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HomeMy WebLinkAbout14-6510s E C T 0 N A s E C T I 0 N B Supreme Court of Pennsylvania Court of Common Pleas Civil Cover Sheet Cumberland County For Prothonotary Use Only: M Complaint • Writ of Summons • Docket No: ILI — (0510 n 0v I I&rm 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: M Complaint • Writ of Summons • Petition • Notice of Appeal • Transfer from Another Jurisdiction • Declaration of Taking Lead Plaintiff's Name: Members 1st Federal Credit Union Lead Defendant's Name: Raymond Nicholson a/k/a Raymond L. Nicholson, et al. -Represented (Pro Se) Litigant • Check here if you are a Self Name of Plaintiff/Appellant's Attorney: Karl M. Ledebohm, Esq. Dollar Amount Requested: within arbitration limits Are money damages requested? : ©Yes • No (Check one) N/A outside arbitration limits Ls 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) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Other: MASS TORT ❑ Asbestos 0 Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABLITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: Pa.R.C.P. 205.5 CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other 0 Other: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute ® Mortgage Foreclosure ❑ Partition ❑ Quiet Title 0 Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Zoning Board ❑ Statutory Appeal: Other Judicial Appeals ❑ MDJ - Landlord/Tenant 0 MDJ - Money Judgment ❑ Other: MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non -Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin 0 Other: 2/2010 0/ Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 LEO-OFFIC7 OF THEPROTHCNSTARY N ti NOV 10 AK II: 211 CLIMBcRLAND COUNTY PENNSYLVANIA MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 14 6151 Qiv .11-Tre,M1 RAYMOND NICHOLSON a/k/a RAYMOND L. NICHOLSON and TARNUM NICHOLSON a/k/a TRANUM NICHOLSON : 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 FEE. 4 115.15 Pi) ATH a3cip Rif 3 isaas 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 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 CONOCES UN ABOGADO, VAYA EN PERSONA 0 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 1ST FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Vs. : NO.: RAYMOND NICHOLSON, a/k/a RAYMOND L. NICHOLSON and TARNUM NICHOLSON a/k/a TRANUM NICHOLSON DEFENDANT(S) : CIVIL ACTION -LAW : MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes Members 1 st 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 Pt Federal Credit Union ("Members Pt"), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2, Defendant, Raymond Nicholson a/k/a Raymond L. Nicholson ("Raymond Nicholson"), is an adult individual having a last known address of 38 % Summit Street, Harrisburg, PA 17101. 3. Defendant, Tarnum Nicholson a/k/a Tranum Nicholson ("Tarnum Nicholson"), is an adult individual having a last known address of 13 Logans Run, Enola, PA 17025. Raymond Nicholson and Tarnum Nicholson are collectively referred to herein as "Defendants." 4. On or about April 12, 2013, Defendants borrowed from and agreed to repay to Members 1st $54,000.00 (the "Loan"). The Loan is evidenced by a Closed -End Note, Disclosure, Loan and Security Agreement dated April 12, 2013 (the "Note") executed and delivered to Members Pt 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 April 12, 2013, on all that certain real estate and improvements erected thereon situate in East Pennsboro Township, Cumberland 2 County, Pennsylvania known and numbered as 13 Logans Run, Enola, PA 17025 (the "Property"). At all times relevant hereto, Defendants have been and continue to be the record and sole owners of the Property. A description of the Property is attached hereto as Exhibit "B" and made part hereof. 6, 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 May 14, 2013, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office at Instrument Number: 201315737. 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 bi-weekly payments of principal and interest due to Plaintiff as set forth in the Note in the amount of $297.11 each for May 23, 2014 through October 24, 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 1st gave written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. 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. 5q., by letter dated September 2, 2014, addressed to each of the Defendants at the Defendants' last known addresses and 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 1St as undeliverable or otherwise. 12. As of the date hereof, Defendants are indebted to Members 1st under the Mortgage for the following amounts: a. Outstanding principal $48,157.26 b. Interest to November 10, 2014 822.97 c. Late charges 178.32 d. Attorney fees and expenses 800.00 e. Total due to Members 1st $49,958.55 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 $4.4727 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, Raymond Nicholson a/k/a Raymond L. Nicholson and Tarnum Nicholson a/k/a Tranum Nicholson, in the amount of FORTY-NINE THOUSAND NINE HUNDRED FIFTY-EIGHT AND 55/100 ($49,958.55) DOLLARS plus interest at the rate of 5 $4.4727 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. Date: 6 Respectfully submitted, Karl M. Ledebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff M" MEMBERS Kriatlisler EOCW CtanifiYNUMBER $54 000.00 DATE OF4/l2/203 2014/10/30 12:16:57 4 /36 5000 Louleo prom, P.O, Boa 40 Mochonicsburg, PA 17056 15STEgFi4TEOEST 3.39% LOAN NUMBER 572422 CLOSED-END NOTE, DISCLOSURE, I DAN AND SFCURITYAGRFFMFMT BORROWER'S NAME AND ASONEae RAYMOND NICHOLSON ENOL13 ... RUN PA 12025 TyRNUM NICHOLSON CO•OWlROWER'a