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HomeMy WebLinkAbout14-6456 Supreme Court of Pennsylvania Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Cumberland County Docket No: i�- (n4�(n �ivilTehn The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S 0Complaint El Writ of Summons El Petition ❑ Notice of Appeal ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T Members 1st Federal Credit Union Marlin E. Kaberle&Tammy L. Magaro I ❑ Check here if you are a Self-Represented (Pro Se)Litigant U Name of Plaintiff/Appellant's Attorney: Karl M.Ledebohm,Esq. N Are money damages requested?: NYes ❑No Dollar Amount Requested: within arbitration limits A (Check one) N/A outside arbitration limits Is this a Class Action Suit? ❑ Yes No Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Zoning Board S ❑ Product Liability(does not include ❑ Statutory Appeal:Other L'j mass tort) Employment Dispute: ❑ Slander/Libel/Defamation Discrimination C ❑ Other: ❑ Employment Dispute:Other T Judicial Appeals ❑ MDJ-Landlord/Tenant I ❑ Other: ❑ MDJ-Money Judgment O MASS TORT ❑ Other: ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations 0 Mortgage Foreclosure Restraining Order PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto ❑ Dental ❑ Quiet Title ❑ Replevin ❑ Legal ❑ Medical ❑ Other: ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 212010 F!LFO-OFFICE }fc Eit� FiONO ARY 1 T1111;[,Nie -5 PM 12: 24 Karl M.Ledebohm,Esquire CUMBERLAND COUNTY P.O.Box 173 FFNNSYLVANIA New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: 14- b45(p 0-%t\IIITO'm MARLIN E. KABERLE and TAMMY L. MAGARO 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, T141S 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. Pr�, arr/ e# a--501 3(3039 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 objections 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 USTED. 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.: MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANT(S) : CIVIL ACTION-LAW MORTGAGE FORECLOSURE COMPLAINT 1 AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1. Plaintiff, Members 1St Federal Credit Union ("Members 1St"), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Defendant, Marlin E. Kaberle ("Kaberle"), is an adult individual having a last known address of 7115 Salem Park Circle, Mechanicsburg, PA 17050. 3. Defendant, Tammy L. Magaro ("Magarao"), is an adult individual having a last known address of 1052 Country Club Road, Camp Hill, PA 17011. Kaberle and Magaro are collectively referred to herein as "Defendants." 4. On or about July 25, 2008, Defendants borrowed from and agreed to repay to Members 1` $139,088.30 (the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement dated July 25, 2008 (the"Note") executed and delivered to Members 1St by Defendants. A copy of the Note is attached hereto as Exhibit"A"and made part hereof. 5. As security for the Loan, Defendants executed and delivered to Members 1St a mortgage ("Mortgage") also dated July 25, 2008, on all that certain real estate and improvements erected thereon situate in Mechanicsburg Borough, Cumberland County, Pennsylvania known and numbered as 130 E. Portland Street, 2 Mechanicsburg, PA 17055 also known as 130 East Portland Street, Mechanicsburg, PA 17055(the "Property"). At all times relevant hereto, Defendants have been and continue to be the record and sole owners of the Property. A description of the Property is attached hereto as Exhibit`B" and made part hereof. 6. The Mortgage and the Note as well as all other exhibits attached to this complaint have been redacted to remove non-public personal information including account number and social security numbers as required by applicable law. 7. On or about August 11, 2008, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office at Instrument Number: 200827208. A true and correct copy of the Mortgage is attached hereto as Exhibit"C" and made part hereof. 8. The Note and the Mortgage have never been assigned by Members 1St and remain held by it as a valid and subsisting obligation of Defendants. 9. 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$1,370.63 each for April 20, 2014 through October 20, 2014, as more particularly set forth and described, in part, in the Act 91 Notice attached hereto as Exhibit"D" and made part hereof. 10. 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. sed., 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 3 P.S. Section 1680.401(c), et. seMc., by letter dated September 15, 2014, addressed to Defendants at the Defendants' last known addresses set forth in paragraphs 2 and 3 above as well as at the Property, via certified mail, return receipt requested. A copy of the said notice is attached hereto as Exhibit"D" and made part hereof. 11. Simultaneously, Members 1St forwarded to Defendants the same Notices and addressed to Defendants at the same addresses as set forth in paragraph 10 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 1 St as undeliverable or otherwise. 12. As of the date hereof, Defendants are indebted to Members 111 under the Mortgage for the following amounts: a. Outstanding principal $124,259.49 b. Interest to November 7, 2014 6,548.90 c. Late charges 479.71 d. Attorney fees and expenses 800.00 e. Total due to Members 1St $132,088.10 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 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. 4 13. 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 12 above, costs incurred by Members 1St as a result of the institution of these legal proceedings. 14. The obligation owed to Members 1St on the Mortgage continues to accrue interest at the rate of$28.5627 per day, through the date of payment. 15. 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. 16. As set forth above, Members 1St has made demand upon Defendants to pay to Members 1St the amounts due under the Mortgage and the Note. However, as of the date hereof, Defendants continue to refuse and fail to make payment of such amounts to Members 1st WHEREFORE, Plaintiff, Members 1St Federal Credit Union,demands judgment, IN REM, against Defendants, Marlin E. Kaberle and Tammy L. Magaro, in the amount of ONE HUNDRED THIRTY-TWO THOUSAND EIGHTY-EIGHT AND 10/100 ($132,088.10) DOLLARS plus interest at the rate of$28.5627 per day, through the date of entry of judgment on 5 this complaint and at the legal rate thereafter through the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. Respectfully submitted, Date: ZQ 1 1-/ Karl M. Ledebohm-Esq. q Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 6 2014/10/3011 :23:39 2 /56 CLOSED-END NOTE,DISCLOSURE, St Ott;IZYnc>t�cr6ENz 8000 Loulse Drive,P.O.Box 40 eoRaowEn'sNANEANn AOnREss Mechanksbur PA 17055 MARLIN E KABERLE 9� t RT�ND_ LPEET MEMDER$t" MECHEnNUM er:.n11a NUMB, �' fiITC6TT51TEREgr -ME 9 TAMMY L MAGAR nNA_..._...__... LOAN NUMBER CO BORROMERB NAME 74334 n DATA 2�U A Ar N FIXEO U VARmaLEli Q ANNUAL PERCENTAGE FINANCE CHARGE: A. -Flnanted:7ho ailmUm a Total of Payments:The anlolRU RATE;the cost a1 your credll as a Tho dollar amount the credit vll credit pmvklad to you or an your you will have pato otter you have yearly rale. cost you, behalf. mode all paymerns as scheduled. 0,39% o S 153,663.76 ° S 139.088.30 r S 320,364.01 Variable RAW:d Yw!bun Ibis a vMhblu rale us Indke ed above ilia Annual Porconmoo Rao may klaoaso dudng the tam of U63 tlnnaodbn 11 the (Indpxl Nranges.Tha audit union wlll ar1E a mploln d to Na Index value.Trq fele still[hemp ma INy¢n IIn At dayy if the men1It.TAa ram W novm ba higlar Dmn the ZX,4dood rata oibwed by IOW.aAd k will never be bs3lXan. My InINCsI rola 11Cf0aSAs W[I 103611 In mem Wyr11aM5 of lllo same nm Wnl FOr Elmmplo,a your ban was for$6,000 at 15%IM 40 months end the Annu01 Perconlogn Rom Increased by 296 oher ono year,the term o(yw 1wn would Imrcesa by Iwo months bfeROd RaIB;If Ulaakpd,.Aa Polhwlnp o"'baiD your Bart: Automatic Paymant DlscoUnlcr3 Roto:Becevs¢you haw¢agreed to make yaw mm�Ired monthN RE meals lhrotlyh an nuaunollc deduction fmm you ChecWnySovi unL A" AL PERCENTAGE RATE has boon dl3c¢utN0lf Vy.20%.The 7l MARIA PERCCNTAGL7RATCdIi"%C ehovo in the ANNUAL PERCENTAGE RATC ba.", m0 AVIOmDl1c PoymaN Dlxoumad RDtO,This rate wyI Inaaoso ay.707,i(1'oU coa5o me au¢maoe paYmOnt DNand¢mOm or)ail w mulMoln Fufaclnrn IurW5111 ynUr DocoUni to carer the oWomGlc yaymOMs.In wch o case,the ef(eclaf Ibe Increase w9 be to attend lh0 tamof yyvOm ban.Fa oxompM.Ify0ur Auomotic PaymeN Discounted RDIe n 10% on a 35,00D.001aan is Ee morins end yar cease the alaumoI.pAyment onnrnggamen,yew Imo will Increase 1010.7076.rasul6ng In 1 edd)bde l payment. Vmleble Rate Pr adi_do.0yyawi loanls a, rata IDOn end you qua fw u gelerred rete,your"afaned discount b IDkan at the lit.ynu take aul Dpov loan.This Mdal pmrenod ANNUAL PERCENTAGE RATE will than vary accadlnp m charges In the lidrx los tliubsntl aboval.For exanpl9,W.vNIph1R mal loan's Inlllol ANNUAL PERCENTAGE RATE Is 1796 el than_ tlrw you lake the lova,yyour All gcrmmU ANNUAL PERCENTAGE RATE wIM be Al Yes Initial gefonod ANNUAL PERCENTAGE RA wal ikon voryaccortsrg b the Index,as dlscbsed In lfia'VenaNa Rate prnvl6bn obava, FIX Raw Probnad Loans.nyour leen Is a prod rata loan and you quailfy for a prelarradrato,you ANNUAL PERCENTAGE RATE will bathe gererteAANNUAL PERCENT AGE RA TE dlscbsad abeva for os ton os ¢W rolmr¢d slaws lOnn .lnapect Number of Payments Amounl of Payments PaynlOnl Fmgvwcy When Payments Alo Uup Property lnsUronca'.YoU tnoy ohlatn pwnedy Yox .131.1x11.from. ho you w ni that Is a ca:able to Parman 230 $1172,36 Menthly-Beginning OEV2012008 Ule credit Union,I AD pal lha Insurance frdr�the s<h�u9 credit union you w pay .albr: 1 $1370.57 Final Due•On 07/2012028 S NIA B¢cudty:Col imalsawin9 mherloens whh lh¢toyrcdirunlan tAo 9oodsa D'opony eller YOW 5 0103 olraidlorNdeposO lnhc cyMhnunlonoond:bearori in I�being p nchewd, ❑IOesaibeh L.am Chorpo•,If a payment Is Into by t067Ys o1 moro you will Ruoqulmd OapoSh BolOnco:Tne Annual Percentage Rau duos illing Feos; Non-FINN Insumnco. be chary[ aloha ce 01576 al your xhedu ed poymcm. rotlake Into�eYwmum your rquhlentl�dcposk boloncr.,If any, $N! $NIA 'ri'W)<aMlt Y°;P.Y —'r-yea nM rve tD Poy DnMe y. ow Wmabn e�io mid s awl bNrWs MItIN n nnny"..A', n 1—vonln optymraxm a orA mowoso p�pgm rc ofd po AMOUNT FINANCED S 139,DBB.3o AmouiaPaldtoomesonyour behalf(Describe) $5.5W.a: To Wuml ReeM j To AMOU NT GIVEN TO YOU DIRECT LY$ 0.00 Stalos.54 TO DISCOVER CMD 3 To S7aT:r,ra TOOANNOPANCRIC $ To $2,101.03 To EXXON MOBIL TO 5:.::0.05 TO CAPIIALONE BA S TO AMOUNT PAID ON YOUR ACCOUNTS $89,:21.09 To PNC BANK 3 TO Sb50R.35 To PNC BANK $ i0 S Yo f To f TO s To PREPAID FINANCE CHARGE S 0.00 S To jaw To Farr f 7o NEDesPlwbns $ To uwasNuicns SECURITY INFORMATION MAKE MODEL YEAR I.O.NUMBER TYPE VALUE OTHER(Describe);130 E PORTLAND STREET MECI.IANICSBURG PA 17055 YOU Po hares AMOUNT ACCOUNT NUMBER AMOUNT ACCOUNT NUMBER mall.,Deposes of $ $ You 93PLro Ilml the)elms oro conAlbns In the di3dosuro suartr6ted and Via loan and seoUlhy a9N)"ffi8 located on papa 7 er Ihis n¢cUMmtl shell apply to Ihis ben,o there Is main man ore bonownr,we agree Ihel ell tiro e0ndclons of the loon and tit agreernuns ooverning tiro loon Shan apply V Wth JainOy end saverelly.You'[knowledge ihot you have rocalYod a copy of Bio bon one SO Carty ogroamenls and tllscWww statement.Co•slgMr.Ilyw aw signing es co signer,you ocknavleagl mcrJq or tna nodcu mcasignor contalrmd on pegs x W'1's sI NATURE BATE MA ER p'OTIIER GWNCR "CO-SIGNER DATE X Gr (si: (SEAL) 11 00-MAKER O'OTIIEROWNCR Q"COSIGNER DATE CO-MAKE CJ'OTRE OWNER "CO-SIGNER DATE X (SEAL{ K (SEAL) (] LO-WAXER C]'Ori4CROWNER p"COSIGNERDATE ] CO-MAKER O'OTHCROWNER p "CO-SIGNER UATL•' X (SCALI X (sf:AL) . '¢TiICkO'MITnI xM1iy"wyin�atNlnW ra�v��awplWxye i^^,wsw,�aWwlm W"b»�pr�ntw t^en.r">jln.lw�n^N���,y,ea..ha.ce.^,xa.i.no+ab�9el.2ku.l Y,a awl,Wl��ePWtl.tb.l YAgromivt.••m.tlak pu eawn,i^.°we unimnry t" n"rncN l,an an y,v.v nryvm.0+um^,wm u q•nvav w.ner la•.aNw.A v.N a.b'wV"Vn.,.ab°.fnW by W. NOTICE TO CO-SIGNER You re barn$asked to Puarentce this debt.Think carefully belaro you do.If the bor2ower doesnt pay the debt,you Avllt have to.Oe sure you can afford to pay I?ym1 hn a m.and t,at ou want to accept this msponsii ihty. You may have to pay up to Iho 1161 amount of Ino debt If the borrower does not pay.You may plan have to pay Inge fees or collection casts,Which increase thin ...11! Thu creditor can copDot this dub111on1 YOU without first 1 n to wllocl Irom 1118 bar r.The creditor can use the same mllecllan methods a9abisl You lnal can he used ago the uorrower,.sucn Os sutnq u.A rinlahlnp you fjos.mc.It s deW I9 aver In dBlou t,that feel may become a pal your Credit record This ne9ke is dol the contract that mnkeR Ou Imble for the doUL Pago 1 of 2 Exhibit "A" 2014/10/3011 :23:39 3 /56 hORROWFA'S kAME '"""'^•"=a ACfdukl aErawan OatEOf LOAN MARLIN E ftA9ERLE 07,2512006 kAAlEO As 80R6R AIENp5,]HE WORDS'CREOI7 UNION'MEANS MEMBERS IST FEDERAL CRG[ai UNION.lHE WO(tos'VOU;'YOUR'ANO'YOURS'MEAN illO6a I,CANAGREEMENT( SECURITY AGREEMENT th mon s'FI 0 I+e ftos:For Ya mLaNdd,you OmIsO[o n,Ol 1. To s v°apo m t of h18I n and al m Ilaa3 incurmc by Iro ur ju rheyGedq Urlro+ irq,all anwurw duo.All po is Shot be pJe vnloi°tM wi�Xo,% ��•'h Ih1 re°s, In r9n�h on a satuyfl_ ingot st,you Un A to the td`sclgs lm sllmem on t Dip fit dowmomoU gggdnl o �cr nun 4isroocati�maa3t n �k88a1� °u a on elstarid IMF 11101 nano C 1 n and to N 09Ysnonl5 shown On o o t °I"' o t s t1, �r}t. an t�tm oat nc u s o nupas°s, da A Ihat A u sl'Imor+s l o+s to t rom se rofCnY,p0tr1pUE ran any o IINS unlem arebbaesedoornl the a9sumpdon of instmtrnenntl uuo mems suranceon t�lo socaes{pl opafy Or m1&"Orgr6rlcngf,omthn wt01w tootle on the schedumd du°11mcg,and,11 yyaqU1 hovo qu. X11 or soca-'lxolx^ty. [a 10 i%t IMI you C0p[Inuo to 58listy 1 corakl sol View, Cross-=O ,ria'm r r, 9V ccur'tr for IA conn a for an �[a II you latl to piyarry Inst°k to by the Il me k is ase,you WAI pny r loan 6arowar4+o woirrl ti a tr°dk 1^°n fs°a,r Ni amounts y adcAJolf.at ln1°rosl aR thdoWrdtA amDOn4 aatrtf�ae 9 vn yr xopert Dwr U e+ Um row aglI Uw lar.tFowe y Allocation of Payments and Addhbnnl Payments:Pe memsand ypCu°r nnpr �e�t IInoQsreCU(I,1hb,Dan lrsue�+mrkoplpeeY ym ym y BOrrON'Ot elf° EOno pimps."lro pro r a013sr011 f10 OHI fV credits shell be applied In the follawlT order:any arnounls past dUo;any I�nan e�e a�no��iv iet 51 racrygremoms bra sat{i�at�).or Ora norl•pvrmoso fees or chafnBs owing Including any Inslttanco promlums;ecauod Interest f'0?' 9 Or finance cfiDr s;mistend' orlrK I.Po mems mad0 fn 0ddiUan to 7. be MJ nm thenRO tm bra;bn oL sell orumisfcr ua c°Aec°+al solea you haw nA ha y rhea air a pfbr Wr0.1on e013= P of aAy sena :I paymems s 0 b0 app0ed In the sem°aide, y You whinem hol a 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p°mens,nl.you agree to pay a late c)"'(90rgo credll un�r as dOcua scunn gore nsL t SUr K0 qnr�,'y rrlon it orw rs disdosed°n page 1 d iPils meamour(u�s�eua md+�uer1,1 alb.1�au �{s r I� ecrcXo�ma�o sxm wool Property[n$uram e;N oil allo a l�nn secur0d by a mea vetdcle or su nsuorm Ntl o su s, ,�Ia undYtA v soca rt a lSds other I�npibp n, mist radia A InslkOne wh h Islas Uro credit opens ate I tt fa�io nalryeln such Imuo ac�l n mo bW 1rOn(1 Pisa°1' I �rwl rapul°01o, la�leraoa wr nom ad (ii'e co orsWltoYSro 1 n I�e�I Ids.The amamt an coven o d to o w s owed.rola war Ver INarost m l ie cpomrea tole ua1�pp.vas funhcl Osll(anLO mUsl a pblD to th1te�Lie A union, UCh 8 to RRt1 1 as�s0�p�to m°sell avian r rx to racaNB NO aaotls of Mpy IpSu pprovtACai bast as.lire caktlrwdodAlionf cove es and fAllisten su�IT plq nV,er er°cloto•.MisuNr{o pay thoso�rorl°at�s 0u�t4ry t°ru � InsU10nL0.k mutt Lan 0 Loss a0 UI douse Onda50moni fwml the vn n,1 pinllx p da aaUA union oo^�Ip1sa a{y c aC a`.d t yov o pf YG 0 nq Ilro prpt9Pr13 d SWl brIWo11W,enU apply haio prOCa0d310 1 i0 6shrt aKYrd to croak unlpn as Ilan holder.You may o1x01n"his bsur°ncp Irom nny�Aam of tna a0a pnWn yyoo{{((rr Chace and direct the agent to send 1110 erodk union a copy a 1 1e You 1 h.amrpnlo mo anodd r unbn os�fa Ingram o Smvke Contra (wiaY• urh I�io mcessary trianb+bri la vM`oicQibnof R.rala mwragC Dabta ResponsOtlg(y:You promiso b rwdfy credit uN of an change In r act, ad Ula tnwo a a o e I lHYna. cro M t or ur lutno Ldd(asSlop, oempgymom.YCcV Momiso ria to°pay)W a bon II un°�a b tnou�°am�t to yourelMrPa '�In�i pnmhruy°p�Cl pomcliwon "rm D knOW t c IS oreasOrbUlc oowbebil ly llwt yw wAI be l7nnae Iv re nc a u n. ur o:trge"on ac�prdingp Io the t°rmS o+1(+e aedA oxlenslon,Yw pfg(�rue a ups In rodh unbn�at of a fxn a m dile grits o nes o Wonn or vnlOrl of h naW Imormolwn lulu relptos to r Wlity to dtr"Utsttea�t�e10°•a fa an 1° n�n t e�dSl aalTt��s re{11Aatl,you Dnpc a aNUro,a�Qon.Yw p'�N$c rwl to iWmu°Ise a ba ckale ppewau rorp assl1pp de umo�104 Ion.t opyy9 atom e sVVCp��"9' Y ° Vn l y all r d � 9 y Ito a00 anlan Veela h roc0awry10 p a Oar Cde umun'agaIMP oma a{n t Door pally c��omoar amalbn ar n our ate IwOrlhtrtess, ss. -adlt sending, or cap caped 7. 1lo data1a�as dsdnod lnl tan rwment anovU IaJ Veda unto Ws 0cfw)l:You shall be con3iidored In doICCuh'I p of the rollowIl occur:1) tro e11ala'a•u sena 13 m swiss arw se tyro ionalmal In bw I1 break Anyy pprrppml3C m@de�rgpr Luis Lopnrry7ypeemertl Or Udder lira manna.In c coca.lho sod or Ila solo Omon'saunPrnod 1110 greOmtmC a 12)U d ho rtwn U 1 ropros°�I�Ias me�'oro a + s bn,nm�I n cm s�+ mr�Iro $5 r A yYw 0 n01 U50 l Cy 1110 Oda Un101 ca�t rn c I sats on N m a s cunt, Iwr w la the U Se sleled in t e Ica ort;LY(3)d llw credll unbn�ler r�l°r011d1F�1lo SFrd�°i I�ie uop°nydoaka� M1S Ia¢r u66s °r{U UmOn m pOPt)coir,beaeve UL7l�pprOSpC�L,tta to I.DOdampno ma silos^aiho co alaol al lxaM1ises al my01a° I the Or rt 7A a+of ito lefek if n.I9 i(n dCU:a l^)d you Ole;of a tat decroesI uA. c Val els Isatin, ��rvrvas sac�(p pp l p y Da w^ sgWl pc lea,tnp(Oda ntolladpY Io +hn{mo0m you hiB B Fenn an UpI[Y ki3dVOnCy Of leCOlVf1f3111p a 8rByUI ate,ill Inc Man0141 � R. (10{far Ila 1 IIW q a d °s ia411 fnvOhlnlall I'0 sVcrl U1°000G•ngS:Of(6'll•Ih0 e01W1°ra4 I'BrtY p`Yef1 asrinaeen urn ss iw e� o ccc000tQelah°a �v�on masaeiss �bs,.", aslrop ,aC A I5•IC? foV °o�rpons°�r��n Ino rain .I."A andyns lad or rn shed;ar O l�yw dO not Vloy on irme anutyao your I^g cal1 aue m 1 a a e oI me kra. n uo0 r a slue tfCRls a lh0 a0 k r If w defy 6 l credit On may, ^ w ��Sao an8p asylalongq 9?BCnsos,tQa�nid el the-edit sheens o on oM without pear nolke,declare this bon u�roax. u ecu poSSS SS a 1 ry halm, .frior:rfanr� ImmadbtelIyy due CVC ria,oral Voll mfrs;hnmpd�meN a9y la the Credit a anvulRO�Ii amo00r tons�Smm va.�en°axnenl w rA�i Iruswunw lm n of IhOi tuna a elIA1paW lsa"I�rtLfi�n5 Wa9 Os Ihb F1nanGe Gl+arge on elle toll rorat,y dxi stand 1 1 1 o do union Aas ro n r 10 a((q anyy Iola CJp�lagCsnrxfcoslsor colledlon rmt1lad andgr law. - agalmmad�Os aI�i°io mcRdcvnbnlnpar)1a Untfam °rmm c 1 led rd03 nOlB Bila 31 M.Ih011hO CrCV1110n Inn inCUl,t to ata nd mhan h a a mine 0a unanm u3c1 ( as Ng °'k ill IDenlace a all data f t uwplto�n u AU 20yG of NB unpaid pri+rc�ai Sod ImCrosl.Costs o(co0ottlon IAcNdo,but are rcowv asSib a t 1pro�rrot�n roew:ii°vcko t° m ur. noir�llmit to,repossess on lues apple als,environmental silo unpn e1 a ��co p1 ec tl1 s c s IM c edit u s to nssessmoms casuoWdamagefriwancecoveig prdallaneysToes!°r wand Uva�dadLNw7l rot uxWflaa wo IW any OVII.bseguerl delauks. anVyac to b�1� allar�a In Ardor til co11 ct Zoon of preservo� a. The uokm is olgpv pp haed as our ADD mcytn•Foa t4 pp d", prdaclh°aeAAnsrinhlsyBndremodlC;,IncNdt tvil7wUlOmppllon, oaf�nouiuryRllpGAlia°tar.�sI�'1°wokutnocoilJicrelend�ia ple•s tAemandsppBeynfbra pQresultme ofl, ar,ukl1t1lent sat y rest cnmfia0memrr ao0 rte 1 'bns, � 0. Il hero more n nnoa7Wa Dal tons c rlNsa c Imo tion Inptnl and 0evas to -digague rosp°nrb IorNr`Rro tot so�s ar IuuDDpplppryd s at cb1m,ppursvin re f nnafron RgrrepmalAs. °A10Aran's' OIICn n CUt1gs 7 aCOkas,and pufslriny cp�pmpgfa�rxs,m01Pfp15 anU 10, lir s sw 119 mom lre nor only bods you,but yaw os°mom admWsuaras, pb}eUlolrgt5 I reTTBte n an w° 101{tO aeQallfFUNrn1s colla emit to to Mas,o els pa nrN),Do rual l�supooAlai ndl•bankruupplcY sVks and�or°drtdn9sl+nirva • boons.onJ appeals.Tho princlpm balancrrM ootaull shag bear Inlaosl et tl10 calaea rata. SlntulorPDl,ien:)l ypu are I�defe0.to°rd Lely nNas the credit Union the M to a iY rho bblancc 0 shoes a dvldclds in YYo0ur n vwnl(sl el 1 0 Ume IOWI Io soll�ryy Nil Ipan.Onto you oro tri.tout1.Iho ere 11 union may exercise Ihb r g1+1 vrohout lunher notice loyou, Oalny In En=t:Crca1 Urdm ton ds)++y anfordnq any d the ae�I ull all r Ms undo ads agroelrant w)thatr�IDS l am. IHegUlar Payments:The croak Ireton may accept Ipt°ps7mems or pial n:,Oven dl h maarked'payyma�tl m IAI,vnihoal mmg nny o llm Q�Di mr�ghis Under IfYa ogleOrhOnl. Cw :fi are slynlnq tills adreemont as a co•m°k°r,you ntl�ee to bn eahGtOp 7100 1 ruteaso enf�socurky w�lhuut raUfy�r q or telcos ng you from espcxlsdnl ly un lits ngr entcN. Carxmaluel Madge of Shaosl YOU ptaoge ell your-nares end'foralts In the Vault UnWn,UCWdlrlg rutaeeaaadan OS SCcwl"'Or Ih13 Lauri In Oesf.'yw dmaun.the credourdminneeyyaappIII ytnnsuanarosand dotseStstoUtepayinom of allsaes d at the 07fdefaUthlneNdingcasts of cosceUon and. maa0neau alar,e7r's bas,Rlel°yyf1 credll unbn may bear.up to 70%of Um urpeld pPlrcb01 and kllorOH.No Aanor right In Imwazs o Ibn on shahs and da{wsll3 shall)nsx,ty m toryry I your slnrus wink^may ba rob to an"hdlNUuol Rothumorx Accawlt'Ol R VELI Wan," Pago 2 of 2 ALL that certain piece or parcel of land having thereon eructed A one and one-h41f story brick building, bituato in the Borough of Mechanicabur9, County of Cumberland and State of Pennsylvania, bounded and doscribed as followo, to wit: BEGINNING at a pnInt at the southwesternmost corner of East Portland Street and Race Street; thence along the weotern line of RaCe Street, South 99 30' East, 160 feet to a point on the northerly line of a public alley; thence in a weeterl,y direction along the no=herly line of said alley, South 810 52' West, 6o teat to a point at line of I&td now or formerly of Edward Ryles thence alonV the landa Of Edwdrd Kyle, North 99 30' west, 160 teat to a polnt on the southern line of East PprtlAnd Street; thence along the south6m line of Eaot Portland Street, North 81° 52' East, 6o fcQt to a point being the place of BEGINNING. FLAVING THEREON erected a one and ori*-halt, story brick building and being known and numbered as 130 rust Portland Street, Known and numbered as 130 East Portland Street, Mechancisburg, PA 17055 Being the same premises which Tammy L. Magaro by her deed dated June 9, 1997 and recorded in the Cumberland County Recorder of Deeds Office at Deed Book 159, Page 271 granted and conveyed onto Tammy L. Magaro and Marlin E. Kaberle. Being Tax Parcel No.: 18-22-0519-107 Exhibit "B" 2014/10/3011 :23:39 6 /56 Prepared By, Members Ist FCU 5000 Louise Drive Mechanicsburg,PA 17055 . : Members 1st FCU Real Estate Department 5000 Louise Drive Mechanicsburg,PA 17055 (717)-795-6026 Parcel Number: 18-22-0519-107 MORTGAGE Made 07/25/2008 Between TAMMY L MAGARO AND MARLIN E KABERLE � ' (hereinafter called ortgagor And MEMBERS IT FEDERAL CREDIT UNION (hereinafter called"Mortgagee") Whereas,Mortggagor has executed and delivered to Mortgagee a certain Mortga a Note(hereinafter called the"Note") of even date herewith,payable to the order opMortgagee in the principal sum of $ 139,088.30 ,lawful money of the United States of America,and has provided therein for payment of any additional oneys loaned or advanced thereunder by Mortgagee,together with Interest thereon at the rate provided in the Note,In the manner and at the times therein set forth,and containing certain other terms and conditions,all of which are specifically incorporated herein by reference; Now,Therefore,Mortgagor,In consideration of said debt orprincipal sum and as security for the payment of the same and interest as aforesaid,together with all other sums payable hereunder or under the terms of the Note,does grant and convey unto Mortgagee, All that certain property of the Mortgagor located it> NMCHANICSBURG ROROUGH I Cumherland County, Pennsylvania PLEASE SEE ATTACHED EXHIBIT"A" which currently has the address of_. 130 E PORTLAND STRZL-T _ [Street] MECHANICC_$ URG Pennsylvania 170 (City] [Zip Code] Acct No — App Page 1 of 4 Exhibit "C" 2014/10/3011 :23:39 7 /56 Together with the buildings and improvements erected thereon,the appurtenances thereunto belonging and the reversions,remainders,rents,issues and profits thereon, To Have and To Mold the same unto Mortgagee,its successors and assigns,forever. Provided,However,That if Mortgagor shall pay to Mortgaee the aforesaid debt or princl al sum, Including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder and under the terms of the Note,together with interest thereon,and shall keep And perform each of the other covenants,conditions and agreements hereinafter set forth,then this Mortgage and the estate hereby granted and conveyed shall become void, This Mortgage is executed and delivered subject to the following covenants,conditions and agreements: (1) The Note secured hereby shall evidence and this Morttggage shall cover and be security for any future loans or advances that maybe made by Mortgagee to Mortgagor at anytime or times fiereafter 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 sold 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 m•might have priority in lien or payment to the debt secured hereby,(b) pa all ground rents reserved from the mortgaged premises and pay and dischargge all mechanics'liens which may be filed against said premises and which shall or might have priority in len 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 secured hereby, (d)provide,renew and keep alive by paying the necessary premiums and charges thereon such policies of hhazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in Favor of Mortgagor and Mortgagee as their respective interests may a pear, and(e)promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges;provided,however,that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges be paid in installments ttr Mortgagee. (3) Mortga or shall maintain all buildings and improvements subject to this Mortgage in nod and substantial repair,as determined by Mortgagee. Mortgagee shall have the right to enter upon the mortgaged remises at any reasonable hour-for the purpose of inspecting the order,condition and repair of the buildings and improvements erected thereon. Acct No AppIR Paco 2 of A 2014/10/3011 :23:39 8 /56 (4) In the event Mortgagor neglects or refuses to pay the charges mentioned at(2) above,or falls to maintain the buildings and improvements as aforesaid,Mortga ee may do so,add the cost thereof to the principal debt secured hereby,and collect the same as a part M'said principal debt. (5) Mortgagor covenants and agrees not to create,nor permit to accrue,upon all or any part of the mortgaged premises,any debt,lien or charge which would be prior to,or on a parity with,the lien of this Mortgage, (G) In case default be made for the space of thirty(30)days lit the payment of any installment of "Inclpal 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 Mortga ee 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 Mortga a and prosecuted to Judgment,execution and sale for the collection of the same,together with costs Y'sult and an attorney's commission for collection of five percent(5%)of the total indebtedness or $200,whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings,waives stay of execution,the right of inquisition and extension of time of payment,agrees to condemnation of any party levied upon by virtue of any such execution,and waives all exemptions from levy and sale of any property that now is or hereafter may be exempted by law. (7) Upon payment of all sums secured by this Mortgage,this Mortgage and the estate conveyed shall terminate and become void. Alter 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 l'or services rendered and the charging of the fee is permitted under Applicable Law, The covenants,conditions and agreements contained in this Mortgage shall bind,and the benefits shall Inure to,the respective parties hereto and their respective heirs,executors,administrators,successors and assigns,and if this Mortgage is executed by more than one party,the undertakings and liability of each shall be Joint and several. Am No AppD Pago 3 of A i 2014/10/3011 :23:39 9 /56 Witness the due execution hereof the day and yea first above written. MMY L MAGARd MARLIN E KABERLE Commonwealth of Pennsylvania ss: Countyof Cumberland ) On tills,the 25th day of July 2008 before me, Beverly 1 organ the undersigned officer,personally appeared tAMM Y I MArAgQ AND MART M F KARFRI F satisfactorily proven to me to be the person(s)whose name(s)is/are subscribed to the within Mortgage,and acknowledgc;d that he/she executed the same for the purposes therein contained. In Witness Whereof,I hereunto set my hand and official seal. My commission expires: Certificate of Residence of Mortgagee Members Ise' Federal Credit Union,Mortgagee within named,hereby certifies that Its residence Is 5000 Louise Drive,Mechanicsburg,PA 17055. By _ Acc!No AppID_ _ Page 4 of a COMMONWEALTH 01 EN SY VANIA Notarial Seal Beverly K.Morgan,Notary Public Upper Allen Twp.,Cumberland County My Commission Expires July 7,2009 Member,Ponnaylvanis Association of Notaries 2014/10/3011 :23:39 10 /56 EXHISIT "A" LEGAL DESCRIPTION A PARCEL OF LAND SITUATED IN THE STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND, WITH A STREET LOCATION ADDRESS OF 130 E PORTLAND ST; MECHANICSBURG, PA 17055 CURRENTLY OWNED BY TAMW L MAGARO AND MARLINE KAIBERLE HAVING A TAX IDENTIB'ICATION NUMBER OF 18-22--0519--107 AND BEING THE SAME PROPERTY MORE FULLY DESCRIBED IN BOOK/PAGE OR DOCUMENT NUMBER 159-271 DATED 6/12/1997 AND FURTHER DESCRIBED AS LOT 1 PB 40 PG 16 RESIDENTIAL BUILDING. 18-22-0519-107 130 E PORTLAND ST; MECHANICSBURG, PA 17055 274334 IIIII111110 011pl KABERLE 38170142/£ 381 0142 PA FIRST AMERICAN ELS MORTGAGE 111II1II IIIit111 ml IIp111111I!IIII II III I I V1lI WHEN RECORDED RETURN TO: Equlty Loan Services, Inc. 1100 Superior Ave., Ste. 200 Cleveland, OH 44114 National Recording-106 2014/10/3011 :23:39 11 /56 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY '--�- • 1 COURTHOUSE SQUARE, CARLISLE' .PA 17013 ,. 717-240-6370 Instrument Number-200827208 Recorded On 8/11/2008 At 9:46:55 AM Total Pages-6 *Instrument Type-MORTGAGE Invoice Number-26779 1User ID-AT *Mortgagor-MAGARO,TAMMY L *Mortgagee-MEMBERS 1ST FEDE RAL CR UN *Customer-TIRST AMERICAN *FEES STATE VW T TAX $0.50 Certification Page STATE JCS/ACCESS TO $10.00 JUSTICE DO NOT DETACH RECORDING FEES. - $13,50 RECORDER OF DEEDS AIrFORDABLE HOUSING $11.50 This page is now part COUNTY ARCHIVES FEE $2.00 of this legal document. ROD ARCHIVES FEE $3,00 TOTAL PAID $40.50 I Certify this to be recorded in Cumberland County PA uy /D 4 RECORDERO r Z DS w -Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 000� If Illlllllllllilllllllllll 2014/10/3011 :23:39 15 /56 (Rev.9/2008) Date: September 15,2014 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_Snecafic information about the nature of the default ;s provided in the attached pages. The HOMEOWN , 'S EMER ENCY MORTGAGE A USTANCE PROGRAM(HEMAP) may be able to bel n cave your home This Notice explains how the program works. To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUN��LING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NQ ICE Take this Notice with you when you meet with the-Counseling Age neX. The name, address and phone number of Consumer Credit Coun eling Aggneies serving_vour County are listed at the end of this Notice Tf you have any auestions ou may call the I Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Perconc with impaired Baring can call 717 -1869), I This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA.NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERE CHO A REDIMIR SU HIPOTECA, Page l of S Exhibit "D" 2014/10/3011 :23:39 16 /56 HOMEOWNER'S NAME(S): TAMMY L MAGARO MARLIN E KABERLE PROPERTY ADDRESS: 130 E PORTLAND STREET MECHANICSBURG,PA 17055 LOAN ACCT.NO.: ORIGINAL LENDER: Members l"Federal Credit Union CURRENT LENDER/SERVICER: Members 1"Federal Credit Union HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN �AVEADUR HOME FROM FOR E CLQSURF„AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTa 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_MEE1lN_G_hIJST OC .UR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THTC 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",EXPLAI.NS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING NSEI IN AGENCIES--.If you meet with one of the consumer credit counseling agency listed at the end of this notice, the-lender may NOT take action against you for thirty (30) days after the date of this meeting. The names,addresses and telephone numbers of designated consumer credit counseling agencies for the 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 i 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 PIMA and received within thirty(30)days of your face-to-face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING,THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE STOPPED. Page 2 of 5 2014/10/3011 :23:39 17 /56 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 tiled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). SURF,OF THF,DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 130 E PORTLAND STREET MECHANICSBURG,PA 17055 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: $1,34126 for April 20,2014,$1,370.63 for May 20,2014,$1,370.63 for J1.1 no 20,2014,$1,370.63 for Aily 20,2014,$1770.63 for August 20,2014 Other charges(explain/itemize): TOTAL AMOUNT PAST DUE: x6,823.78 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION(Do not use if not applicable): 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 $ 6,823.78 , 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 pale and sent to: Members la'Federal Credit Union,ATTN: Lynn Unger 5000 Louise Drive Mechanicsburg,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 2014/10/3011 :23:39 18 /56 IF YOU DO NOT CURE la' --If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to cx rcisp its rights to Re cel ra he 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 neon yo,r mo ffanpd nrnpor IF THE MORT(ACDF I FORT O +D UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However,if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If von cure he default within the T111RTY DAY period•you will Iiot be req uir d to pay attorney's fees, OTHER>::ENDER REMFDiF --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 un 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. FARLiEST POSSIBLE SHERIFF'S SALE DAT --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 10 CONTACT THE I,F,NDFR: Name of Lend r; MemhPrs 1ST r+'arinrnl ltirnrii4 IT.,,.,., Address: SOOd Louise illrivn Mpchanicshn,r9.PA_ 17055 Phone Number: (717)795-51 nr{ Ql 1 'QT'z�Q r rinn i Sao Fax Number: (717.)295,52Q7 Lontaet Person: Lvnn IInge F-Mai1Addr ngeE(Linemberslstorg EFFECT OF SH .RITE'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to Iive 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. Page 4 of 5 2014/10/3011 :23:39 19 /56 YOU MAY ALSO A { THF RI >FIT• • 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. CONS IM+,R CRE4 DIT COUNSELING AGENCIES-SERVING YOUR COUNTY (Fill in a list of all CounselinP Agencies listed in Aggadix C FOR THE COUNTY in which the nrgizaay is located, using additional gaga if necessa&A Certified Mail # 9171999991703440719012 i I i i Page 5 of 5 2014/10/3011 :23:39 28 /56 YOU MAY ALSO HAUL TFIE 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 1N ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY .HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. -CONSUMER CREDIT CO 1N +I IN T a GENC1L� S �RVING OUR COUNTY MI-1 i a.l' all Co e. e c e E T CQUATYe located. usiaad itioral pamesif necessaa), Certified Mail # 9171999991703440719049 Page 5 of 5 2014/10/3011 :23:39 42 /56 YOU MAY ALaQ HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE.MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY jFill in a list of all CounselingALen cies listed in Appendix C. FOR THE COUNTYin which the jzM erty is located. using additionalga=if'necessary). Certified Mail # 9171999991703440719036 Page 5 of 5 2014/10/3011 :23:39 20 /56 Servicemembers Civil U.S. Department of OMB Approval 2502- Relief Act Notice Disclosure Housing 0584 and Urban Development Exp 1113012094 Office of Housing Legal Rights and Protections Under the SCRA Servicemembers on"active duty"or"active service,"or a spouse or dependent of such a servicemember may be entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act(50 USC App. §§501-597b)(SCRA). Who May Be Entitled to Legal Protections Under the SCRA? • Regular members of the U.S.Armed Forces(Army,Navy,Air Force,Marine Corps and Coast Guard). • Reserve and National Guard personnel who have been activated and are on Federal active duty • National Guard personnel under a call or order to active duty for more than 30 consecutive days under section 502(f)of title 32,United States Code,for purposes of responding to a national emergency declared by the President and supported by Federal funds • Active service members of the commissioned corps of the Public Health Service and the National Oceanic and Atmospheric Administration. • Certain United States citizens serving with the armed forces of a nation with which the United States is allied in the prosecution of a war or military action. What Legal Protections Are Servicemembers Entitled To Under the SCRA? • The SCRA states that a debt incurred by a servicemember,or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6%duringthe period of 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 Servicemember or Dependent Request Relief Under the SCRA? • In order to request relief tinder the SCRA Prom 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 Iender 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-riles for indicia of military 2014/10/3011 :23:39 21 /56 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 Servicemember 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 http://Iegalassistance.law.af.mil/content/locator.php • "Military OneSource"Is the U.S.Department of Defense's Information resource.If you are listed as entitled to legal protections under the SCRA(see above),please go to www.mllltaryonesource.com/scra or call 1-800-342-9647(toll free from the United States)to find out more information.Dialing instructions for areas outside the United States are provided on the website. i I i I 1 r v 2014/10/3011 :23:39 22 /56 HENUP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated:09/09/2014 09:34 AM Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestowu Road 1514 Deny Street Harrisburg,PA 17102 Harrisburg,PA 17104 888-511-2227 717-232-9757 Housing Alliance of York/Y Housing Resources Maranatha 290 West Market Sheet 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 E High Street 211 North Front Street Gettysburg,PA 17325 Harrisburg,PA 17110 717-334-1518 717-780-3940 800-342-2397 10/30/2014 15:46 7179320317 KARLLEDEBOHM PAGE 08/08 MEMBERS 1 S'�FEDERAL IN THE COURT OF COMMONPLEAS CREDIT UNION ; CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANT{S} : CIVIL ACTION-LAW MORTGAGE FORECLOSURE V'ERIKCATI ON I,Jen.ni.fer Perry, Collateral. Liquidation Specialist for Members I11F ederal Credit Union, being authorized to do so on behalf of Members 1"Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my infortnation knowledge and.belief. I understand that false statements are made subject to the penalties of 1$ Pa. C.S.A. Section 4904,relating to unsworn falsification to authorities. Members 1"Federal Credit Union Date: October,36 , 2014 tr",'fr P i , Collatera.l quidation ist 7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson I" Vii... ;tO..'OF lCL Sheriff _ _ `' key }` THE t'RO THL'HU1. Jody S Smith Chief Deputy Richard W Stewart Solicitor F THE SHERIFF 201ii NOV 20 PH 3: R CUMBERLAND COUNTY PENNSYLVANIA Members 1st Federal Credit Union vs. Marlin E Kaberle (et al.) Case Number 2014-6456 SHERIFF'S RETURN OF SERVICE 11/06/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 130 E. Portland Street a/k/a 130 East Portland St, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant. 11/07/2014 05:34 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Marlin E Kaberle at 7115 Salem Park Circle, Hampden Township, Mechanicsbur. A 17050. �f,A/ �/y►I ` ram GU ALL, DEPUTY 11/10/2014 08:34 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Tammy Magaro at 1052 Country Club Road, East Pennsboro Township, Camp Hill, PA 17011. ISTO SHARPE, DEPUTY SHERIFF COST: $99.04 SO ANSWERS, November 14, 2014 (c) CountySuiie Sheriff, Teleosoft, Inc. RONNY R ANDERSON, SHERIFF Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 14-6456 : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY: Please enter judgment in the above captioned proceeding in favor of Members 1St Federal Credit Union, Plaintiff, and against the Defendants, Marlin E. Kaberle and Tammy L. Magaro, in the amount of ONE HUNDRED THIRTY-THREE THOUSAND ONE HUNDRED SEVENTY-THREE AND 48/100 ($133,173.48) DOLLARS, plus interest at the rate of $28.5627 per day from December 16, 2014 through the date of judgment and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other charges collectable under the mortgage and for foreclosure and sale of the mortgaged property. Judgment is entered pursuant to Pa. R.C.P. 1037 for failure to file an Answer on behalf of Marlin E. Kaberle and Tammy L. Magaro to Plaintiff's C61 Complaint within twenty (20) days of service thereof and after a 10 -day Notice was sent. Date: December 15, 2014 Res mitted, edebohm, Esqui e Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff I hereby certify that notices of intent to take a default judgment were forwarded to Marlin E. Kaberle and Tammy L. Magaro by United States Mail, First Class, postage prepaid on December 2, 2014. The aforesaid notices were each contained within an envelope bearing the return address of the undersigned. The notices sent to the defendants at the mortgaged property have been returned as "not deliverable as addressed unable to forward". A copy of the returned envelopes are attached hereto and marked Exhibit "A". The notices sent to the last known addresses of the defendants have not been returned to the undersigned as undeliverable or otherwise. A copy of the notice and Postal Forms 3817 are attached hereto and marked Exhibit "B". . Ledebohm, Esquire IND l!q!4x3 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 Tammy L. Magaro 130 E. Portland Street a/k/a 130 East Porth, ' • Mechanicsbur! N.I.XI"E 17 6,. N'7'l_" °1:• .14 Z -Z1 Z- 0 9'-j::1:.4•:. RETURN TO SENDER NOT DELIVERABLE AS ADDRESSED UNABLE TO FORWARD BC: 17070017373 *0219-95130-02-46 17 677 6(4617 illi1141111{ts11{111illtll{Illtstlllllll!!t{rlilllll!lils{1.111 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 Marlin E. Kaberle 130 E. Portland Street a/k/a 130 East Portlarfi;.,, Mechanicsburg, r.. . - 17UI Ut xnit r • L} 176• N:7E' ZZ1,Z/ 09412 RETURN TO SENDER 'NOT DELIVERABLE AS .ADDRESSED UNABLE TO FORWARD BC: 1707 0017373 *0219-05127-'0Z-46 Illllllllll{1111{l11111111{Il1111111111irltillrlilillillirflll _ Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 ST FEDERAL CREDIT UNION PLAINTIFF Vs. MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANTS Date: December 2, 2014 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 14-6456 : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Marlin E. Kaberle 7115 Salem Park Circle Mechanicsburg, PA 17050 Tammy L. Magaro 1052 Country Club Road Camp Hill, PA 17011 Marlin E. Kaberle 130 E. Portland Street a/k/a 130 East Portland Street Mechanicsburg, PA 17055 Tammy L. Magaro 130 E. Portland Street a/k/a 130 East Portland Street Mechanicsburg, PA 17055 PURSUANT. TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED Exhibit "B" WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 Date: December 2, 2014 Respectful u.mitted, M Ledebo , Esq. upremCourt ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff avAliTED STATES Certificate Of POSTAL SERVICE0. Mair This Certificate of Mailing provides evidence that mad has been presented to IJSP$St for n This form may be used for domestic and international neail From: * Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To: • Tammy L. Magaro 130 E. Portland Street a/k/a 130 East Portland Street - Mechanicsburg, PA 17055 PS Form 3817. April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE ' Certificat Ma CC tnis Certificate of Maifing pros,des s-,••cfef-.e Iffa ma- has 55r, eFeseNeo to USPS! 0_ ittmfo.-4-11 may be used for dornests: ard ,fsernabo,a0 atilt uJ • 0 Ca t<5. E F tom To _ Karl M. Ledebohm, Esq. If P.O. Box 173 7. ! New Cumberland, PA 17070-0173 — Marlin E. Kaberle — 130 E. Portland Street a/k/a 130 East Portland Street Mechanicsburg, PA 17055 PS Form 3817, April 2007 PSN 7530-02-000-9065 0 urvi tDifir ES POSTAL SERVICE0. Certificate — Mail This Certificate of Mailing provides cadence ihai matt has been presented to USPS® for rrr This form may be used for domestic and tatemaltonal riI From: Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To — Marlin E. Kaberle 7115 Salem Park Circle Mechanicsburg, PA 17050 a_ LU CD CI CC Z sr (17) 6 crmr--=,0 'G.E-. 1t • 'C.) LU Id% Z • I JL - PS Form 3817. April 2007 PSN 7530-02-000-9065 Certificate C PP-_...dide POSTAL SERVICE: ' Mailin thiSCerlii.Cate Or Maffing ofovfoes evslef Ira era nas pet, ufeseh:eo lc USPS2IC, "Ss-nl. this form may be used tor doroestfe and interhatfo,-, road From _ Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To Tammy L. Magaro 1052 Country Club Road — Camp Hill, PA 17011 ‘t.' • '77 • " 4 cc a. Lu • (.3 c) cn CE Z T — r=T ......._ ...._ ,/, _,..- ,-- MC° -Nr:Dcorcr--- .z S....4., P:\17 4.T7 uJ '..7 •CI -X—. cr, .6, .-J� w '13 ° "s. PS Form 3817. April 2007 PSN 7530-02-000-9065 0 0 cp Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANTS DEC2014 16 4111.28 CUl`iD[F`,^ >, 0 COUNTY IN THE COURT OF COON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-6456 : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE The undersigned hereby swears and affirms on behalf of Members 1St Federal Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff's knowledge, Marlin E. Kaberle and Tammy L. Magaro are not currently on active military service. Date: December 15, 2014Abe Respect , y submitted, AllIdAwarA Karl . Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 205,11:i P:-; 2:45 C� ;SYLVA�';IA MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 14-6456 : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, Amount Due: Interest from: Attorney's fees Costs $133,173.48 12/16/14 at the legal rate thereafter to be added $ to be added $ to be added Directed to the Sheriff of Cumberland County, Pennsylvania; To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the following real property: All that certain real estate and improvements erected thereon situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, known and numbered as 130 E. Portland Street a/k/a 130 East Portland Street, Mechanicsburg, PA 17055 and as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof by reference. °►9. oy CSF << • So l ll Dated: January 9, 2015 ebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN piece or parcel of land having thereon erected a one and one-half story brick building, situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point at the southwesternmost corner of East Portland Street and Race Street; thence along the western line of Race Street, South 9 degrees 30 minutes East, 160 feet to a point on the northerly line of a public alley; thence in a westerly direction along the northerly line of said alley, South 81 degrees 52 minutes West, 60 feet to a point at line of land now or formerly of Edward Kyle; thence along the lands of Edward Kyle, North 9 degrees 30 minutes West, 160 feet to a point on the southern line of East Portland Street; thence along the southern line of East Portland Street, North 81 degrees 52 minutes East, 60 feet to a point; being the place of BEGINNING. HAVING THEREON erected a one and one-half story brick building and being known and numbered as 130 East Portland Street, Mechanicsburg, PA 17055. BEING the same premises which Tammy L. Magaro by her deed dated June 9, 1997 and recorded in the Cumberland Recorder of Deeds Office at Deed Book 159, Page 271 granted and conveyed onto Tammy L. Magaro and Marlin E. Kaberle. Tax Parcel No.: 18-22-0519-107 Exhibit "A" Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 14-6456 : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1St Federal Credit Union, plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, known and numbered as 130 E. Portland Street a/k/a 130 East Portland Street, Mechanicsburg, PA 17055. 1. Name and address of owner(s) or reputed owner(s): Marlin E. Kaberle 7115 Salem Park Circle Mechanicsburg, PA 17050 Tammy L. Magaro 1052 Country Club Road Camp Hill, PA 17011 2. Name and address of defendant(s) in the judgment: Marlin E. Kaberle 7115 Salem Park Circle Mechanicsburg, PA 17050 Tammy L. Magaro 1052 Country Club Road Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1St Federal Credit Union Attn.: Jennifer Perry, Collateral Liquidation Specialist 5000 Louise Drive Mechanicsburg, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: Members 1St Federal Credit Union Attn.: Jennifer Perry, Collateral Liquidation Specialist 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: Borough of Mechanicsburg c/o Lisa Marie Coyne, Esquire 3901 Market Street Camp Hill, PA 17011 Borough of Mechanicsburg 36 W. Allen Street Mechanicsburg, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Inheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 130 E. Portland Street a/k/a 130 East Portland Street Mechanicsburg, PA 17055 U.S.A U.S. Dept. of Justice U.S. Attorney, Federal Building 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-1754 US Department of Justice Attn.: Housing & Civil Enforcement Section 950 Pennsylvania Ave., NW Washington, DC 20530-0001 Internal Revenue Service Advisory Grotp, Room 704 1000 Liberty Avenue Pittsburgh, PA 15222 Internal Revenue Service 600 Arch Street, Room 3259 Philadelphia, PA 19106 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: January 9, 2015 i ubmitted, edebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929. t , MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. MARLIN E. KABERLE and TAMMY L. MAGARO DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 14-6456 : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Marlin E. Kaberle 7115 Salem Park Circle Mechanicsburg, PA 17050 Tammy L. Magaro 1052 Country Club Road Camp Hill, PA 17011 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 130 E. Portland Street a/k/a 130 East Portland Street, Mechanicsburg, PA 17055, as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof, is scheduled to be sold at Sheriffs Sale on June 3, 2015 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $133,173.48 plus interest from 12/16/14 at the legal rate thereafter until the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs and additional reasonable legal fees, if any, and other costs and charges collectible under the mortgage, if any, or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938-6929. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your house (real estate) will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at the County Courthouse, which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate) until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before (within thirty (30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed by the Sheriff. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 The Sheriffs phone number is: (717)240-6390. arl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN piece or parcel of land having thereon erected a one and one-half story brick building, situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point at the southwesternmost corner of East Portland Street and Race Street; thence along the western line of Race Street, South 9 degrees 30 minutes East, 160 feet to a point on the northerly line of a public alley; thence in a westerly direction along the northerly line of said alley, South 81 degrees 52 minutes West, 60 feet to a point at line of land now or formerly of Edward Kyle; thence along the lands of Edward Kyle, North 9 degrees 30 minutes West, 160 feet to a point on the southern line of East Portland Street; thence along the southern line of East Portland Street, North 81 degrees 52 minutes East, 60 feet to a point; being the place of BEGINNING. HAVING THEREON erected a one and one-half story brick building and being known and numbered as 130 East Portland Street, Mechanicsburg, PA 17055. BEING the same premises which Tammy L. Magaro by her deed dated June 9, 1997 and recorded in the Cumberland Recorder of Deeds Office at Deed Book 159, Page 271 granted and conveyed onto Tammy L. Magaro and Marlin E. Kaberle. Tax Parcel No.: 18-22-0519-107 Exhibit "A" THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net MEMBERS 1ST FEDERAL CREDIT UNION Vs. NO 2014-6456 Civil Term CIVIL ACTION — LAW MARLIN E. KABERLE AND TAMMY L. MAGARO WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $133,173.48 L.L.: $.50 Interest 12/16/14 AT THE LEGAL RATE THEREAFTER TO BE ADDED Atty's Comm: Atty Paid•# 9. Plaintiff Paid: Date: 1/14/15 (Seal) REQUESTING PARTY: Name: KARL M. LEDEBOHM, ESQUIRE Address: P.O. BOX 173 NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 Due Prothy: $2.25 Other Costs: David D. Bue 1, Prothonota Deputy