY A, signature 1 d ■ Complete Items 1,2,and 3.Also complete X 0 Addressee 1 i Item 4 If Restricted Delivery is desired. 1 ■ Print your name and address on the reverse C.Date of Delivery 11 -• 1 so that we can return the card to you. B. Received by(Printed Name) ■ Attach this card to the back of the malipiece 0 Yes or on the front if space permits. D. Is delivery address different from Item 1? 0 No 1 1.:Article Addressed to: If YES,enter delivery address below: BRAND MERT -SWAR RE RD 017 3. service Type 11�N EW C U PA' 1 - [3 cem'ed Mail o Exp=s Mall f ipt for Merchandise ❑Registered 0 Return Rece ❑Insured Mail ❑C.O.D. l 4. Restricted Delivery?(Exna Fee) E3 Yes I I 11 I 3946 2. Article Number 7 012 2 210 0001 2222 I I (►iansfer from service label) 102595.02-M-1540 2004 Domestic Return Recelpt i PS Form 3811,February py 11,92 - ._ J I KP',mavj,,,,..2•Y.:ktd' PSEC(ii April 8, 2013 RANDY ZD&AERMAN 1017 S WARTHMORE RD NEW CUMBERLAND,PA 17070 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 (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME: RANDY ZIlVIlV ERMAN ADDRESS: 1017 SWARTHMORE RD NEW CUMBERLAND, PA 17070 LOAN ACCT. NO.: 6757 ORIGINAL LENDER: PSECU CURRENT LENDER/SERVICER: PSECU 1 ,CREDIT UNION PLACE, HARRISBURG, PA 171 10-2990 800.237.7328 >>psecu.com THIS CREDIT UNION IS FEDERALLY INSURED BY THE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. HOMEOWNER'S EMERGEN SISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE.-IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." 1 CREDIT UNION PLACE, HARRISBURG, PA 171 10-2990 800.237.7328 >>psecu.com 2459591-1 THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. t P S E CC& 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. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency-under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT: The MORTGAGE debt held by the above lender on your property located at: 1017 SWARTHMORE RD, NEW CUMBERLAND, PA 17070 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: You are past due November 2012 thru April 2013 payments Principal = $726.49 Interest = $2,267.39 Escrow.= $1,607.79 and Late Fees = $ 367.46 Other charges = TOTAL AMOUNT PAST DUE _ $4,969.13 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 $4,969.13 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: Pennsylvania State Employees Credit Union (PSECU) PO Box 67013 Harrisburg, PA 17106-7013 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: 7 1 CREDIT UNION PLACE, HARRISBURG, PA 171 10-2990 800.237.7328 >>psecu.com 2459591-1 THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. PSECO Make a payment of the total past due amount of$4,969.13 to re-instate your loan. IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable Attorneys' fees actually incurred by the lender even'if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Pennsylvania State Employees Credit Union (PSECU) Address: P O Box 67013 Harrisburg, PA 17106-7013 Phone Number: 800-237-7328 X3120 Fax Number: 717-772-2273 Contact Person: Mary Whipple E-Mail Address: mwhippleapsecu.com- 1 CREDIT UNION PLACE, HARRISBURG, PA 1 71 10-2990 800.237.7328 >>psecu.com 2459591-1 - THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. EFFECT OF SHERIFF'S SALE--You ou Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You may or 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. 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. Sincerely MaryWrAAdvisor le Accoun 1 CREDIT UNION PLACE, HARRISBURG, PA. 171 10-2990 800.237.7328 >>psecu.com 2459591-1 THIS CREDIT UNION IS FEDERALLY INSURED BY THE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. HEMAP Con m it ling Agencies CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND County Report last updated:09/20/2012 03:40 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 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 1 CREDIT UNION PLACE, HARRISBURG, PA 1 7110-2990 800.237.7328 >>psecuxom THIS CREDIT UNION IS FEDERALLY INSURED BYTHE NATIONAL CREDIT UNION ADMINISTRATION.EQUAL OPPORTUNITY LENDER. 11-GNF ADV-0722 7111 EXHIBIT "D " Jun. 18. 2014 1 , 31PH, No, 5559 P. 3 ' rennsylvanla Homeowners'Emergency Housing Finance Agency Mortgage Assistance Loan ftg ram Pa tnents 211 North Front Street P,0.Box 15206 Harrisburg,PA 17105-5206 Cnrrespondenc : 211 North F onr,street, P.O.Box 15530 Harrlshurg,PA 1 71 05-553 0 (717) 780-3940 1-800-342-2397 TAX(717)780-3995 77Y(717) 7804869 7/02/2013 PSECU PO BOX 67013 SUBJECT: HARRISBURG, PA 17106 RANDY S. ZIMMERMAN 1017 SWARTHMORE RD NEW CUMBERLAND, PA 17070-1730 HEMAP Account#: HE0002768463 Loan#: 67571200 Your application for a HEMAP loan has been DENIED pursuant to Act 91 of 1983, 35 P,S. Section 1680.401-0 et seq, and/or Agency Guidellnes 12 PA Code Section 31.201 et seq. for the following reasons: DELETED IN LENDER'S COPY EXHIBIT "E " Jun, 18. 2014 1 :31PM Nn, 5550 P. 4 Pennsylvania 'JUL 19 2013 Rom eowne7rs Emergency Housing Finance Agency Mortgage Assistance Loan Progranr� 211 North Front Street,P.U.Pox 15628 Harrisburg,PA 17105-5628 (717) 780-3957 1-800-392-2397 F,9 .(717) 780-9031 17T(717) 780-1869 July 11,2013 PSECU PO BOK 67013 HARRISBURG, PA 17106 Dear Lender: Be advised that the Pennsylvania Housing Finance Agency is in receipt of an administrative appeal filed from the denial of mortgage assistance in accordance with Act 91, as amended, for the account listed below: Date of Receipt: 7/11/2013 RANDY S. ZIMMERMAN 1017 SWARTHMORE RD NEW CUMBERLAND, PA 17070-1730 Bank Loan#: 67571200 HEMAP Account # HE0002768463 PENNSYLVANIA HOUSING FINANCE AGENCY Homeowners' Emergency Mortgage Assistance Program hpapinfoldtmdocs/HEMAP/ EXHIBIT "F" Jun, 1$. 2014 1 . 31PM No. 5559 P. 2 PENNSYLVANIA HOUSWG FINANCE AGENCY Homeowners' Emergency Mortgage Assistance Program 211 North Front Street P.O.Box 15628 Hairisburg,PA 17105-5625 (717)780-3957 TIED#For Hearing Impaired(7 17)780-1569 October 18,2013 PSECU P.O. BOX 67013 HARRISBURG,PA 17.106 OCT 2 1 2013 Re: Randy Zimmerman Account 467571200 1017 Swarthmore Road New Cumberland,PA 17070-1730 TO WHOM IT MAY CONCERN: Please be advised that an independent review from the Decision of the Pennsylvania Housing Finance Agency denying assistance under the Homeowners' Emergency Mortgage Assistance Program for the abovenamed Applicant(s) has been decided as follows: The decision of the Agency has been affirmed and the mortgage assistance loan is denied. Sincerely, Pamela Fisher Hearing Examiner w 'l PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION—MORTGAGE V. FORECLOSURE JCivil RANDY S. ZIMMERMAN, ' Defendant r; F� =' 1 `A Ir NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First,within twenty(20) days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative,at no charge to you. Once you have been appointed a legal representative,you must promptly meet with the legal representative within twenty(20) days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. 4360247-1 Respectfully submitted: Date Attorney Name 4360247-1 a y 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: CUSTOMERIPRIMARY APPLICATION Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes❑ No❑ Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied: Yes❑ No❑ Mailing Address(if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? • BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes❑ No❑ if yes, provide names, location of court,case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1:Model: Year: Amount owed: Value: Automobile#2:Model: Year: Amount owed: Value: Other transportation(automobiles, boats,motorcycles): Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description(not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently payins) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payment(s) Condo/Neigh.Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other Prop.Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes❑ No❑ if yes, please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: r , Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed F i PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION—MORTGAGE V. FORECLOSURE RANDY S. ZIMMERMAN, Civil Defendant REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date 4360247-1 ,r PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CIVIL ACTION—MORTGAGE V. FORECLOSURE RANDY S. ZIMMERMAN, Civil Defendant CASE MANAGEMENT ORDER AND NOW,this day of , 2013,the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at_. M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21)days prior to the date of the Conciliation Conference,the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2)which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the 4360247-1 case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference.The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference,the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. 4360247-1 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Oi 'LJI11.7'y._ 0 i I I i L P R O T H O N C OFFICE OF"• H: .H.RIF1-' 2014 NOV -3 Ph 3' 55 ERCU Pg NNSYLVAN COUNTY i Y Pennsylvania State Employees Credit Union vs. Randy S Zimmerman Case Number 2014-6137 SHERIFF'S RETURN OF SERVICE 10/22/2014 12:14 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Randy S Zimmerman at 1017 Swarthmore Road, New Cumberland Borough, New Cumberland, PA 17070. CHRISTOP I R SHARPE, DEPUTY SHERIFF COST: $47.21 SO ANSWERS, October 23, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuito Shsrft, Tel .()soft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - MORTAGE FORECLOSURE Plaintiff Pennsylvania State Employees Credit Union: VS. Defendant Randy S. Zimmerman: ANSWER 1. ADMITTED, 2. ADMITTED. 3. ADMITTED IN PART AND DENIED IN PART. ADMITTED IN PART on or about December 14, 2000 defendant executed a note to PSECU. DENIED IN PART defendant didn't deliver note to PSECU on or about December 14, 2000 in the original sum of $64,600. 4. ADMITTED. 5. ADMITTED IN PART DENIED IN PART. ADMI 1 1ED IN PART The Note is written requires Defendant to pay late charge of 5% DENIED IN PART Randy S. Zimmerman was told by Bonnie Browtowski (not sure of spelling of Browtowski)) fees will be waived, 6. ADMITTED IN PART DENIED IN PART. ADMITTED IN PART the description of Premises, Exhibit "B" BOOK 1659 PAGE 432 copy attached with complaint, Premises Being The Same premises which Samuel E. Jamieson, by his deed dated the 14th of December, 2000. DENIED IN PART The Same premises which Samuel E. Jamieson, by his deed dated the 14th of No.14-6137 Ci rn rn cn r - CD -ED (":‘? CD December, 2000 is written as such in Exhibit `B', however the deed was altered to the name of Samuel E. Jamieson. 7. DENIED. Defendant disagrees with calculations and plaintiff has not attached anything to the complaint to prove the allegation is true. 8. DENID. Paragraph 8 makes reference to ACT 91 NOTICE being sent in regards to Mortgage Foreclosure No. 14-6137 Civil. 9. ADMITTED 10. ADMITTED 11. ADMITTED 12. ADM' 1'ED IN PART that PHFA denial decision had been affirmed. DENIED IN PART that PHFA denial decision was affirmed in regards to the civil complaint No 14-6137. 13. DENIED. Disagree with calculations. 14. ADMITTED IN PART AND DENIED IN PART. ADMITTED IN PART states in paragraph 14 pursuant to note. DENIED IN PART. Action to enforce note must be within parameter of the law. 15. I am without knowledge or information sufficient to form a belief as to the truth of paragraph 15, which is therefore denied. 16. DENIED. Defendant disagrees with PSECU calculations and plaintiff has not attached anything to the complaint to prove the allegation is true. 17. DENIED. Defendant disagrees with PSECU calculations and plaintiff has not attached anything to the complaint to prove the allegation is true. 18. I am without knowledge or information sufficient to form a belief as to the truth of paragraph 18, which is therefore denied WHEREFORE, Defendant Randy S. Zimmerman request that the following relief be granted. 1. Dismissing the complaint. 2. Award fees that were to be waived. 3. Award monthly mortgage payments paid from June 2013. 4. Granting such other, further and different relief as to this Court may deem just, equitable and proper. Respectfully Submitted, Randy Zimmerm 1017 Swarthmore Road, New Cumberland, Pennsylvania 17070 Date (j1/ /3 , Zd% . I verify that the statements made in this Answer are true and correct. I understand that false statements herein are made subject to the penalties of 19 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /Op'/3(-z&/ft Date IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Plaintiff vs. RANDY S. ZIMMERMAN Defendant No. 14-6137 CIVIL CERHF'ICATE OF SERVICE ZeimoitA,--J)efendant, hereby certify that I served a true and correct copy of th Answer in the above matter on 0 , 2014, by first class mail, postage prepaid, to the following: Name: Shawn M. Long, Esquire Attorney for Plaintiff Address: Shawn M. Long, Esquire 126 E. King Street Lancaster, Pennsylvania 17602 Date