NAME N ❑a FoIE0 ❑ vARIAOLE ANNUAL PERCENTAGE RATE: The cool of your credit as o /coil/ rata.' 3.39 % • FINANCE CHARGE: The dollar amount the woad will coal you, 3 7,825.77 a Amount Financed; The amount Of comfit provided to you or on your behalf $ 54,000.00 '. Total 01 Payments' Tho amount you will have pour Oftel you have made ell poymonte as scheduled, $ 61,825.77 e Vedsbla Rata: II your lean has a vadabl• rale a Indicated above the Annual Percentage Rale may levitate during Ina tram at MIs van action It the (lode+) efiengee, The coedit Laden WII edit a margin of In the Index velue, ins rate wtr Nange monthly on the first day of the month. The rate will never bo higher Nan the maeimum rale allowed by law, and a wit never be Ins than . Any Intern) rata amnesties will nun( In mon peynllMs o1 Me lame amount. Fet Example, If your ken wee for 15,000 ei 15% ler 46 monlns cud the Annual Percentage Rote !nolo sod by 2% after one yaw, Me tremor your ben would (moue by Ala months 'Pralarred Ran: II checked, M. following apprise to your loan: ait Automate Payment Dlecounted Met Because you have 'girded to make your mWlr*d monthly payments through en iutgmelle deduction from your Check(ny$avings acaunt your ANNUAL PERCENTAGE RATE hes bean diacountnd.by .20%, The ANNUAL PERCENTAGE RATE disclosed above In the ANNUAL PERCENTAGE RATE bon b the Avlomeuo Payment Discounted Reid. Thlt rile wal Inwase by ,20% it you cease ate automatic payment arrangement or fax to ntaintalel sufficient funds In your account to cavo the aulomaua payments. In such o use, the affect of the heueed wE be to aided the term of your IoM. For esemple, If your Avtomaln Payment Discounted Role Is 10% an ■ 55,000.00 loan for e0 menthe end you cues, the automatic psyln/nt einngamonl, your role vol Increase to 10 20%. resulting in I additional payment. Variable Rat. Pre/mod Loewe, II your loan is a variable rate loon end you quality for a plinad ret., your pniarred dereounl Is taken el Me ttmi you Mk. out your ban. Thle Initial preferred ANNUAL PERCENTAGE RATE will than vary ecobrding to change In the Index tat Ancioaed above). Far ase mote, if a van able roleleon's Initial ANNUAL PERCENTAGE RATE le 12% el the tone you Uke the loan, your lMNel preferred ANNUAL PERCENTAGE RATE%al be NIA%,You/Inlual preferred ANNUAL pERCENTAOE RATE will urn vary according 10 M, Index, el disclosed H the Variable Rita' peorislan above. Flied Rate Preferred Lome, If your loan lea fixed rale rode and you qualify fora preferred rale, your ANNUAL PERCENTAGE RATE will be the prereged ANNUAL PERCENTAGE RATE disclosed oboes ler es long es your preferred status remains In effect. Numb., 01.Payments Amount of Paymanta Paymonl Friquency When Payments Ara Due fou P.m.. 207 6297,25 Pi -Weekly -Beginning 05/2412013 sem*credit vial se 1 5205,02 Final Due - On 04/30/2021 Property Insurencol You may obtain property insurance from anyone you want that to acceptable to 'rho credit ration. If yOu gat the insurance from the union you will pay $ NIA Sr/curtly! Collateral securing otter loon, win the credit union Ma good, or propany Ala also secure tills Josh. You are giving a security Interest in baMy purrhuea. m your shares and/or depose In the credit tinea, and: C1thn (oesedbe�ORTGAGE Lao Charge: II. payment is late by 10 days or more you WI be chimed a late fee *US% of your scheduled payment, R.qulred Dapoalt Balance: The Annual Percentage Rite does Filing Fine: NocFiling Insurencel riot hka Ito atauntyour required deposit balance, levy. $ WA $ NtA r n�rmamtlmye. pry Miserly, youvalnunen.to pay 'parity le bee yew moreutdawnwahtaleoydduominh,rnWnahoy( nenpaylrnt Oeleue, any mewed raoenrNmn lel 6iiore ter lenid eacote end plepeyrMa Wendt tee NNWI AMOUNT FINANCED $ 54,000.00 Amount Pohl to others on your behalf (Describe) AMOUNT GIVEN TO YOU DIRECTLY $ 54,000,00 AMOUNT PAID ON YOUR ACCOUNTS PREPAID FINANCE CHARGE $ 0,00 f To $ To S To f To $ To S To $ To S To f To f To f To NMd woman, To To To To To To To To To To F.., To Abed Sep,lena f ' MANE •'-- SECURITY INFORMATION ' M4DEL YEAR I.O. NUMBER TYPE VALUE OTHER (Doscribe): 13 LOGANS RUN, ENOLA, PA 17025 You Pledge Shares Clndyor Depoulls of IAMOUNT S ACCOUNT NUMBER AMOUNT ACCOUNT NUMSER You apse that the terms and uonddlena in the dleclosure alalemont end the coin and eatunly agreemente toiled On pipe 2 01 This a eumonl ehe0 apply 10 lhl. loan, It(hne. I. more than one burrower, we agree that sa Inted,/ ns ditto loan end eeeudry egreemenli governing this toen shell apply to both jointly end seventy, You acknowladga that you have received a copy sate loan and earl Pyr J yds end Weelosure alatemN,t, Coalpner, If you ere stoning es oo•atgner, you eeknoWmole!edpa wlpl of the meet. to CO-14101 0onleln•• j,• nn prop 2. • F;r AlIER ❑'OTHER OWNER p' -c•' IGNER DATE (SEAL). Q CO•MANER Q'OTHER ONNER Q '-CO,StONER pArE X (SEAL) O CO-tAKER X 'OTHER 0 ER 0 a:CO.SIGNER DATECq// (BEAL) Y/ Q CO. E'OTHER OWNER n "CO-SIGNER DATE X (SEAL) Q CAMAKER CI 'OTHER OWNER O "CO.BtGNER DATE X (SEAL) ...le CWNenl let ponaf ea+a Me a a400rn ...tit leer, w., ae.na.101 Mo.41 hole. aloe W,nIM.MI.le i Yen, one fit noel.... m1,,, Ye. e e aW.r le 00101.24. a rye n,.4a,, br und.,eNN, N„ a.0,1 wNn ee . Lawny a„w.l m ler aoI.lnY,u o•Ale„Nd N it 1.W.1 N,..OYN.-co iMNelh upon dew.. M .1..1114,11/04 May .,.t un.od.lo p1,n.01 hoe M (...1.., Of any.n0 ,n wma 4,..n 1M,.,n n. W0'Me,.oue, ee.oloe le .1+W M e eM **Al charWal M Wlleh Ir N. NOTICE TO CO•StGNER You am being naked to guarontoo this debt, Think carefully bo�ron you do. 11 me borrower d00sn'1 pay the debt, you will havo to. Be sure you can afford to pay if you hove fo, and that you want to accept this renp0niiblidy. You may have to pay up to the full amount of the debt d 100 borrower doe. not pay. You may also hove Is pity tate fees or collection costs. which Inueaso this amount. The creditor can collect this debt from you without first Wing to collect from the bonower. The creditor can use the same collection molhods against you that can be used oggelnst the borrower, ouch as suing you, garnshing your wages, etc. It this dobt Is even In default, that tact may become a part of your gtedit record. This notice is not the contract that mokos you liable fot the debt. Page 1 of 2 Exhibit "A" 2014/10/30 12:16:57 5 /36 aoroumsRS twill RAYMOND NICHOLSON (LOui NUMBER I r nmJWT NUMBER DATE OF LPW 04!12!2013 14 1 1E0AS 60RROWEfiseilE WORDS 'CREDO UNION' MEANS MEMOERe 1ST FEDERAL CREDIT UNION. THE WORDS YOU; 'YOUR- AND "YOVRO' MEAN THOSE LOAN AGREEMENT PaymaMinns nca Chanes: fa value received, you promlae to pay, at the Credf Unon'e off Sae all amounh due, At payments shall bo made pursuant to the disclosure Ulatomenl on pegs 1 d1 this dolxlmote. You Understand that the finance charge one fatal of payments shown on page 1 of this document ate based on the assumption Use) ell instetmont payments wR be made on the 4chddu4ed duo dittos, and, it you hov0ualifi d tel preferred rate that you continue to satisfy the carvfnlons of that proferred rate, It you tel to pay shy Installment by the time it to duo, you will pay additional interost on the overdue ambinl. Allocation of Payments and Additional Payments: Payments and Credits shell be Wiled In the fallowing order. arty omounts post due; accrued nearest or Manta Chargos; any fees or cherges owing, Including any Insuranco premium': outstanding prindpat. Payments made in addition to regularly achoduled payments shall be applied In the some order. Preferred Rata: If you qualify lora proterrod rate os disclosed on page 1of thin document or in o "operate prelarred rale addendum, you unddratend that you must moot the conditions disclosed to you m order to quality for the preferred rate and mute cangnua to meal those conditions in order to keep your pro erred rale. II you fell to meet those conditions, your role will increase, thereby extending Ma tonne of your loan. You promise to continua making payments and to moat oil obllgadbna under this Agreement even if you no longer receive the preferred rale. Leto Charges: If you make a late payment, you agree to pay a late charge it one is disdoaad on page 1 of this document, Property Insurance; If you obtain a loan secured by a motor vehicle Cl other tangible properly, you must obtain insurencowhich protests the credit limon from (nandal loss. The amount and coverage of the properly insurance must bo acceptable to the credit union. Such a policy mull provide at toast fire. then, combined edddtonal coverages end coaision Insurance. It must contain o Loss Peyablo clause endorsement naming the credit union as pen holder. You may obtain this insurance from any agent of your chino and Wad the agent to send the credit union a copy of the policy Debtor Responstbllltb: You promise to notify credit union of any change in your name adieu' of employment. You proinlee not to apply fur a loon ou know theta lea reosonohle probability that you will be unable to repay your obligation ac icing to tho terms of the credit oetension. You promise to inform credit union Of any new information Mich rolates.to yourabdity ro ropey your obligation. You promfoo no! to submit folio or inaccurate Informetlan or wdlfully Concool information regarding your creddwoMiness, credo standing, of Veen capably. Default; You shell bo Considered in dolaull if any of the fallowing occur 1) II you break any promtle mode under this Loan Agreemant or under the Socfdly Agreement; of 12) 1f you do not use the money the erode union loanedu for Iho purpose dated In ),out spplicatlon; or (3) d the credit union should, In good bath, Dellave that prospect of payment, performance or realization of the collateral, if any, Is impeded; or (4) if you dial or (b) if you file a petition in bankruptccyy, Insolvency or rocoivshrp or Mout Involsnlanly Into such brocoedlner 0s; or (S) lithe collateral, it any, given as seamy for thia account Is kcal, damaged or desitoyed, or ii it Is levied Against, attached or garnished; or (71 d you do not pay on time any of your other or future debts to the code union II you default, the credit union may, et the credit inion'e option ond.without prior notice, declare this bon Immediately due end payable, and you must Immediately pay to aha credit union of that Urns the Total unpaid balance, as well as the FInanco Charge to date, any late toadies and caste of collection permitted under low, including reasonable eltarrheye fees, that the Gadd union may Incur, up to 20%of Ole unpaid principalnd interest. Coale of ootiection Include, bel are nor halted to, reposapqnston fees apprasale, environmental ills aa osaomenuu auaity imagoinsurance coverage and attomoys lees for any action Nikon by an attorney n order to colied this loan or prosorvo or protect the credit union's rights end remedial, including, without hmeOtron, pre -ole demands tot Payment prs.aua mediation or settlement riapotlallons. Inveetigatmn end esaoesment of the credit unions' rights, participation in bankruptcy cases, matters, and procaet o s (Inducting,without Imitation, fing proofs of claim, pursuing reanimation agroemonb, ottordin9 moetingeofcreditors, end pursuincomplaints, motions, and ododlorie that rotate (n any way to the credit union's collateral or right to payment), collateral dl9ppsitIon,nonbankngnoy sults andh administrative nctrong, end appeasei the principal balance In deme!t shell bear Interco el the contract rate. Statutory Uon: If you are In default, federal law.glvee the credit union the right to apply the bologna of shares and/or dhddonds titour account(,) al the time of dofoull to 'stilly this loan. Once you are In datault, the.rr6Ot union may exercise this right without furthor notice to you. Delay In Enforcement; Credit Union mny delay enforcing any of the credit union rights Under this agreement without losing them. Irregular Payments; no cretin union may acoept tote payments or ported payments, even thou marked 'payment In (ul4 without teeing any of the .rode union rights u this egreemonl Co -makers: H you ore slgnhg this agreement as o co -maker, you agree to be equally reeponelble with the borrower, but the credit union may sue either or both of you. The credit union doss riot have to notlyy you Net this agreement hoe not been paid. The credit union may extend the tams of payment and an oda agreement,ncacuy without notifying or retooaing you tram Comnctual Pledea of Shams: You pods. all you. thins and deposit. In the credit union, Including lutunaddttiona, as secudie far This 1022. 12 211e Yee 24021. to credit enyn may apply those shin, and deposits to the payment el an seen deo at the flaw of default., Including costs of co/batten and nmombte .ulomay's rtes. that the credit nfan may Incur up Is 20% at , unpdd principal end !maria No Ilse or right to Menem s ben pon shorts and depeelb sM0 apply 1e any of your chane which may be hold in an Individual Retlremant Account" em ^Mope Pun," SECURITY AGREEMENT I, To 'scup payment of ad. lose and all sepp••ndiluros !neural') by the emelt union In connection with this leen, r m re tilos en■ eeeo(lhI wase, you great o If andh union a ..curly trusion iv, 'moony y.ecsrbed on Ego otl is aoaunwnL Thu aeavr N tnlansl lnclvdes sit NU11CMMosta. woe cations end addition/Ito Na sseurse proper! pro sal ho •ny seance on tem secured pmepeny end all ■ iming/ rsoeiwd from Me tictInid property. Cross401111arellution: Property !Pen n cants for Nle lean ar for any Cher leen Borrower has, with ah..tedlf ion i eseun all amounts Other owes the redo union clewloyllil the inure. However .petty f.eudnp nethper debt wµnInn not semyfrs this loan nests properly)$ C given spdi princtpst re■ldence (unlne aha propCsr gqKlulon flollde I re he cclose apd arty other IsdpN nqulne.ntl an Ntltlted). or en nOn pUfchau money 11028 old goads, 2. au wwiIlal nos ``hence nue losedon of fes or tend ter Ma collaterot unlet) you have ate Credit unbn'a prior anile cameo! 0. You warrant that pm have coed (Nell the colblonl, bet e1 al s.auety internale except Matgiven to the credit union end wept for any interest at a nanm• • maker Owner of Ie WRAC/fat who hes signed mthe agts.manl M the Ndreslad pick. 4. You *gm, as uses, asses omeate, `IN sons ago or attached to the 01)011y Odic -Mad Yeo furter tame to tet ar property n Name eeedeon, hoo In a tunable 'Mlle, You aurae lalBo ie amalidn sulMena end newlys reemmlarnandmontsatiiicm itutevw nloldoriondadittoeduaproperly .Senn sayers. shed pary deans S. Yea yAtt maWain Inswence is ceaaranyvtMds m other areae t9t=ethe emun union pps s a t.cunly mune. on Youunnu way Ih N a loam foal i otl tint secracbry i m best unson ou con rt' Ida cede un on with pool st.n ars cepa uicl olu su� owed i vc I red Ncur�u io ro Vat. rMN art dao I yaps a ce u�i our ea Imusd the Sisin cosy, but to snot Orelie is ole wlmUnnasDIour tecoe adddsae until aayetodr. assign food, This ear will pearhen Inlene a the cardrae. tine paid. You a an anionuIM credit Order the p(tWrlanuema Proceed.s anYlnsunnu an tunicoisn, VIe u enrldwd unynntunl lag heal ands tCIII looad� LNon. Y u ahem In• rued!,aced tp a ones ode a de a rna eco as chs Credit un ol.u� Inference, and apply Nose ass le the idms owed to Na tntld unnn You further wNorltt• IM credo iurlon ro�o�da yyour elate eovurService Center wilts IM nekncry Informs bore erwn c1 o p . You acknowledge that Insurance ar any tyloesi Memo f, plead by the code unit without benefit to you srjMduelty but Is prtnarar for the protection of the credit n union. a, Should the credit onus feel m any !dna Viotti. security daunted has Mame had fr7 ,, of lot any icemen Me net addition■( see n reduOed, you sores to am n o credit dnro mum 91%00) days wutiyn u■ndlyvuan■t scorn ow asda unity to It necessary u protect de been union ag.brsl possible lase, 7, if a admit n defined In Iles Loon "ragmen' shopb ea the creel union has the sem upon such delaret lv (ago. entlaelicda LeOoisraf In Iamb! nane,r. �n i1W rht Cele, the Boal! u on kr me email utterly audorn.a Te Aunts! we may a1 to amen unnn option, Mler lie prember•het.the co lateral n het andtaa pie ions at to .tpllca le laws. Thewdil an an Me the tmam to madam Ns �roeta dgod es sonata II unusable ar,,,d� cloy deposed a colatorsl on the pro ea Wroro the CO ler• Is kept. lithe betel anion MCW.s lD sslt de ceSsttn al ■ 7u IK sitls, va . eels or FBaal a dspes. el de utalan( fn, .rade Yuman will rel 'Yau a is ems stn CC. lir Lhlieded Moulton tie 110) say■ prier to tho/ Ie or a�speslUon. II Ne tr. imam Boas of uIMrwu tbspyeeu of the tetatml ms endd tap may collect form au omne re eepsnBoI.nwnod in the nullllllppA mU end ((ryeaplom emit( for end tonaamp ate get: or Ihs inulin! The resell union iyty f seas nelMab'e'altomeys ren and leg sapenss., rmnled appBci a tee, ed to cennecbon with drsposouon the prapenpi. Unless yyendCtluh, frau m■Y kora posesesnn ofthe pal keunl1 duufbed end We nN my al wful mann rcennu.nlwsth the cr yrtisntor cots els ain nohls poky en the o deaf t, yy undanla a that the credo union hos ordain n hH and legal nmdefp Bo ■Irl. n the ads uNon aper the umrotm Camnwfpal Code and outdraw low's ops del the credut tint on may use these !gills to soturce payrea1l1d1 I!you dolault, In 11151 svanl, you mu It the .twit union's Mimesl e • e pro properly leeltelerall and make d aro able da bade unionl epia ce al the strode unions Nothing limo credit union decau to waive this default, n vele not constitute warm of any other suboaquentt debuts.ut a ' Kai w�thldehdi onion wed union onMilo ems nods s your a }Apia* +es eoll•�drsi end ice sacunly laterest vends Oaf agrsement mous g, u Nen li mon den end senowrr yyour abaoetbna adv lois sanem.nt sir loin and uvanLaach rap sauatryntpanucru tl alio eras el Nu agrsenent 10, This leudy�peemenl net only binds you, tut year exeutorn, admntnnton, hebs..nd Bougns. Paps 2 012 61007Na LEGAL DESCRIPTION Parcel #09-14-0836-263 ALL THAT CERTAIN tract of land situate In East Pennsboro Township, Cumberland County, Pennsylvania known as Lot No. 93 of Logan's Run, Phase III as described in that certain Final Subdivision Plan, Phase III Logan's Run as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 74, Page 92, as follows to wit: BEGINNING at a point on the southern dedicated right-of-way line of Logans Run at the dividing line of Lot #94 and Lot #93; thence by line of Lot #94 South forty-three degrees fifty-seven minutes six seconds West (S 43 degrees 57' 06" W), one hundred and zero hundredths (100.00) feet to a point on line of Lot #56, Logans Run, Phase II, thence by line of Lot #56 and #55, Logans Run, Phase II North forty-six degrees two minutes fifty-four seconds West (N 46 degrees 02' 54" W) eighty and zero hundredths (80.00) feet to a point on the dividing line of Lot #92 and Lot #93; thence by line of Lot #92 North forty-three degrees fifty-seven minutes six seconds East (N 43 degrees 57' 06" E) one hundred and zero hundredths (100.00) feet to a point on the southern right-of-way line of Logans Run; thence by the southern right-of-way line of Logans Run South forty-six degrees two minutes fifty-four seconds East (S 46 degrees 02' 54" E), eighty and zero hundredths (80.00) feet to a point at the dividing line of Lot #94 and Lot #93, the place of BEGINNING Subject to any restrictions, easements and/or adverses that pertain to this property. Under and subject to restrictions as set forth in Misc. Book 451, Page 687; Misc. Book 475, Page 657 and Misc. Book 651, Page 825. Known and numbered as 13 Logans Run, Enola, PA 17025. Being the same premises which Charter Homes Building Company, a Pennsylvania Corporation, real owner, and Village Home Builders, Inc., a Pennsylvania Corporation, equitable owner, by their deed dated April 20, 2001 and recorded in the Cumberland County Recorder of Deeds Office at Deed Book 243, Page 460 granted and conveyed onto Raymond L. Nicholson and Tarnum Nicholson, husband and wife. Being Tax Parcel No.: 09-14-0836-263 Exhibit "B" Prepared By: Members 1st FCU 5000 Louise Drive Mechanicsburg, PA 17055 Return To: Members 1st FCU Real Estate Department 5000 Louise Drive Mechanicsburg, PA 17055 (717)-795-6026 09- )9'- G- X3 MORTGAGE Made 04/12/2013 Between RAYMOND L. NICHOLSON AND TRANUM NICHOLSON (hereinafter called "Mortgagor") And MEMBERS 1ST FEDERAL CREDIT UNION (hereinafter called "Mortgagee") 1111111)101 Whereas, Mortgagor has executed and 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 $ 54,000.00 , lawful money of the United States of America, and has provided therein for payment of any additional moneys 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 or principal sum and as security for the payment of the same and interest as aforesaid, together with all other sums payable hereunder or under the terms of the Note, does grant and convey unto Mortgagee, All that certain property of the Mortgagor located in EAST PENNSBORO TOWNSHIP , Cumberland County, Pennsylvania PLEASE SEE LEGAL DESCRIPTION which currently has the address of 13 LOGANS RUN [Street] Enola , Pennsylvania 17025 Acct No [City] [Zip Code] ApptD Exhibit "C" Page 1 of 4 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 perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be Added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and 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 past 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 secured 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 time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges 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 AppID 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. (5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this Mortgage. (6) In case default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in 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 (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. 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 assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each shall be joint and several. Acct No AppID Page 3 of 4 Witness the due execution hereof the day and year st above tiltAirdotio AL OND L. NICHOLSON TRANUM NICHOLSON Commonwealth f Pennsylvania ) County of /7%624.20/ e ss: On this, the c23"1 day of (264.4:1, 2013 , before me, JeZ yC:Ti .-44...,(}� , the t dersigned officer, personally appeared RAYMOND L. NICHOLSON AND TRANUM NICHOLSON satisfactorily proven to me to be the person(s) whose name(s) is/are subscribed to the within Mortgage, and acknowledged that he/she executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and off My commission expires: COMMONWEALTH OF PEN SYLVAN Notarial Sea. Jody L Travis, Notary Public Lower Allen Twp., Cumberland County M Commission Ekplres Sept. 29, 2016 PaNNsvi.vANta A oto[7imm0N of NOTAR CC Members 1ST Federal Credit Union, Mortgagee with is 5000 Louise Drive, Mechanicsburg, PA 17055. By Acct No ApprE Page 4 of 4 Order ID: 810212 LEGAL DESCRIPTION. Parcel #09-14-0836-263 ALL THAT CERTAIN tract of land situate In East Pennsboro Township, Cumberland County, Pennsylvania known as Lot No. 93 of Logan's Run, Phase III as described in that certain Final Subdivision Plan, Phase Ill Logan's Run as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 74, Page 92, as follows to wit: BEGINNING ata point on the southern dedicated right-of-way line of Logans Run at the dividing line of Lot #94 and Lot #93; thence by line of Lot #94 South forty-three degrees fifty-seven minutes six seconds West (S 43 degrees 57' 06" W), one hundred and zero hundredths (100,00) feet to a point on line of Lot #56, Logans Run, Phase II, thence by line of Lot #56 and #55, Logans Run, Phase II North forty-six degrees two minutes fifty-four seconds West (N 46 degrees 02' 54" W) eighty and zero hundredths (80.00) feet to a point on the dividing line of Lot #92 and Lot #93; thence by line of Lot #92 North forty-three degrees fifty-seven minutes six seconds East (N 43 degrees 57' 06" E) one hundred and zero hundredths (100.00) feet to a point on the southern right-of-way line of Logans Run; thence by the southern right-of-way line of Logans Run South forty-six degrees two minutes fifty-four seconds East (S 46 degrees 02' 54" E), eighty and zero hundredths (80.00) feet to a point at the dividing line of Lot #94 and Lot #93, the place of BEGINNING Subject to any restrictions, easements and/or adverses that pertain to this property. ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201315737 Recorded On 5/14/2013 At 10:18:58 AM * Instrument Type - MORTGAGE Invoice Number -136816 User ID - BMM * Mortgagor - NICHOLSON, RAYMOND L * Mortgagee - MEMBERS 1ST FEDERAL CR UN * Customer - MEMBERS 1ST * FEES STATE WRIT TAX STATE JCS/ACCESS TO JUSTICE RECORDING FEES - RECORDER OF DEEDS PARCEL CERTIFICATION FEES AFFORDABLE HOUSING COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $23.50 $13.50 $10.00 $11.50 $2.00 $3.00 $64.00 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA ..16.-€4.-1,7-74 547-4, RECORDER OP DKEDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. iaw 2014/10/30 12:16:57 15 /36 (Rev. 9/2008) Date: September 2, 2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default,and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-18691. 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI(N OBTENGA UNA TRADUCCI(N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRJSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page 1 of 5 Exhibit "D" 2014/10/30 12:16:57 16 /36 HOMEOWNER'S NAME(S): RAYMOND L NICHOLSON TRANUM NICHOLSON PROPERTY ADDRESS: 13 LOGANS RUN LOAN ACCT. NO.: ENOLA, PA 17025 ORIGINAL LENDER: Members rt Federal Credit Union CURRENT LENDER/SERVICER: Members 1st Federal Credit Union HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YO11 MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAI(E FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES — If you meet with one of the consumer credit counseling 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 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. 1F 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 TEIESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPT.IC,ATIfN IS FVFNTITAT .I.V APPROVFT) AT ANY TTMF. RRFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Page 2 of 5 2014/10/30 12:16:57 17 /36 AGENCY ACTION — Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date/. NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 13 LOGANS RUN ENOLA, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 5/23/2014 of $297.11, 6/06/2014 of $297.11, 6/20/2014 of $297.11, 7/04/2014 of $297.11, 7/I8/2014 of $29TL i l , 8/01/2014 of 12,97.11,1/15/2014 of $29711, 8/29/2014 of $297.11, Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $2,376.88 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 $ 2,376.88 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD, Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Members 1" Federal Credit Union,.ATTN: Laura H 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 2014/10/30 12:16:57 18 /36 IF YOU DO NOT CURE THE DEFAULT --If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within. THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upQ 1 your mortgaged property. IF TIlE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY period. you will not be required to pay attorney's fees. OTHER LENDER REMEDIES — The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's 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. t{ ,t - 1 . t EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately Six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. 11OW TO CONTACT THE LENDER: Name of Lender: Address: Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg PA 17055 'III ►_ItI•. - _. I ;II Fax Number: (717) 795-5207 Contact Person: Laura II E -Mail Address: hokelnmemberslst.org EFFECT QF SHERIFF'S SALF, -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF 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 2014/10/30 12:16:57 19 /36 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT, (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Mil in a list of all Counseling Agencies listed in Appendix C. FOR THE COUNTY in which the property is located, using additional pages if necessary). Certified Mail # 9171999991703213560155 Page 5 of 5 2014/10/30 12:16:57 10 /36 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C. FOR THE COUNTY in which the vroveriy is located. using additional pages if necessary). Certified Mail # 9171999991703213560148 Page 5 of 2014/10/30 12:16:57 29 /36 YOU MAY ALSO HAVE THE MIGHT: • 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 COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C. FOR THE COUNTY in which the property is located. using additional pages V necessary). Certified Mail # 9171999991703213560162 Page 5 of 5 2014/10/30 12:16:57 20 /36 Servicemembers Civil Relief Act Notice Disclosure U.S. Department of Housing and Urban Development Office of Housing OMB Approval 2502- 0584 Exp 11/30/2014 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 % during the 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 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. • 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 2014/10/30 12:16:57 21 /36 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://legalassistance.law.af.mii/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.militaryonesource.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. 2014/10/30 12:16:57 22 /36 Uu Comprehensive Housing Counseling Agencies Agencias de Consejo al Clients para Vivienda Cumberland County "CCCS of Western PA 114 N Hanover St Carlisle PA 17013 888.611.2227 www.advantageccs.org *CCCS of Western PA 55 Clover Hill Road Dallastown PA 17313 888.511.2227 / 888.511.2227 www.advantageccs.org Community Action Commission - Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 www.cactrlcounty.org Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing & Redevelopment Authority - Cumberland Cnty 114 N Hanover Si; STE 104 Carlisle PA 17013 866.683.5907 / 717.249.0789 www.cchra,00m Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www.rurallsc.org/pathstone pa.ijn Pennsylvania interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www.adamscha.org NOTE; Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated: 11/11/2013 9:46:17 AM Page 1 of 1 11/03/2014 14:53 7179320317 KARLLEDEBOHM PAGE 08/08 MEMBERS IST FEDERAL CREDIT UNION PLAINTIFF Vs. • RAYMOND NICHOLSON, a/k/a RAYMOND L. NICHOLSON and TARNUM NICHOLSON a/k/a TRANUM NICHOLSON : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA DEFENDANT(S) : CIVIL ACTION -LAW : MORTGAGE FORECLOSURE VERIFICATION I, Jennifer Perry, Collateral Liquidation Specialist for Members 1 Federal Credit Union, being authorized to do so on behalf of Members Pt :Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best or information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: November, 3 , 2014 Members 1St Federal Credit Union B ateral Liquidation Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FtLED—OFFICE OF THE P RO T HDND TARsi 201411'!OV 2 kH 11= 21 �tixc, of Chita/en OFFICE THE SHERIFFCUMBERLAND COUNTY PENNSYLVANIA Members 1st Federal Credit Union vs. Raymond Nicholson (et al.) Case Number 2014-6510 SHERIFF'S RETURN OF SERVICE 11/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Raymond Nicholson, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 11/14/2014 09:02 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Tarnum Nicholson at 13 Logans Run, East Pennsboro, Enola, PA 17025. CHRISTO' ER SHARPE, DEPUTY 11/17/2014 11:25 AM - The requested Complaint in Mortgage Foreclosure served by the Sheriff of Dauphin County . upon Raymond Nicholson, personally, at 38 1/2 Summit Street, Harrisburg, PA 17101. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 11/19/2014 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 Complaint in Mortgage Foreclosure as "Not Found" at 13 Logans Run, East Pennsboro, Enola, PA 17025. NOTE: Tarnum Nicholson is the only adult living at this address. SHERIFF COST: $85.44 SO ANSWERS, November 19, 2014 RON R ANDERSON, SHERIFF tc) CountySuito Sheriff, Toleosoft. Inc. Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy MEMBERS 1ST FEDERAL CREDIT UNION VS RAYMOND NICHOLSON Sheriffs Return No. 2014-T-2984 OTHER COUNTY NO. 2014-6510 And now: NOVEMBER 17, 2014 at 11:25:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon RAYMOND NICHOLSON by personally handing to RAYMOND NICHOLSON 1 true attested copy of the original COMPLAINT IN.MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 38 1/2 SUMMIT STREET HARRISBURG PA 17101 Sworn and subscribed to before me this 18TH day of November, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, �'�°✓%mac___ Sheriff of Dauphin County, Pa. By.,..'■..•• Deputy Sheriff Deputy: BROCK FASNACHT Sheriffs Costs: $41.25 11/14/2014 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : NO.: 14-6510 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA RAYMOND NICHOLSON a/k/a RAYMOND L. NICHOLSON and TARNUM NICHOLSON a/k/a TRANUM NICHOLSON DEFENDANTS : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY: Please enter judgment in the above captioned proceeding in favor of Members 1' Federal Credit Union, Plaintiff, and against the Defendants, Raymond Nicholson a/k/a Raymond L. Nicholson and Tarnum Nicholson a/k/a Tranum Nicholson, in the amount of FIFTY THOUSAND ONE HUNDRED FIFTY AND 88/100 ($50,150.88) DOLLARS, plus interest at the rate of $4.4727 per day from December 23, 2014 through the date of judgment and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other charges collectable under the mortgage and for foreclosure and sale of the 6,tff-g90 -6- ce woe; mortgaged property. Judgment is entered pursuant to Pa. R.C.P. 1037 for failure to file an Answer on behalf of Raymond Nicholson a/k/a Raymond L. Nicholson and Tarnum Nicholson a/k/a Tranum Nicholson to Plaintiffs Complaint within twenty (20) days of service thereof and after a 10 -day Notice was sent. Date: December 23, 2014 Respect Iii ljfr4p • itted, - 1 arl M. Le+ebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff I hereby certify that notices of intent to take a default judgment were forwarded to Raymond Nicholson a/k/a Raymond L. Nicholson and Tamum Nicholson a/k/a Tranum Nicholson by United States Mail, First Class, postage prepaid on December 9, 2014. The aforesaid notices were each contained within an envelope bearing the return address of the undersigned. The notices have not been returned to the undersigned as undeliverable or otherwise. A copy of the notice and Postal Forms 3817 are a marked Exhibit "A". hed hereto and edebohm, Esquire Karl M. Ledebohm, Esquires P.O. Box 173 • - Nevi Cumberland, PA 17070-0173 (717)938-6929 ; ,, ,, MEMBERS 1 ST FEDERAL?., CREDIT UNION PLAINTIFF Vs. 3. i•• • IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : • PENNSYLVANIA 4-6510 RAYMOND_ NICHOLS,ON;ra/k/a. RAYMOND�L. NICHOLSONiand,.: TARNUM NICHOLSQN a%k/a , • TRANUM NNICHOLSON : CIVIL ACTION — LAW DEFENDANTS : MORTGAGE FORECLOSURE • }. IMPORTANT NOTICE Date: December 9, 2014. TO: Raymond Nicholson a/k/a Raymond L. Nicholson 38 1/2 Summit Street Harrisburg, PA 17101 Tarnum Nicholson a/k/a Tranum Nicholson 13 Logans Run Enola, PA • 17025 PURSUANT TO THE FAIR DEBT COLLECTION. PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS.LETTER'AND ANY , SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION, OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A Exhibit A Lipat, WV' tu S IATES Certificate Of POSTAL SERVICE, Mai' This Certificate of Mailing provides evidence that rear nas been presented lo USPSTioi This form may be used for domestic and international rsr From: • 11," sr Karl M. Ledebohm, Esq. r',,,,', ,l Va •-• ,a4rC... •ii MCIC P.Q. Box 173 ., ..-..,_: 4.-....u..m= -F-." \ 1 4 ' •---• .T•FLEN—r=2 *--iiii New Cumberland, PA 17070-0173:-%„ a LU Z To: -- Raymond Nicholson a/k/a Raymond L. Nicholson 381/2 Summit Street Harrisburg, PA 17101 r1;11‘\ PS Form 3817, April 2007 PSN 7530-02-000-9065 LiNiTLu STATES ate c.,,,, POSTAL SERVICE. • , i,::," MaU :tie. Ceoiticale ol liiitaiiiiiii, pi,iaoicies ei,idei i.e ii,.si •ii,i ii.iii, ueei oiee,e4ii ir. ' ' t Ci C.1 i oil:. lormi may be used fol domestic, ard em, tt f („4, l' t"' ' C — CDT 1•'T ‘ k- :-.moo From , ,_ , CDCOCCFs. •Z \ ,;:• , , 1,F• i ¢mr•-=ci, .,..,,,,, i CL.--•LUc>7)7 •rs.--- I"- '. :-../N, / Q.., / •CLX— z Irlc,,, Karl M. Ledebohm, Esq. ,,, -• • L.) ul 1= tF,C7 CD UJ Z To P.O. Box 173 New Cumberland, PA 17070-0173 _ Tarnum Nicholson a/k/a Tranum Nicholson 13 Logans Run Enola, PA 17025 PS Form s. 7. April 2007 PSN 753() 02.ri0ci-9065 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : NO.: 14-6510 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA RAYMOND NICHOLSON a/k/a RAYMOND L. NICHOLSON and TARNUM NICHOLSON a/k/a TRANUM NICHOLSON DEFENDANTS : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE The undersigned hereby swears and affirms on behalf of Members 1' Federal Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff's knowledge, Raymond Nicholson a/k/a Raymond L. Nicholson and Tranum Nicholson a/k/a Tranum Nicholson are not currently on active military service. Date: December 23, 2014 Res ec . ly submitted, // ./ji , 0 ar M. 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 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : NO.: 14-6510 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA RAYMOND NICHOLSON a/k/a RAYMOND L. NICHOLSON and TARNUM NICHOLSON a/k/a TRANUM NICHOLSON DEFENDANTS : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE NOTICE OF JUDGMENT PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS NOTICE AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE TO: Raymond Nicholson a/k/a Raymond L. Nicholson 38 1/2 Summit Street Harrisburg, PA 17101 Tarnum Nicholson a/k/a Tranum Nicholson 13 Logans Run Enola, PA 17025 You are hereby notified that on 1 , 2014 the following judgment has been entered against you in the above captioned case: Dated: Judgment in favor of Members 1St Federal Credit Union, Plaintiff, and against the Defendants, Raymond Nicholson a/k/a Raymond L. Nicholson and Tarnum Nicholson a/k/a Tranum Nicholson, in the amount of FIFTY THOUSAND ONE HUNDRED FIFTY AND 88/100 ($50,150.88) DOLLARS, plus interest at the rate of $4.4727 per day from December 23, 2014 through the date of judgment and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other charges collectable under the mortgage and for foreclosure and sale of the mortgaged property. Judgment is entered pursuant to Pa. R.C.P. 1037 for failure to file an Answer on behalf of Raymond Nicholson a/k/a Raymond L. Nicholson and Tarnum Nicholson a/k/a Tranum Nicholson to Plaintiff's Complaint within twenty (20) days of service thereof and after a 10 -day Notice was sent. I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 is: Raymond Nicholson a/k/a Raymond L. Nicholson 38 1/2 Summit Street Harrisburg, PA 17101 Tarnum Nicholson a/k/a Tranum Nicholson 13 Logans Run Enola, PA 17025 A: Raymond Nicholson a/k/a Raymond L. Nicholson and Tarnum Nicholson a/k/a Tranum Nicholson Por este medio se le esta notificando que el de 2014, el/la siguiente (Orden), (Decreto), (Fa11o), ha sido anotado en contra suya en el caso mencionado en el epigrafe. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado de residencia: Raymond Nicholson a/k/a Raymond L. Nicholson 38 %2 Summit Street Harrisburg, PA 17101 Tarnum Nicholson a/k/a Tranum Nicholson 13 Logans Run Enola, PA 17025 Dated: December 23, 2014 Resp; ct P01 ly .. miffed, I arl M Lei ebohm, Esquire upreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff