HomeMy WebLinkAbout14-6227 Supreme Court of Pennsylvania
Court t f Comm, n Pleas
11,\ V_% For Prothonotary Use Only.
vil,�C6vekt, li'eet
Cumbe land'.�: County Docket No:
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the fiting and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
9 Complaint 1:1 Writ of Summons ❑ Petition El Notice of Appeal
S El Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T Members 1 st Federal Credit Union John F. Crone& Bobbie Jean Crone a/k/a Bobbie J. Crone
1 0 Check here if you are a Self-Represented (Pro Se)Litigant
0 Name of Plaintiff/Appellant's Attorney: Kari M.Ledebohm,Esq.
N Are money damages requested?: OYes, 11 No Dollar Amount Requested: within arbitration limits
(Check one) N/A outside arbitration limits
A
Is this a Class Action Suit? 13 Yes N No
Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim,check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CML APPEALS
❑ Intentional 0 Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution 11 Debt Collection:Credit Card ❑ Board of Assessment
❑ Motor Vehicle 11 Debt Collection:Other ❑ Board of Elections
❑ Nuisance ❑ Dept.of Transportation
❑ Premises Liability ❑ Zoning Board
S ❑ Product Liability(does not include ❑11 Employment Dispute: Statutory Appeal:Other
E mass tort) Discrimination
D Slander/Libel/Defamation
C 0 Other: 11 Employment Dispute:Other
Judicial Appeals
T MDJ-Landlord/Tenant
1 0 Other: ❑ MDJ-Money Judgment
o MASS TORT ❑ Other:
El Asbestos
N ❑ Tobacco
❑ Toxic Tort-DES
❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment 11 Common Law/Statutory Arbitration
B 0 Other: ❑ Eminent Domain/Condemnation 0 Declaratory Judgment
0 Ground Rent D Mandamus
El Landlord/Tenant Dispute 11 Non-Domestic Relations
0 Mortgage Foreclosure Restraining Order
PROFESSIONAL LIABLITY 11 Partition 11 Quo Warranto
0 Dental 0 Quiet Title 0 Replevin
11 Legal
0 Medical 11 Other: 11 Other:
11 Other Professional:
Pa.R.C.P.205.5 212010
r
43
Karl A Ledebohm,Esquire (11,
FV
P.O.Box 173 r L . "t D
New Cumberland,PA 17070-0173
(717)938-6929
MEMBERS 11T FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF :
Vs. NO.: I ( /�-0 ;L-� U
JOHN F. CRONE and
BOBBIE JEAN CRONE a/k/a
BOBBIE J. CRONE CIVIL ACTION-LAW
DEFENDANTS MORTGAGE FORECLOSURE
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action 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 for
any money claimed in the Complaint or for any other claims or relief requested by the
Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO C113 )
FEE.
ow i v I I.<-), 7S
C (Lo aa�s
epW— 1�
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013
(717)249-3166 OR(800)990-9108
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes,usted tiene viente(20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus objectiones a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA LISTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE O CONOCES UN ABOGADO,VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013
(717)249-3166 OR(800)990-9108
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C.
SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE THE
VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30)
DAYS OF THE RECEIPT OF THIS NOTICE, COUNSEL FOR PLAINTIFF WILL
ASSUME THE DEBT TO BE VALID.
IF DEFENDANT(S)NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WITHIN
THIRTY(30)DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN
VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S)PROVIDE
COUNSEL FOR PLAINTIFF WITH A WRITTEN REQUEST WITHIN THIRTY(30)
DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND
DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF
DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY
(30)DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING
YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT
YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT
TIME. FURTHERMORE,NO REQUEST WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY(30)DAYS AFTER YOU
HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF
THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR
WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT
OF THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS
(THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE
MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS
IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND/OR RECEIVED A DISCHARGE, THIS
IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A
LIEN ON REAL ESTATE.
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS IST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
JOHN F. CRONE and
BOBBIE JEAN CRONE A/K/A
BOBBIE J. CRONE
DEFENDANT(S) : CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
COMPLAINT
1
fi
AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1. Plaintiff, Members 1St Federal Credit Union("Members 1st"), is a National Federal
Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA
17055.
2. John F. Crone and Bobbie Jean Crone a/k/a Bobbie J. Crone (collectively herein
"Defendants"), are adult individuals having a last known address of 7407 Wertzville
Road Carlisle, PA 17015 (formerly 17013).
3. On or about May 23, 2013, Defendants borrowed from and agreed to repay to
Members 1St $50,000.00 (the "Loan"). The Loan is evidenced by a Closed-End Note,
Disclosure, Loan and Security Agreement dated May 23, 2013 (the "Note") executed
and delivered to Members 1St by Defendants. A copy of the Note is attached hereto as
Exhibit"A" and made part hereof.
4. As security for the Loan, Defendants executed and delivered to Members 1"a
mortgage ("Mortgage") also dated May 23, 2013, on all that certain real estate and
improvements erected thereon situate in Middlesex Township, Cumberland County,
Pennsylvania known and numbered as 7407 Wertzville Road Carlisle, PA 17015
(formerly 17013) (the "Property"). At all times relevant hereto, Defendant, Bobbie
2
Jean Crone, has been and continues to be the record and sole owner of the Property. A
description of the Property is attached hereto as Exhibit `B" and made part hereof.
5. The Mortgage and the Note as well as all other exhibits attached to this complaint
have been redacted to remove non-public private information including account
number and social security numbers as required by applicable law.
6. On or about June 21, 2013,the Mortgage was recorded in the Cumberland County
Recorder of Deeds Office at Instrument Number: 201320395. A true and correct copy
of the Mortgage is attached hereto as Exhibit"C" and made part hereof.
7. The Note and the Mortgage have never been assigned by Members 1 st and remain
held by it as a valid and subsisting obligation of Defendants.
8. Defendants obligations under the Mortgage and the Note are in default for failure to
make the monthly payments of principal and interest due to Plaintiff as set forth in the
Note in the amount of$373.38 each for April 27, 2014 through September 27, 2014,
as more particularly set forth and described, in part, in the Act 91 Notice attached
hereto as Exhibit"D" and made part hereof.
9. Members 1 st gave written notice of its intent to foreclose Pursuant to the Act of
January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. seq., and in particular
section 403 thereof, and of Defendants' rights in accordance with the Homeowners'
Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35
P.S. Section 1680.401(c), et. seq., by letter dated July 14, 2014, addressed to
Defendants at the Defendants' last known address set forth in paragraph 2, being the
3
Property, via certified mail, return receipt requested. A copy of the said notice (the
"Act Notice") is attached hereto as Exhibit"D" and made part hereof.
10. Simultaneously, Members 1St forwarded to Defendants the same Notices and
addressed to Defendants at the same addresses as set forth in paragraph 9 by United
States mail, first class, postage prepaid, bearing the return address of Members 1St
The Notices forwarded in said manner have not been returned to the offices of
Members 1St as undeliverable or otherwise.
11. Since the date of the Act Notice, Members 1 st received and applied the following
partial payments to the account evidenced by the Mortgage without waiver of any
demand for all amounts due: $200.00 on 8/6/2014 and $440.00 on 8/14/14.
12. At no time since the date of the Act Notices has the account evidenced by the
Mortgage been brought current.
13. As of the date hereof, Defendants are indebted to Members 1St under the Mortgage
for the following amounts:
a. Outstanding principal $48,491.17
b. Interest to October 24, 2014 465.92
c. Late charges 37.34
d. Attorney fees and expenses 803.50
e. Total due to Members 1St $49,797.93
together with additional interest, additional legal fees and expenses and costs of suit
as well as all other costs and charges collectable under the Mortgage, the Note and
4
applicable law. Plaintiff reserves the right to file a motion in the above captioned
matter to add the forgoing additional amounts to the above itemized amounts due and
owing under the Mortgage.
14. Defendants also agreed under the terms and conditions of the Mortgage that in the
event of default there under Defendants would pay, in addition to the amounts set
forth in paragraph 13 above, costs incurred by Members 1St as a result of the
institution of these legal proceedings.
15. The obligation owed to Members 1St on the Mortgage continues to accrue interest at
the rate of$5.5001 per day, through the date of payment.
16. Members 1St is not seeking a judgment of personal liability (or an in personam
judgment) against Defendant(s); however, Members 1St reserves the right to bring a
separate action to establish that right, if such right exists. If one or more of
Defendant(s)have received a discharge of personal liability in a bankruptcy
proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such
personal liability discharged in bankruptcy, but only to foreclose the mortgage and
sell the Property in accordance with Pennsylvania law.
17. As set forth above, Members 1 st has made demand upon Defendants to pay to
Members 1 st the amounts due under the Mortgage and the Note. However, as of the
date hereof, Defendants continue to refuse and fail to make payment of such amounts
to Members 1St
5
WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment, IN
REM, against Defendants, John F. Crone and Bobbie Jean Crone a/k/a Bobbie J. Crone, in
the amount of FORTY-NINE THOUSAND SEVEN HUNDRED NINTY-SEVEN AND 93/100
($49,797.93) DOLLARS plus interest at the rate of$5.5001 per day, through the date of entry of
judgment on this complaint and at the legal rate thereafter through the date of payment,
additional legal fees and costs of suit as well as other costs and charges collectable under the
Mortgage and for foreclosure and sale of the mortgaged property.
Respectfully submitted,
Date:
/ Karl M. Ledebohm, Esq.
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
6
CLOSED-END NOTE,DISCLOSURE,
1St Q )Z,$FTLIRITV A(':RFT
gORRNFC CRONE ADDRESS
6000 LOUIBe Drive,P.O.BqK 40 JOHN F CRONE
Mechanicsburg,PA 17066 Qt7 TZVILLE RD y
MUIBERS I' MOUNT NUMB R
Ital•Aarart
s�Ars�onrmrohlur _ DFIATEPT _ —�-----
4.1 80,��3B.IE J GHQrv�
PFlINCIAnL71h1W.1Nf-----.---- AN DE CC•60R til R'S NAME Y '
7E QF5 019 MATWIlp
^ Q FIXES] Q VARIAOLe
—
ANNUAL PERCENTAGE FINANCE CHARGE: Amount rinanced:The amount of Total of Payments:The amount
RATE; The cost of your credit ase The dollar amount the credit will oref it provided to you or on your yoU will have paid an or you have
yearly rate. cost you, behalf, made,all payments as schedulod.
4.14% s $ 17,253,38 $60.000,0D e S 67,253,36 0
Variable Rate;if your loan has a variable rale as Indicated above the Annual Parcontoeo Rete rally Increase during the term of thla troneaolbn If Rha (Index)ohantos.The
aradit union vitt odd o reshgie of to tho Indoxvithm.The rote will change rnonlhty on the and dayy of the month.The to
W41 never bo hlghor then the maximum role allowed by
law,and It will novel be len than. Any Interest rate Increases will result h more pay"Als of the some amount,For Example,it your loan was for$5,000 4116%[of 46
months and dm Annual Poroeniago Rale increased by 2%after one year,die form oryavr roan would Incraase by two months
'pLoknotl Ratp;If oheakaitNo following appdeo to your loan:
ICC' Automatic Peymenl Dleeountod Rate;Coaevao you have agreed to make your mquimd monthly payments through en automatic deduction frons Your CheakingrSovings
aunt,yet#ANNUAL PERCENTAGE RATE hos been discounted yyyy.20%.The ANNUAL PERCENTAGE RATE disclosed above In the ANNUAL PERCENTAGE RATE box is
the,Automatic Payment Discounted Rale.This rate will Increase by.26041fou cease the colonic Ila poymonl.onangtimenl or ran to maintain sufficient Nnds in your accounl W
cover the
11
cover In such a case,the effect of iho Increase wli be to Dxtend the term of y'/our loan,For oxomplo,If9our Automatic Pay moot of accented Rate n 19%
on a$5,000.00 loan for 60 months and you cubic the automatic payment arrangement,yourrela will klafe9ae to 10.20%,m%vI rig in t additional paymenl.
Variable Rate Preferred loans.11 your loon Is o variable rate loan and youqualdy for a preferred roto,your proferred dismount Is taken at the time you take out your bon,This
Inflict preferred ANNUAL PERCENTAGE RATE will Ilion vary acaordln0 W c=05 In ails Indox v,disclosed above.For oxornC,If a vadablo rale loon's Inillsl ANNUAL
PERCENTAGE RATE is 12%altho time you take the loan,your InWaf prclarr ANN t1AL PERf�ENTAGE RATE wilibo NIA%.Your Initial pmlomod ANNUAL PERCENTAGE
RATE wal then very awording to the Indox,is dlsolosed In the"Vorlobio Rato"provlsfon above
Fixed Rale Proferred Loam.If your lain is o"`ad rate ban and you quality[of a preferred sate,your ANNUAL PERCENTAGE RATE wal bo No prolonod ANNUAL
PERCENTAGE RATE disclosed above for all(ono so your preferred status remalns in eaocl.
Numberol Payments Amount of P■ymen4 PDyfnunl Frequency When Payments Are Due Property Ip suran":You mev Ob aln DroperN
your Insuranoe Irom anyone yo want 110)19 noce{Stabia to
Pcymeof 179 $373.63 Monthly•Beginning 06!2712013 credit niluno ni , YYrail p yet the Insurance from the
sol bye 1 $377.69 Final Ova•On 0612712028 S NIA y
Sac ud .CdtateirolsecuringotherlosnawiththeondItunon the goods or property Other
will also wcure this loan.You ora gluing
o sacurlry Interest In beln8 pluchosed, �lDescnba):
your shams and/or deposit in the cradii union,and: K
Leto Chatgo:it a payment Is late by 10 days or more you wilt Req ulred Deposit D alanon:The Annual Percentage Rale,does PDing Foes: Non•Flling Insurance:
be units a law foo of 6%of your schedutad paymont. not take Into account your requhbd deposit balance,H any, f N/A $NIA
Prvurymsal: yW pay art 00 y,you wit not hb,o l0 pay a Penally. all9.cone douM.na I AY,odleanal letormeudla Inorpsyman eeuk any roqurt pay nt I M
p' aaienlnvda, lad pdWde dela artdpropdyme /prunaa and panelael.
ITEMIZATION OF
j AMOUNT FINANCED $ 60,000,00 Amount Pold to others on your behalf(Describe)
S To i To
AMOUNT GIVEN TO YOU DIRECTLY$ 47.948.83 To 11i TO
$ To $ To
$ To $ To
$ To $ To
AMOUNT PAID ON YOUR ACCOUNTS 2,051.17 $ TO To
To $ To
S To $ To
$
TO $ To
PREPAID FINANCE CHARGE $ 0.00 $ To $ago To Foes
$ TO Ailed Ualtnons $ To Allied Sdvi
SEC U RITY/INF,ORMA--hbN
MAKE MODEL YEAR I.D.NUMBER TYPE VALUE
OTHER(Describe):7407 WERTZVILLE RD CARLISLE PA 17013
=ace hares AMOUNT ACCOUNTNUMBER AMOUNTACCOUNTNUMBER
and/or Deposits of $ $
{
Vint Panic lhelthe terms and conditions in the disdosum statement and the loan and security agreements located on page 2 or ibis dornnont shod oou*W Ws loan If Mom it mora
than one burrower,we conte that all the conditions of the loan and security agreements govorning(life loan shall appply to both)ointy and aovamfiy You*
that you hove
recalvad o copy of the loan and security agrear a rls and disclosure statement.Co-signer.If you ere signing os eo•sgnar,you acknowledge receipt of the notice to cosigner
conWnad an pogo 2.
BORR $SIGNATURE DATE CO• K LJ'OT H OWNER LJ "COSIG ER DATE
X l (SEAL) A3 x (SEAL)S 12 I
CO-MAKER (3'OTHER OWNER "CO-6IGNER DATE ❑ CO-MAKER []'OTHER OWNER O "CO-SIGNER DATE
X (SEAL) X (SEAL)
CO-MAKER Q'OTHER OWNER []"COSIGNER DATE r) CO-MAKER (]'OTHER OWNER L) "CC-SIONER DATE
X (SEAL) (SEAL)
'aP,e,tawMear4yp•nm Ne N••prof„rylrlYna,taerr,nenn•mw,r.lMarrl In ay'On.,Us— —AIrn.la. erwr.wl.py—If ir— anai.dep�Wspry our MM,—ty 1—.
valrw; •wcudy wW6,10hNer h—.••e.olwl.le IM0.4ky ."'On..,Us— tradeunion mryreekrmmwal•perrwnlRon Hr yannlw e1.rvr mall Non blur onWiep,.TM
wusnbrrMvr•meeat•w�.ela,Me,Mweuld MlnrwM bwYWd ey Ow. ,
NOTICE•TO CO•S§IGIN ER
You are being asked to auafanloe this dab!,Think carefully before you do,If the borrower doesn't pay the debt.you will have to,8a sure you can afford 10
pay If you have to,and(flat You want to accept this responsitrdily.
You may
amount. have to pay Up to the full amount of the debt 11 the borrower does not pay.You may also have to pay late foes our collection costa,which Increase this
The creditor can collect this debt from You without Rrs1 Wing to collect from the borrower.The creditor can use the same collection methods against you that
Can to used a9alnsI the borrows/,such as suing ou,gdrnlshlrlg�aur wages,oto.It this debt Is ever In default,that fact may become a part of your credit
record.This notice Is not the con act that makes�a u liable fort debt.
I
Page 1 of 2
Exhibit "A"'
POOFtROfFr8 NAla LOAN In--q .rnrx nrr NtWnER DATE OF I.MN
JOHN F CRONE OSf23l2013
IN,96161
INA WORDS"CREDIT UNION"MEANS MEMBERS IST FEDERAL CREDIT UNION,THE VVORD3'YOU,""YOUR"AND'YOVAS'MEM!THOSE
LOAN AGREEMENT SECURITY AGREEMENT
Pay�ltlton�ofppmenco Chs! 0s;For Va a rocplvod,you promise to pay,at - h To adellra a m aUr{,�+ I0rp and 01 oxpwndlUrow Incurred b o aroau
the Cradll Urdon a off co,all amounts�uc,Ali paygents shall be modo illunin
nion In �'nXcc tall wllh�It a leen r In roallynp on o►ocurl to et,you
pursua�ll the dlagoauro elalelrant Dn pp0pu 1 01 Otis document.You ntjo ggel lunton tlmoaurfl��n rest n T PrBdsoV PC�crlbe�on
tmdora a that Ifre Mance charge and lolal of so hown on a t a a rr os1 la dopuTDrtt y epC {y a atfnc, ►a I narposo►
1 II uatuiod adUlilop►to illi estprof°gropon paIInlr ,legmell p mOn18 c on tho woury property anti addernlnpe iocOfvOd Trom U10m
will be made on the schedu9edv dales,and,ff hove yUaliMd Tar secure Pproporty.
prClemttd fete lhal yDU wnllnue 0 Gall➢ry Ih CpmIt one of that to fired C oes odlac rallxetlo�FV o o es oeurlN farrlua I n or f r any
rateg It Yyou lal(lo Vay enY Insloflmenl by(he IQme tl is due,you vn11 pay ichor an Baorrowor he► �th"ebro�t vARaooufC at�amoun�s
BdUltionallniDtoalOnlireov¢rdue�mount. �orroworowoslD orodl11unon�awa lnohrhu Hawovar roporty
AlI00atI0n of PeymorM a0d Addltionat Ppymvnte:Payments and credits ao rmwe snor1th oradhtwi9'not aocun�r 4wn lra a i ro rtr1P
Bortoweya circ Ipa+naWonce(unlaasl spm ac�sa�noUaas vo
shag be applied In the Iollowing oder.any amounla peal due earned Ivan a�ld➢R�ser Iasal nqulhmanta an aat�it�a�),ar era non•purchew
Inlem or fm once charges;anyfeegot dNesowing indurlingany oney oua ho goes.
Insurenca premiums;outatand g principal.Payments made In addition to z. YouwVl cot Phenpa the IRaotion ol,seg wt insist me collateral antess you koro
regularly echodule l payments ahOlt be piledlin the same order, mo era un ore's rtor w nen mmant
Protonod are:If you quail for a pre trod ra as disclosed o p e of a. You warrant Ual you havaolood lite to the collateral,fine of all attudty,Interest$
�p {a q og exco that p o w the v l u and extept la any Infero t d a nonce•
lhla doamerd or kl a se era a prefarred rale pudendum,you UD erstan� mxk owner o�u,a weotera�w�a�pa elpnod We apraemem�n too bWtwtpd
lhe}you UsI mast Iho Condi lona dlW aep to you y{�ardDr lD quailry Ivr the price.
pre 9rre rale and muel nlmue to meet those Carl Ill..In order[o keep a, your will pit ant $,assmsmonu,and lions ogatnat or atwahaa w me o arty
YYour pre arced IIe10.If ou II to lncat III SO Conditions, our rate will opsc��cpod d lu���°yr op ee w kao roperly I opd ndltlon,(rove d ri o
net 11 at yyour loan.Youyprallisetocontinue .ulaNea%ear.taua4r000xacoRaranpa�a�oma�r�iEnocooud
making payments sgntl to moB all obil6pellOns unser this Agreement even It 'is
moot anon;Wan►alt cm un a roquarl a Wal dalend w�property
you F1 aria the pre fled rale, a�Mut advalssi tura party a
Late Charges;Ild'ou makes lots pad gent,you agree to e a lots charge a. You wl'I malmaln insurance to cover vshldo or other RcogentY h vAakh the
pay g uedll unlaq hhas a$scudq Into sal Th nm peep�Wyeyl bo rn 1 rig,
e
II one Is dildoes on page 1 of!hie acumen4 emaunt seasiecwry Wme It union, au p4�I sWr4 8 the u ung%w�i l prior
Props Insunnrs:If ou obtain a loan secured by a motor vehicle or of cosh wsunanro nh7 efi au a awed w vertk un na eau d b lcob
OIIIOf la glbkl pfopgnyI�QU must obtain Insurance wh Ch protects the oredll m n am ropes U� la to mainloin arach Inaur�nw or*n.un may out
limon Trom finanual foss.Tho amount end I�vera o the pro s �e Mp4raqul oe W,ob+ n nouranco of our orvn one o d Mir costol evch to rho
Ae l( P su sowed.ThN poctwoeatl wrntattho Con W rate unto Dale.You lunhor
In8lur�rartC¢mUal ba 8CCepIa018 t litq credit Un On.SUC71 a pOIICy r�IFt sae tin to Iho aedn Non the riphtto etehro 1rro oteods or ny!neaten on
Provida of IC➢sl fire,Ihefl,wmbinad eddlt�onp�covers as➢red c0111aton au property and�l act any Wult{a pay Ilwsr"pmCcoas doecey to.e(e�1
f19Ur8r1CC.Ii muss con all 8 Lose Payaayy�g Clouse endorsement naming the union.You FIrlhortto trio vodd union Ip andono any cheek of drary provlda�as
cmdM inion al Icon hv�der,You may obtain(his Insurance from enY e9ant of I o pro.sw il0l sues insuran e,and npply those proeesda to Illhhheee sums owed to
I'll,
chD!Co and dbeCI the agent to send the credit union a copy of Ih8 tpio erorri union
Policy. Y f dhef aulhorlxa Aa cr rill uNon pr old your Inrunnu Service Canter
l w•41�i IYie necea$ery IMormatjon for vadt tPan og eaegIr coverope.
Dobtor RobpOns141111y:You remise to noll��yy credit union of any ChanOo In You a owlad.th►t Insuran or en axle a marcor, Iced the pedlt
our name address or emplpGymen`.Y4 profnlse not to apply r r e loan If lint Is unou�oenetu w yw�'ndlvaua�ry burs p lmarxy wPlae pra�aclwn of the
our there Is a reasonable p a ab It that you will be ung @ to repay cre�un�"on,
yyour ODI'a on p rd t0 the 1QrTns Of peso credit extension,You promise 0. gh d Ili cmdk uNan loot ate oma Brei th xc dly feaegmd hoe
(o lnfoml aodl}union plbny rmw InfOfmailOn WI1IDh relates 10 yyopUf eblgty 10 4 m n�rnaa In valva,or iw on4 ra apn feel lhel atltle ne�iawn, (a rcqubea,You
repay your obbgaUOn.You proms a net to submlf))also or Ina Xxlfele o0roat$aaa�an�ocroml lined u m ton St�r tlaya w otovor e0 boreal secunry
In Drmallon or I Ull taneeel I ormalion regarding �ni era h un n ed►is necessary to plot 0 me area I union ago nn possible
Y . g g your creditworthiness, sa,
ere it stending,orcredil Capa y, y, Lderoul ea delinad l me LoenAgreaments b lir the aedit union nae
Default,.You shall be considered In default It a of the talloWnp occur:1) the ourr tv uaon w dotou I w favors ss aAnoduso, cane�rra1 r lawful
KIMlo�W`dl
8ny prOmis m@de under lhls Loan Agr08 ret or uifd¢f the manner.�luch care,+hp vbilil truce p�ie cred4 un10 a auinD 4ym¢ @ mC ro4reaenUUbrrrJves maY,at me coda uNon►gylbn,and r too p�em.�a whereth.SOcurlor nh or 2)Ify0 u do Trot use the monoyy the credit untopp colateral Ia kc t aMt raze pos.eulon wbracue apWetcaDDlla aw$, nocraUlIOarreDrIh0 D.0 Sot6 ladIn ourapplication;br(3)Iithecredit unioos the '%I w rorWn the pppropdrty led d ai conal coluntn OF arpunion ,In olid elth,bdievo that pros d of payment,�aRormanCe d�apoae are cameral On Nn copes.Qw1tnro hn m4mtem,b kept.Il chs
or realization'Of the collalorol,If vj,,Is Ilnpatrrood;or(�If You dlo;or(5)if �I ante dac ar to oeu .eollla oral el a �+�'Ie sale, dvata auto 0
/ov file a Ips IT, 11 In RenkoNCet nsoivon or recel rshlp or are put o o�p Ie I
goof tr�a c omni,t oto k�iNpn well n�Ity 7rov o me lime red
cy I t p� a 'a a' a ►i Ike' i ,0)�avt na 4U19 Ah-.
10 of ala�ofluon,41
nvotunlar�Iyv nfv oua pprr m s;or((e If the 11I,f.pny Igen alt Iho tradn un n se!le v rwlee els sea of Qe ales the u unto may
sea rd loth atbouitrs los, oma 8�or des�myed,or It It li levied mnacl to r u o sone a expense. od'fn C e rale ny.ho�hnp en
a0qaaUUnin$rioch5od a pamishad'or(7 y u do nDl pay on Ihne any of your f nn trot aoflePeml la end en q e solo w me mtorel.ilio orodlt
olltaf of Ira debtsla the credh In on.I you default.the credit union m0 �'n,�+�'�o cdlecl re$�onable at tris s la sand loos 9xDensi s.parm Wed
al the creep unlon's option and wilhout prior notice declare this Ivan y app'n a low,Incline In coons on m d4aposkbn o t e aroperi�.U�ra
Immediate duo and ayable,and you rrwsl lmtnoQlalety pox to the credit yyou d sub yov rnoyy keepp posnadon a Aeppropon ooimlero de.c bed arca
41 Y Q Us It on(rlawM rYrmnOrcon lrnonl ah Nlsopredmanttawl�ail0 Unnee
uN l at t t.Is Itlo o til unpaid bet Woe,a9 well as``h Flhanc0 ChptgO po�!aY on ma eo afetal.ypp un rmon� st Noc II vnton has rtaln d 1
to ate,arty tole charges and costs oPcollection pernefled unda(r law, gnd_regel ro��tad�ee aysileble w e rpdtp�nlan u1�ermo UN�o m` mmo4c a�
IncglDUdlnp feasonable a110rri8 la0e,that the (a It un10DD mgy❑CUq up t0 a red o10er wppYublo lows a thel ma Qnrlif un'n e arca ao{Ip m
2096 of ole unpaid prin al rind Interosl.Costs o(coiltxlIon Include,but aro to ami p. onl Ilff you dcleuIt n Ulet event,you wY�et c dl union
nil limited to,rupees �r�o re ues�eil�,�mt�0 oDe (m owrol credm►e n a da e t e tm�a
00eefonfive appraisals,ofalle andalalta y un�onata�auofine�rddil niv acno�slnp.lrmetfid`�tunlon40d cidQoe(o
any actionnts,casuallydema e(rlaurencecoverappe ertdellome 'sieeslor waivelN. Elavil ItwYlnotmnahplubwavma e o erauaweuenl6 feasts.
i arty action lake��by an altorlley In Grder to collect This Wan pr prosefve or e. Tho c d 1 n+an h b colla es r Attomo-In-Fact w eerie m an
protect the cretlll lir Ion's rights antl ramadles,blcludin wiltlaul Ilmlle0vn, ecu.l a cro�i ��� aro no 'Baryw proCecl Bre Elis of and IXa
pre•eeVUlt demanndda i0r peyyman Dre•eNl mediatlIDpnn or a 1btry111ant recu ry�nteroatw a sgreamem creates
negdlalWm,invesl'�gallan 0�esaasamettf.ol the ae it untol1a phla, p, If loan la mora1hon errebe newer Yowstdm Ilam und$r Nla o wmont are
vaafuclppetlon Yn bonkkruDtCy cBBas, alto ,ono roceodings`'nc�uding ram ono several,each bolnp equally aspon3rble w miw Iho to cis or u t.
'thoUt IimlWGon,411ng proofs ofm,pursuing replfgirls[ivn agraemenls, oBroament.
allonNq9 I aedn 6 01 C'¢dltOrB,and pUfBtrf COm IBlnt,motfOng D
g q p g R 10, Thie secuA ogmemam nal only binds you,but your oxecutoro,edminhlm+ma,
ob}¢e INS Osal relate In enYY way to tna aed�t urdon s c011aterel or r��00ht to heln,.naa�e"rym.
Paymang,collatvfaldle osltfon noq•DonkruptcYsullsopNOradrtllrlislretiv0
occlllloonn,end appeals.The princlpol balance In tlefsull shall beer Interosl of
Ileo con1racl ref ,
glalutory Liam II yyou are In fault,federal law g a the credit union the
right to apply the bSlance of s4ares andror dividends In your a0counl a at
the Ume of default to aoUaty UIIsa loan.Once you are In defnult.the c�r�fI
talon may exQTCI6O Uus 118%1 withoul further nolice to you.
Delay In Enlorpomant:Credit union me Y delay erdoroing any of the credit
union rights under this agreement wlthoui losing them.
Irrepular Payments:The cmdll union me Y accept tale go gents or pargal
payr tants,evefftt thol r�rkod"payment In fug, whho0I faoing any of the
aedll union rlQhte un er hie agrsemrmi.
Coarmkore:Y you are alppning IMS agreement os a co-maker,yyou ogled to
bli oqualN reaponSlhle MIIl,the borrower,but the uedil QniC trio sus
elmer
of
oth of u.The credit union�does pont thnave to nils yid Thant Ihls
parymentand a e➢f e0enmm��DaeoodryeWCAhouf noilfying oPrWOieaa rep you horn otos vas
ro Dons bhilyan this agraentanL
Contactual Pledge of Shares:You piadga all your wham$and dal oelto In the
credit union,Inaluding future adolUons,as security for this loon,in colo you
default,the credit union may apply Iheeo aharoe and dopoalq to the payment
Of cn■uma due at me Unto of default,Initialling taus of tollocdon and
reasonable atiomoy'►loco,that 1110 Credit union may Ina lir,up lv 20%of the
unpaid printlPat and Inloroat No Iron or right toimpmos o}len an aharoe and
drop
a Us shall apply to any ofyour shares which may be hold In an"IndMilual
11.0romant Account"or"Keogh Plan."
Page 2 of 2
-EC,AL DESCRIPTION
• 21.11��3031.004 t
All that certain house and lot of ground situate on the South side of Wertzvllle Road,In the Township of Middlesex,
County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit:
Beginning at a point on the southern side of Wertzvllle Road,Pa. Routes 944 and 569, (L.R.21001)(60 feet ROW),said
point of beginning being measured two hundred ninety-nine and fifty-eight hundredths(299.58)feet from the western
extremity of a curve having a radius of twenty(20)feet and a length of thi
rty-orie and 31,73)
feet,connecting the southern line of Wertzvllle Road and the western line Oak LaneebaIng-ahso the northwesree hundredths 1om
comer of Lot No.5 on the hereinafter mentioned Plan of Lots;thence by Lot No, 5 South 13 degrees 12 minutes 48
seconds West a distance of one hundred sixty-six and forty-three hundredths(166,43)feet to an Iron pin at Lot No, 10
Section B of the Plan of Regency Woods;thence by Lot No. 10 and Lot No.11 on said Plan North 63 degrees 64 minutes
20 seconds West a distance of nlnety-one and nine hundredths(91.09)feet to a concrete monument thence by Lot No.
11 on said Plan North 73 degrees 13 minutes 50 seconds West a distance of seventeen and thirty-six hundredths(17.36)
feet to an iron pin at Lot No,3 on the hereinafter mentioned Plan;thence by Lot No. 3 North 15 degrees 40 minutes 47
seconds East a distance of one hundred sixty-four and flfty-nine hundredths(164.59)feet to an Iron pin on the southern
aide of Wertzvllle Road;thence by Wertzvllle Road South 65 degrees 42 minutes 25 seconds E=ast a distance of one
hundred and nlnety-two hundredths (100.92)feet to an Iron pin,the Place of Beginning.
And Further being Lot No. 4 on the Resubdivision Plan of Lots 1-7 on Section A,Regency Woods, as recorded In
Cumberland County Plan Book 31, Page 16.
Subject to any restrictions,easements and/or adverses that pertain to this property.
As surveyed by Gerrit J. Betz Associates, Inc., November 11, 1976,drawing No. 76558-D and containing
16878 square feet, more or less.
Having thereon erected a dwelling house known and numbered as 7407 Wertzville Road,
Carlisle, PA 17015 (formerly 17013).
Being the same premises which Mary C. Rohrbach by her deed dated July 31, 2003 and
recorded in the Cumberland County Recorder of Deeds Office at Deed Book 258, Page 2460,
granted and conveyed onto Bobbie Jean Crone and by which Mary C. Rohrbach reserved onto
herself a life estate. The said Mary C. Rohrbach died on May 31, 2005 whereupon the foregoing
life estate terminated.
Being Tax Parcel No.: 21-11-3031-004.
Exhibit "6"
Prepared By; Mein bers 1st FCU
5000 Louise Drive
Mechanicsburg,PA 17055 110
xZ
Return To: Members 1 st FCU
Real Estate Department
5000 Louise Drive
Mechanicsburg,PA 1705 5
(717)-795-6026
I. 1 3a31 r oar-)
MORTGAGE
Malde 05/23/2013
Between
BOBBIE JEAN CRONE
(hereinafter called " or gagor'1
And
MEMBERS 18T FEDERAL CREDIT UNION (hereinafter called "Mortgagee")
Whereas,Mortgagor has executed acid delivered to Mortgagee a certain Mortgage Note(hereinafter
called the"Note")of even date herewith, payable to the order of Mortgagee in the principal sum of
$ 50,000.00 lawful money of the United States of America,and has provided therein
for payment of any itional moneys loaned or advanced thereunder by Mortgagee,together with
Interest thereon at the rate provided in theNote,In the manner and at the times therein set forth,and
containing certain other terms and oonditions, all of which are specifically incorporated herein by
reference;
Now,Therefore,Mortgagor, In eonsIderation of said debt or principal suns and as security for the
payment of the same and Interest as aforesaid, together with all other sums payable hereunder or under
tho terms of the Note, does grant and convey unto Mortgagee,
All that certain property ofthe.M.ortgagor located in MIDDLESEX
TOWNSHIP ,,__Curnj&rlaL-ld County, Pennsylvania
SEE ATTACHED LEGAL DESCRIPTION
Milch currently has the address of 7407 WERTZVILLE RD
[Street]
CARLTSLE Pennsylvanla 17013
[City] [Zip Code]
AoctNo_ _ ApplD Page 1of4
Exhibit "C"
Together with the buildings and improvements erected thereon,the appurtenances thereunto
belonging and the reversions, remainders,rents,issues and profits thereof,
To Have and To Hold the same unto Mortgagee,its successors and assigns,forever.
Provided,However,That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note,together with interest thereon,and shall keep and perforin each of the
other covenants,conditions and agreements hereinafter set forth,then this Mortgage and the estate hereby
granted and conveyed shall become void,
This Mortgage is executed and delivered subject to the following covenants,conditions and
agreements;
(1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any
tlfture loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
Intended by Mortgagor and Mortgagee to be so evidenced and secured,and Such loans and advances shall
be added to the principal debt,
(2) From time to time until said debt and Interest are fully paid,Mortgagor shall; (a)pay and
discharge,when and as the same shall become due and payable,all taxes,assessments,sewer and water
rents,and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt
secured hereby,(b)pay all ground rents reserved from the mortgaged premises and pay and discharge all
mechanics' liens which may be filed.against said premises and which shall or might have priority In lien
or payment to the debt secured hereby,(c)pay and discharge any documentary stamp or other tax,
Including Interest and penalties thereon,if any,now or hereafter becoming payable on the Note
evidencing the debt seamed hereby,(d)provide,renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability Insurance as Mortgagee may from tlme to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor and Mortgagee as their respective Interests may appear,
and(e)promptly submit to Mortgagee evidence of the due and punctual payment of all the forogoing
charges;provided, however,that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage In good and
substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order,condition and repair
of the buildings and improvements erected thereon.
Acct No Appy Page 2 of 4
(4) In the event Mortgagor neglects or refuses to pay the charges mentioned at(2)above,or fails to
maintain the buildings and improvements as aforesaid,Mortgagee may do so,add the cost thereof to the
principal debt secured hereby,and collect the same as a part of said principal debt.
(S) Mortgagor covenants and agrees not to create,nor permit to accrue,upon al l or any part of the
mortgaged premises,any debt,lien or charge which would be prior to,or on a parity with,the lien of this
Mortgage,
(6) In case default be,made for the space of thirty(30)days in the payment of any installment of
principal or interest pursuant to the terms of the Note,or In the performance by Mortgagor of any of the
other obligations of the Note or this Mortgage,the entire unpaid balance of said principal sum,additional
loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this
Mortgage,together with unpaid interest thereon,shall at the option of Mortgagee and without notice
become immediately due and payable,and foreclosure proceedings may be brought forthwith on this
Mortgage and prosecuted to judgment,execution and sale for the collection of the same,together with
costs of suit and an attorney's commission for collection of five percent(S%)of the total indebtedness or
$200,whichever is the larger amount. Mortgagor hereby forever waives and releases all errors In said
proceedings,waives stay of execution,the right of inquisition and extension of time of payment,agrees
to condemnation of any party levied upon by virtue of any such execution,and waives all exemptions
from levy and sale of any property that now is or hereafter may be exempted by law.
(7) Upon payment of all sums secured by this Mortgage,this.Mortgage and the estate conveyed shall
terminate and become void. After such occurrence,Mortgagee shall discharge and satisfy this Mortgage.
Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this
Mortgage,but only If the fee is paid to a third party for services rendered and the charging of the fee is
permitted under Applicable Law,
The covenants,conditions and agreements contained in this Mortgage shall bind, and the benefits shall
inure to,the respective parties hereto and their respective heirs,executors, administrators,successors and
ass] ns,and if,this Mortgage Is executed by more than one party,the undertakings and liability of each
shall be joint and several.
Acct No ApplU Page 3 of 4
Witness the due execution hereof the clay and year first a ova written.
13013BIE JEAN OFCME
Commonwealth,f Pennsylvania
ss:
County of P
ldbldee iz )
i
On this,the , �4i` day of Afelt,4 ,2013 ,before me,
the un r igned officer,personally appeared
BOBBIE J AN CRONE
sat sfactorl y proven to me to be theperson(s)whose names is/are su5soribedtoth6w—itfiln Mortgage,and
acknowledged that he/she executed the same for the purposes therein contained,
In Witness Whereof,I hereunto set my hand and o iia 1.
My commission expires;
Q0MMQNWE6LTH OF PENNSYLVANIA
Notarial Seal
Jody i•,Travis,Notary Public
Lower Allon Twl).,Cumherlud County
M Commtsslon Expires Sept.29,20W
MBMt ek PENNSYLVANIA ASSOCCATnoN Of NVO AMRWS
Certificate of I3ra sidence of h1Qr gagm
Members 1s'r Fedcral Credit Union,Mortgagee within na ed,hereby certifies that its residence
is 5000 Louise Drive,Mechanicsburg,PA 17055,
BY
Acct No ApplD _ _ _ page 4 of 4
Ordor ID:818134
LEGAL DESCRIPTION
21.113031.004
All that certaln house and lot of ground situate on the South side of Wertzville Road,in the Townshlp of Middlesex,
County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit:
Beginning at a point on the southern side of Wertzville Road,Pa. Routes 944 and 569, (L.R.21001)(60 feet ROW),said
point of beginning being measured two hundred ninety-nine and fifty-eight hundredths(299.58)feet from the western
extremity of a curve having a radius of twenty(20)feet and a length of thirty-one and seventy-three hundredths (31,73)
feet,connecting the southern line of Wertzvllle Road and the western line of Oak Lane, being also the northwestern
comer of Lot No.6 on the hereinafter mentioned Plan of Lots;thence by Lot No,5 South 13 degrees 12 minutes 48
seconds West a distance of one hundred sixty-six and forty-three hundredths(166,43)feet to an Iron pin at Lot No. 10
Section B of the Plan of Regency Woods;thence by Lot No, 10 and Lot No.11 on said Plan North 63 degrees 54 minutes
20 seconds West a distance of ninety-one and nine hundredths(91.09)feet to a concrete monument thence by Lot No.
11 on said Plan North 73 degrees 13 minutes 50 seconds West a distance of seventeen and thirty-six hundredths(17.38)
feet to an iron pin at Lot No,3 on the hereinafter mentioned Plan;thence by Lot No,3 North 15 degrees 40 minutes 47
seconds East a distance of one hundred sixty-four and fifty-nine hundredths(164.59)feet to an Iron pin on the southern
I , side of Wertzvllle Road;thence by Wertzvllle Road South 66 degrees 42 minutes 25 seconds East a distance of one
i hundred and ninety-two hundredths(100,92)feet to an Iron pin,the Place of Beginning.
i And Further being Lot No.4 on the Resubdivision Plan of Lots 1-7 on Section A,Regency Woods,as recorded in
Cumberland County Plan gook 31,Page 16.
Subject to any restrictions,easements and/or adverses that pertain to this property.
i
ROBERT P. ZIEGLER
RECORDER OF`DEEDS
CUMERLAND COUN'T'Y Y
1 COURTHOUSE SQUARE
CARLISLE,PA 17013
717-240-6370 '
was ,L.r
Instrument Numbor-201320395
Recorded On 6/21/2013 At 9:42:24 AM *Total Pages-•6
*Instrument Type-MORTGAGE
Ixt'volce Number-139972 'User ID-RZ
*Mortgagor-CRONE,BOBBIE JEAN
*-Wi•tgagee-MEMBERS 1ST FEDERAL CR.UN
*!Customer-UNITED ONE RESOURCES INC
*.FEES
STATE WRIT TAX $0.50 Certification Page
'STATE JCS/ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES - $3.3.50
RECORDER OF DEEDS noV1'This page is art
PARCEL CERTIFICATION $3.5.00 P g P
FEES of this legal document.
AFFORDABLE HOUSING $11.50
'COUNTY ARCIUVES FEE $2.00
jbb ARCHIVES FEE $3.00
0 AL PAID $69.00
s'4 .
I Certify this to be recorded
in Cumberland County )VA
CU
RECORDER O Z D ., D5
"-Information denoted by an asterisk may change during
the verillcntion process and may trot be reflected on this page.
002726
• • 11i1(!I(Ilfllllllllillll(II
1
1
(Rev.9/2008)
Date: July 14,2014
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default and the lender intends to
foreclose. SFecifie 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 MEETIW TH A CONSUMER CREDIT COUNSELING
AGENCY WITH,IIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with
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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICAC16N OBTENGA UNA TRADUCCION INMEDIATAME NTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRtSTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERE CHO A RE,DIMIR SU HIPOTECA,
Page I of 5
Exhibit "D"
HOMEOWNER'S NAME(S): BOBBIE JEAN_CR-Q2I
PROPERTY ADDRESS: 7407)PERT WILLS RD
CARLISLE,PA 17013
LOAN ACCT.NO.:
ORIGINAL LENDER: Members t Federal Credit Union _
CURRENT LENDER/SERVICER: Members ls'Federal Credit Union _
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
OU MAY BE ELIGIBLE FQR FiNANCIAI A SSIST�� CE
HI H CAN SAVE YOUR HOME FROM>ti`•"EC OSU E AND
HELP YOU MAKE F ITiIRF
TGAGE, PAYMENTS.
IF YOU COMPLY WITII 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 FnRECi ncrror -_ 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, TIIIS METTING MIIrT OCCUR WITHIN murb rc, ..Y.,,,, . _._ _
()r THF HATE nF THiC
NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORT AGE ASSISTANCE YO MUST BRING YOUR
MORTGAGE jjP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAG
f DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUME CRFniT r 01INSF ING AGENCIES --If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names addresses and telehone numbers of designated consumer credit counseline agencies for the county in which the pronert�is located are set forth at the end of this Notice, It is only necessary to
meeting.Advise your lender immediately of your intentions, schedule one face-to-face
APPLICATION FOR MORT( AGE ASSiSTANCE--Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature ofy our 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".
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YOU HAVE THE RI HT !..FILE A HEMAP APPLSE TIME PERIODS. A LATE
[CATION EVEN BEYOND THE
APPLICATION WILL NOT PREVENT THE LENDER '
STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE
STOPPED,
Page 2 of 5
A , N Y 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 riled bankruptcy ou 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:
7407 WERTZVILLE RD
CARLISLE,PA 17013
IS SERIOUSLY IN DEFAULT because: -'
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due: for April 27,2014 in the amount of 273.38,May 27,2014 in the amount of 373.3 8,and June
7.7,2014 i„the=ouD,t of 373.38
Other charges(explai»/itemize):
TOTAL AMOUNT PAST DUE: $1,020.14
D. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION(Do not use if not applicable):
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HOW TO CURE THE. DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,020.14 ,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY(30)
DAY PERIOD. Payments must be made either by cash,cashier's check certified check or money order made payable and
sent to:
Members 1"Federal Credit Union ATTN, Tracey
I 5000 Louise Drive
Mechanicsbure.PA 17055
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do
not use if not applicable.)
Page 3 of 5
I)F.YOI O NOT CIIRF THEnHEAU T -If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exer-c*se Its rights o aceglerate the-mortgage gag 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=ur mortgaged grol eerix.
IF THF, MORTGA TF IS FOR + I OS +
FD UPON -- The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to
$50.00. However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs.
not be reouired to R X attorney's fe s.
QTHTR LENDER RF.MFn7FS__The tender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURT_+. THE DEFAULT,PRIOR TO SHERIFF'S
SAU -- If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and
prevent the sale at any time un to one hour before the Sheriffs Sale You ma do so b
Y spaying the total amount then Dast
due,_plus any late or other charges then due reasonable attomey's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriffs Sale as specified in writing_l y the lender and by performing
any other
requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
_EARL.IEST PO SIB SHERIFF'S SALF DATE-7- It is estimated that the earliest date that such a Sheriffs Sale of
the mortgaged property could be held would be approximately Six(6) months from the date of this Notice. A notice of
ithe actual date of the Sheriffs Sate will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time exactly what the required payment or action will
be by contacting the lender.
HOW TO CONTACT THE LENDER:-
Name
END R.Name of Lender: Members 1"Federal Credit Union
Address: 5000 Louise Drive
Machani sburg,PA 17055
Phone Njjjmmherr:- -717- )0) 283-2328 Ext 3$
Fax Number: (712)795-5202
Contact Person: Traca
E-Mail Address: Mack,CyLjm&mbers1st org
EFFECT OF SHERIFF'S 5,A, LF -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the tender at any time.
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ASSUMPTION OF MORTGAGE -- You may or XX may not(CHECK ONE) sell or transfer your home to a
buyer or transferee who will assurne the mortgage debt, provided that all the outstanding payments,charges and attorney's
fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
Page 4 of 5
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.
. CON5 E C�tEDI ' COUNSELING AGENCIES SERVINQ YOUR COUNTY
Mil in a listl Counseling A gge-ncies-Usted in Jpgendix C. FOR THE COU rt
located, using additionalgaggs ifnecessa4g).
Certified Mail # 917199 9991 7034 4067 2201
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HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated:04/23/2014 05:44 PM
Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region
2000 Linglestown Road 1514 Derry Street
Harrisburg,PA 17102 IIarrisburg,PA 17104
888-511-2227 717-232-9757
Housing Alliance of YorklY Housing Resources Maranatha
290 West Market Street 43 Philadelphia Avenue
York,PA 17401 Waynesboro,PA 17268
717-855-2752 717-762-3285
PathStone Corporation PathStone Corporation
1625 North Front St 450 Cleveland Ave
Harrisburg,PA 17102 Chambersburg,PA 17201
717-234-6616 717-264-5913
PA Interfaith Community Programs Inc PHFA
40 B High Street 211 North Front Street
Gettysburg,PA 17325 Harrisburg,PA 17110
717-334-1518 717-780-3940 800-342-2397
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Servicemembers Civil U.S. Department of OMB Approval 2502-
Relief Act Notice Disclosure Housing 0584
and Urban Development Exp 11130/2014
Office of Housing
Legal Riahts and Protections Under the SCRA
Servicemembers on"active duty"or"active service,"or a spouse or dependent of such a servicemember may be
entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act(50 USC App.
§§501-597b)(SCRA).
Who May Be Entitled to Legal Protections Under the SCRA?
• Regular members of the U.S.Armed Forces(Army,Navy,Air Force,Marine Corps and
Coast Guard).
• Reserve and National Guard personnel who have been activated and are on Federal active
duty
• National Guard personnel under a call or order to active duty for more than 30 consecutive
days under section 502(f)of title 32,United States Code,for purposes of responding to a
national emergency declared by the President and supported by Federal funds
• Active service members of the commissioned corps of the Public Health Service and the
National Oceanic and Atmospheric Administration.
• Certain United States citizens serving with the armed forces of a nation with which the
United States is allied in the prosecution of a war or military action.
iWhat Legal Protections Are Servicemembers Entitled To Under the SCRA?
• The SCRA states that a debt Incurred by a servicemember,or servicemember and spouse jointly,
j prior to entering military service shall not bear interest at a rate above 6%duringthe period of
military service and one year thereafter,in the case of an obligation or liability consisting of a mortgage,
trust deed,or other security In the nature of a mortgage,or during the period of military service in the case
of any other obligation or liability.
• The SCRA states that in a legal action to enforce a debt against real estate that is filed during,or
within one year after the servicemember's military service,a court may stop the proceedings for a
period of time,or adjust the debt.In addition,the sale,foreclosure,or seizure of real estate shall
not be valid if It occurs during,or within one year after the servicemember's military service unless
the creditor has obtained a valid court order approving the sale,foreclosure,or seizure of the real
estate.
• The SCRA contains many other protections besides those applicable to home loans.
How Does A Serviceme.mber or Dependent Request Relief Under the SCRA?
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• In order to request relief under the SCRA from loans with interest rates above 6%a servicemember
or spouse must provide a written request to the lender,together with a copy of the servicemember's
military orders. [Note: Lender should place its name,address,and contact information here.]
• There is no requirement under the SCRA,however,for a servicemember to provide a written notice
or a copy of a servicemember's military orders to the lender in connection with a foreclosure or other
debt enforcement action against real estate. Under these circumstances,lenders should inquire about
the military status of a person by searching the Department of Defense's Defense Manpower Data
Center's website,contacting the servicemember,and examining their files for indicia of military
service. Although there is no requirement for servicemembers to alert the lender of their military
status in these situations,it still is a good idea for the servicemember to do so.
How Does a Servieemember or Dependent Obtain Information About the SCRA?
• Servicemembers and dependents with questions about the SCRA should contact their unit's Judge
Advocate,or their Installation's Legal Assistance Officer,A military legal assistance office locator for all
branches of the Armed Forces is available at htta:/Ilegalassistance,law.af..mil/content/locator.phD
• "Military OneSource"is the U.S.Department of Defense's information resource.If you are listed as
entitled to legal protections under the SCRA(see above),please go to
www.militaryonesource.com gra or call 1-800-342-9647(toll free from the United States)to find
out more Information. Dialing instructions for areas outside the United States are provided on the
website.
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10/16/2014 15:48 7179320317
KARLLEDEBOHM PAGE 08/08
MEMBERS i ST FEDERAL,
CREDIT UNION IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
JOHN F. CRONE and
BOBBIE JEAN CRONE A/I{/A
BOBBIE J. CRONE
DEFI✓1`1DANT(S) : CIVIL ACTION,LAW
MORTGAGE, FORECLOSURE
VERIFICATION
I, Jennifer Perry, Collateral. Liquidation Specialist for Merttbers 1 st Fedcral Credit
being authorized to do so on behalf of Members 1 st Federal Credit Union, Union,
Hereby verify that the
statements made in the foregoing pleading are 1xL1e and correct to the best of my irtformatio
knowledge and belief I understand that false statements are made subject to the e n
Pa. C.S.A. Section 4904, relating to unsworn falsification to a.u.thorit' penalties of I$
zes.
Members 1'Federal Credit Unio».
Date: October_, 2014
enni•e P rry, C a..a r-'al Liquidation
Spec' list
7
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
UFFIt';E OF THE SHERIFF
f l.` U -OFF t'L'.
H E P i', O E H O} i l A
2014 NOV -5 PM 3:46
CUMBERLAND COUNTY
PENNSYLVANIA
Members 1st Federal Credit Union
vs.
John Crone (et al.)
Case Number
2014-6227
SHERIFF'S RETURN OF SERVICE
10/24/2014 03:44 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be John Crone,
Husband, who accepted as "Adult Person in Charge" for Bobbi Jean Crone a '40/ ertzville Road,
Middlesex Township, Carlisle, PA 17013.
IL IAM CLINE, DEPUTY
10/24/2014 03:46 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by "personally" handing a true copy to a person representin ; themselves to be the
Defendant, to wit: John Crone at 7407 Wertzville Road, Middlesex Townshi Ca�rle�pA 17015.
AM LINE, DEPUTY
SHERIFF COST: $51.27 SO ANSWERS,
October 27, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySlife Sheriff, Teleosoft, Inc.
riLEJ-Cr; ;LL
.!F THE Pf i T HONO T h
2014 NOV 26 PM 12: 4 2
CUMBERLAND? COUNTY
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 14-6227
Vs.
JOHN F. CRONE and : CIVIL ACTION — LAW
BOBBIE JEAN CRONE a/k/a
BOBBIE J. CRONE
DEFENDANTS : MORTGAGE FORECLOSURE
PRAECIPE TO SETTLE, DISCONTINUE AND END
To the Prothonotary:
Please mark the docket in the above captioned case settled, discontinued
and ended without prejudice.
Date: November 24, 2014
Respectful sub fitted,
Ot
earl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff