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HomeMy WebLinkAbout02-2683THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Thomas J. Coleman, III, Esquire Attorney ID# 58607 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP MORGAN CHASE BANK, as Trustee for Equity One, ABS, Inc., Mortgage Pass Through Certificates, Series 2001-1 400 Lippincott Drive Marlton, NJ 08053 Plaintiff VS. ARTHUR HIEBER 1712 Chatham Road Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY TRIAL DIVISION No.: 02 -aLR l lt??l? L_" l CIVIL ACTION MORTGAGE FORECLOSURE Defendant(s) NOTICE 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 claim 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 rtxxxxrtrtrtrtxxxxrtrtrtrtxxxrtrtwrtrtxwxxrtrtrtrtrtxxxrtrtrtrtrtrtxxrtrtrtrtrtrtrtxxxrtrtrtrtrtrtrtrtxxrtrtrtrtrtrtrtrtxxxxxrtrtrtrtrtrtrtrtrtrtxxxxrtrtrtrtxrt NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT xxrtrtrtrtrtxxxxrtrtrtrtxxxxxrtrtrtrtrtxxxxrtrtrtrtrtxxxxrtrtrtrtrtrtxxxxrtrtxrtrtrtrtxxxxrtrtrtrtrtrtrtrtxxxxrtrtrtrtrtrtrtrtrtxxrtrtrtxrtrtrtrtrtrtrtrtxxxx This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2.Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgement will be mailed to you by our offices. THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Thomas J. Coleman, III, Esquire Attorney ID# 58607 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP MORGAN CHASE BANK, as Trustee for Equity One, ABS, Inc. Mortgage Pass-Through Certificates, Series 2000-1 400 Lippincott Drive Marlton, NJ 08053 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY TRIAL DIVISION VS. ARTHUR HIEBER 1712 Chatham Road Camp Hill, PA 17011 Defendant(s) No.: 02 - o2I. Z3 l." u.tcc- CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, JP Morgan Chase Bank, as Trustee for Equity One, ABS, Inc. Mortgage Pass- Through, Certificates Series 2000-1, is a mortgage company, having an office and place of business at 400 Lippincott Drive, Marlton, New Jersey 08053. 2. Defendant, Arthur Hieber is the real owner of the premises hereinafter described. 3. The residence of the Defendant is 1712 Chatham Road, Camp Hill, PA 17011. 4. On August 21, 2001, Defendant, Arthur Hieber, executed and delivered to Equity One, Inc. a note (the "Note") and mortgage (the "Mortgage"), a true and correct copy of the Note and Mortgage are attached as Exhibit "A". The Mortgage was recorded on August 28, 2001 in the Department of Records in and for the County of Cumberland under Mortgage Book 1731 Page 3933. 5. The said Note and Mortgage were in the principal amount of $112,500.00, with an interest rate of 10.75% thereon, payable as to the principal and interest with monthly installments of $1,050.17 commencing October 1, 2001. Said Note and Mortgage are incorporated herein by reference. 6. The Mortgage covers the following real estate (the "Mortgaged Premises"): 1712 Chatham Road, Camp Hill, PA 17011. 7. The mortgage is in default because payments of principal and interest due October 1, 2001, and monthly thereafter are due and have not been paid, whereby the whole balance of principal and all interest due thereon have become due and payable forthwith together with late charges, escrow deficit (if any) and costs of collection including title search fees and reasonable attorney's fees. 8. The following amounts are due on the Mortgage and Note: Balance of Principal $112,500.00 Accrued but Unpaid Interest from 09/01/01 through 5/20/02 @ 10.75% per annum ($33.13 per diem) $ 8,646.93 Title Search Fees $ 150.00 Reasonable Attorney's Fees $ 5,625.00 Late Charges on Overdue Amount from 10/01/01 through 05/20/02 @ $52.51 Per Month $ 420.08 TOTAL as of 5/20/2002 $127,342.01 Plus, the following amounts accrued after 5/20/2002: Interest at the Rate of 10.75% per annum ($33.13 per diem); Late Charges of $52.51 per month 9. Plaintiff has complied fully with Act No. 91 (35 P.S.§1680.401(c) of the 1983 Session of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the Defendants at 1712 Chatham Road, Camp Hill, PA 17011, on December 14, 2001, the notice pursuant to § 403-C of Act 91, and the applicable time periods therein have expired. True and correct copies of such notices are attached hereto as Exhibit "B" and made apart hereof. WHEREFORE, Plaintiff demands judgment against the Defendants for foreclosure and sale of the mortgaged premises in the amount due as set forth in paragraph 8, namely, $127,342.01, plus the following amounts accruing after 5/20/2002, to the date of judgment: (a) interest of $33.13 per day; (b) late charges of $52.51 per month; plus interest at the legal rate allowed on judgments after the date of judgment, additional attorney's fees (if any) hereafter incurred, and costs of suit. LAW OFFICE OF MICHAEL J. MILSTEAD, L.L.C. Thomas J oleman, III, Esquire Attorney for Plaintiff ?uvc"?f'LI IQ;CQ f L/ L VERMCATiON The undersigned, Timothy A. Tracy hereby certifies he/she is the Default Specialist of the Plaintiff in the within action, Complaint and that he/she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that Use statements herein are made subject to the penalties of 18 PA.C.S. 4904 relating to unswom falsification to authorities. /N e ?, C Trp-r TPtmCOPY Prepared By: Rr turn To: Michelle Pierce Eiuity One. Inc.. dba Pipular Financial Services 410 Lippincott Drive. M.trltor.. NJ 08053 Parcel Number: -[Space Above lhij Line For S1".ard)ng Datal MORTGAGE DEFINITIONS Words used in multiple sections of this document are 9eEned below and other words are defined in Sections 3, 11, 13, 18, 20 and 21. Certain rules regardicg, he usege of words used in this document arc also provided in Section 15. (A) "Security Instrument" means this document, which is dated August 21, 2001 together with all Riders to this document. (B) "Borrower" is ARTHUR HIEBER a Borrower is the mortgagor undo this Security Instrument. (c) "Under" is Equity One. Inc.. dba Pop I E r Financial Services Lender is a 0 L7422 r PENNSYLVANIA - Single rani fly ? Fanr le Mal /Freddie 13: c UNIF 1RM INS 1 RUMENT Form 3039 1101 (M -6(PA) Nodal PWe 1 0114 MWBa40 WP 1 •Jblc: [Yf I IIII II IIII III II?L? IIII I IIII P MDPTG/6E FORMS - IBU 1162 1-0291 organized and existing under the laws of Pennsylvania Lender'saddressis 40C Lippincott Drive, Marlton, NJ 08053 Lender is the nwrtgagee under this Security Instrument. (D) "Note" means the promissory note signed by Borrow,r End dated August 21. 2001 nc Note states that Borrower owes Lender OnEi [tundra Twe I ve Thousand Five Hundred and no/100 Dollars (U.S. $112,500. 00 ) plus interest. B)rrowe- has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later utar' $E ptember 1. 2016 (E) "Property" means the property that is described belaw under the heading "Transfer of Rights in the Property." (F) "Loan" means the debt evidenced by the Nt,t, plus mNrest, any prepayment charges and late charges due under the Note, and •ill sums due under Liis 5.-curiiy lattmment, plus interest. - (G) "Riders" means all Riders to this Security Irs:runuat fiat are executed by Borrower. The following Riders are to be executed by Borrower [check ow. as app:icable]: Q Adjustable Rate Rider Cendaminiurc R.der ? Sccond Home Rider ® Balloon Rider Planned Unit Dcvelolimmt Rider ? 1-4 Family Rider VA Rider Q Biweekly Payrne it Rider ? Other(s) [specify] (M "Applicable Law" means all cbnunlicg applicale federal, state and local statutes, regulations, ordinances and administrative rules and orders rl,at hav i the effect of law) w well as all applicable final, non-appealable judicial opinions. (n "Community Association Dues, Fees, and Assessr,enis" means all dues, fees, assessments and other charges that are imposed on Borrower- or flee Property by a condominium association„ homeowners association or similar organization. (.1) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through. an electronic terminal, telephonic instrument, computer, or magnetic tape so as to order, Nstmet, or authorize a ftuancial institution to debit or credit an account. Such tern includes, but is not limited to, point-of-sale transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers. (I) "Escrow Items" means those items that are described in Section 3. (L) "Miscellaneous Proceeds" means any compensation„ settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condenmation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or 'iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (" "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the Load. (N) "Periodic Payment" means the regularly scheduled unount due for (i) principal and interest under the Note, plus (it) any amounts under Section 3 of this Security Instrument. _ 00274227 m nw: ®61PAl mooed reaea of 6 Form 3039 1/01, (O) "RESPA" means the Real Estate Settlement 7rocedu:es Art (12 U.S.C. Section 2601 at seq.) and its implenunting regulation, Regulatim X (24 C.F.R. Part 3590), as they might be amended from time to time, or any additional or successor legislation or regulati to that govens Pte same subject matter. As used in this Security Instrument, "RESPA" refers to all icoulrc nests and restrictions that are imposed in regard to a "federally related mortgage Ican" even if the.'_oan coca not qualify as a "federally related mortgage loan" under RESPA. (P) "Successor in Interest of Borrower" means any parr that has taken title to the Property, whether or not that party has assumed Borrower's obligsGoris under tl a Note and/or this Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrument secures le Lender: ii) tb repaya en, of the Loan, and all renewals, extensions and modifications of the Note; and (h) the performance of 2.anrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borriwsr does hereby mortgage, grant and convey to Lender the following d%cribed property located in -.he COUNTY rryK of Recording Jurisdiction] of CUMBERLAND [Name of Recording Jurisdiction]: DESCRIBED ON THE TAX MAP AS THE TO'WNSHIi f]F LOWER ALLEN ATTACHED LEGAL DESCRIPTION which currently has the address of 1712 CHATHAM ROAD Isaeet] CAMP HILL icay], Pennsylvania 17011 [zip Cade) ("Property Address"): TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereatcr a part of the property. All replacements and additions shall also be covered by this Security Instrur.tent. All of the foregoing is referred to in this Security Instrument as the "Property." - (M-61PA) Iowa, - 06)742,7 K1. 3.1 "m.u:/W Form 3039 1/01 ; EX41BIl A ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWVSHIP OF LOWER ALLEN IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVAIIIA, BEING MORE FULLY DESCRIBED IN A FEE SIMPLE DEED DATED 02/25/2000 AND RECORDED 03/:)1/2000, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN VOLUME 240 PAGE 163. TAX PARCEL ID: 13-23-0547-038 ADDRESS: 1712 CHATHAM ROAD CAMP HILL, PA 17011 44 j,. 4 4 BORROWER COVENANTS that Borrower is lawn illy seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property 1..d that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will do end generally the title to the Property against all claims and demands, sub'ect to any encumbrances if recc.d. - THIS SECURITY INSTRUMENT combines unitrm covenants for national use and non-uniform covenants with limited variations by jurisdiction fo constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lander covenant and agree as follows: 1. Payment of Principal, Interest, Escrow Items., Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and intuee; on, the debt evidenced by the Note and any prepayment charges aid late charges due under tl_e Note. Borrower shall also pay funds for Escrow items pursuant to Section 3. Payments due under the tote i, i ai, Security Instrument shall be made in U.S. currency. However, if ai;y check or other instrwn:-r,: rec,:ived by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Leader may require that my or all subsequent payments due under the Note and this Security . Instruntert be n z'c. in are or more of the following forms, at selected by lender. (a), cash; (o) money order (c) carnfied check, bank check, treasurer's check or cashier's check, provided any sech check is divas upce an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Eiectron;c Funds Tr.nsfer. Payments we deemed received by Lender. w'ten re ei, ad at the location designated in the Note or at such other location as may be designated by Untie!: in a,:.:o.dance with the notice provisions in Section 15. Lender may remm any payment or partial payment if tl:e )aymen; or partial payments are insufficient to bring the lean current. Lender may accept any prymerr o_ partial payment insufficient to bring the Loan current, without waiver ?f any rights hereunder or prejoaic° to its rights to refuse such payment or partial payments in the future, out Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of it s^heduled due date, than Lender need not pay interest on unapplied funds. Lender may hold such unap;lic.7 funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower . might have now or in the future against Lender shall cnlirve Borrower from making payments due under the Note and this Security Instrument or perl'onning the X,enants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to mduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payrimt may be applied to the delinquent payment and the late charge.. If more than one Periodic Payment is outstanding, Lender tray apply any payment received from Borrower to the repayment of the Periodic Paymens if, and to the extent that, each payment can be 00274227 e ma.: -6(PAl iaooe) ew•<drs Form 3039 1/05 paid in foil. To the extent that any excess exists alter th, pryment is applied to the full payment of one or more Periodic Payments, such excess may be applied to my late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, ur Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or ch:mge the amount, of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pap to Lender on the day Periodic Payments arc due under the Note, until the Note is paid in full, a sum (thc "Funds") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Len(I?:r under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the. provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term ( I the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be :screwed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower sf.al! pnnmtly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Louder ne Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for soy or a•1 Escrow Items Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrov gems at cay time. Any such waiver may only be in writing. In the event of such waiver, Borrows: shall riy directly, when and where payable, the amounts due for any Escrow Items for which payment cf Funds Ins been waived by Lender and, if lender requires, shall furnish to Lender receipts evidencing suci: payment v itltin such time period as Lender may require. Borrower's obligation to make such payments and to provde receipts shall for all purposes be deemed to be a covenant and agreement contained in this S?chrity hnstrument, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay ?scrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount ar.d Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or a I Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this Section'. Lender rosy, at any time, collect and hold Ponds it ar, amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditores of future Escrow '(eras or otherwise in accordance with Applicable Law. The Funds shall be held in an institution wl: )se deposits are insured by. a federal agency, instrumentality, or entity (including Lender, if Lender i; at institution whose deposits are so insured) or in any Federal Home Loan Bank. Lender shall appl die F in ; to pay the Escrow Items no later than the time specified under RESPA Leader shall not charge Borrove? for holding and applying the Funds, annually analyzing the escrow account, or verifying the E:..crow gems, unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to in.ke sucl. a elmrge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Fends, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and L antler can agree in writing, however, that interest 00274227 (Mb ® 61PA) Io0091 wye s ai . 6 Form 3039 1/01 shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess finds in accordance with RESPf . If there is a shortage of Foods held in escrow, as defined under RESPA, Lender shall notify Berrower a.; required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shorts gc in accordance wish RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held n escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower s'.all pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no n:. ire than 12 monthly payments. Upon payment in full of all sums secured by this S. cu, ity ID;hnment, Lender shall promptly refund to Borrower any Fonds held by Lender. 4. Charges; Liens. Borrower shall nay al'. tase:, assessments, charges, fines, and impositions attributable to the Propeny which can attain pri,:rhiy ove this Se-mty Instrument, leasehold payments or ground. rents on the Property, if any, and Comnn:mty As:acration Dues, Fees, and Assessments, if any. To the extent that these items are Fzcmw Items, Bocnwer shall nay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which ha, priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of he ob getion secured by the lien in a manner acceptable to Lender, but only so long as Borrower is performing s ;cb agremitait; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those p: eceednlg:: are pending, but only until such proceedings are concluded; or (c) secures from the holder of the lien it agreement satisfactory to Lender subordinating the lien to this Security Instrnmert. If Lender deR ranter. L' :.at any part of the Property is subject to a lien which can attain priority over this Securhy Instmrent, 1 a:nner may give Borrower a notice identifying the lien. Within 10 days of the time on which afar noti:e is gi+cn, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Suction t. Lender may require Burrower to pay a one.-time charge for a real estate tax verification and/or reporting service used by Lender in connection with this V.orn. 5. Property Insurance. BorrowerAiall keep the brpr vements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but not limiter to, earthquakes mil floods, for which Lender requires insurance. This insurance shall be maintained in the amouas (incl iding deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the Lean. The insurance carrier providing the insurance sh,.ll be chosen by Borrower subject to Lender's right to disapprove Borower's choice, which right sLsll not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loa h, either: (a) a one-time charge for flood zone determination, certification and tracking services; or (b; a one-time charge for flood zone determination' and certification services and. subsequent charges each r:mu remappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be. responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection, with the review of any flood zone determination resulting from an abjection by Borrower. „ 00274227 t' _ INllrl": -BIPwI toooel cop" s-N q Form 3039 1101 . If Borrower fails tc. maintain any of the ieaernge described above, Lender may obtain insurance coverage, at Lender's option and Borrower's ;,arose. Leander is under no obligation to purchase any particular type or amount of coverage. Therefore, such _ i Trage shall cover Lender, but might or might not protect Borrower, Borrower's equin, in the Properly. or the contents of the Property, against any risk, hazard or liability and it ight provide greater ur Lasser i /v_rage that was previously in effect. Borrower acknowledges that the asst of the insurance coverage st obtained night significantly exceed the cost of insurance that Borrower mould have obtained. Any anrou is disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Secu-ity Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and rene;va.s of such policies shall be subject to Lender's right to disappmve such policies, shall include a standsrd mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender sh ell have the right to hold the policies and renewal certificate:. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such po;ic% shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an aeditional lass payee. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, any insurance proceeds, whether or nos the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not +essened. During such repair ane restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, prgvlded that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless - i agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall dot be required to pay Borrower any interest or earnings on such proceeds. Fees for publ a adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance I;.roceecs imd shall be the sole obligation of Borrower. If the restoration or repair is not economically feasible or -..ender's security would be lessened, the insurance proceeds shall be applied to the sums secured 'uy this Security instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance prr ce. ds shall be applied in the order provided for in Section 2. If Borrower abandons the Property, Lendtr may file, negotiate and settle any available insurance claim and related matters. If Borrower does not responI within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lancer may negotiate and settle the claim. The 30-day period will begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby = gns to Lender (a) Borrowers rights to any insurance proceeds in an amount not to exceed the amovid,. unpaid under the Note or this Security Instructions, and (b) any other of Borrower's rights (other than the right ro any refund of unearned premiums paid by Borrower) under all insurance policies covering the property, insofar as such rights are applicable to the coverage of the Property. Lender may use rite insurance proceeds either to repair or restore the Property or to pay amounts unpaid ender the Note or this Security Icsn-ument, whether or not then due. 092742N (M-91PA) ?cooet ,•.u.). 6 wfl h A9 Form 3039..1/01 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Sec trity Instrument and shall continue to occupy the Property as Borrower's principal residence for at least of a year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not 've unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control 7. Preservation, Maintenance and Prorection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Properly to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section 5 that repair or testoralion is not economically feasible, Borrower shall promptly repair the Property if damaged to avoid ti.rtber deterioration o. damage. If insurance or condemnation proceeds are paid in connection with danflge to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs a ad restoration in a single payment or in a series of progress payments as the work is completed. If the imu-ance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is aot reliev A of Borrower's obligation for the completion of such repair or mnomtior- Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause, Lender may inspect the interior of the imnravements on the Property. Lender shall give Borrower notice at the time of or prior to such as intcrio: inspection specifying such reasonable cause. 8. Borrower'. Loan Application. Borrower shat be in default if, during the Loan application process, Borrower or tiny persons or entities using ?',,,. t: a direction of Borrower or with Borrower's knowledge or consent give materially false, misleading, or inaccurate infcernation or statements to Lender (or failed to provide Lender with material information) in connection with the Loan. Material representations include, but are not limited to, representations concerning Borrowers occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest in the Properly and Rights Under this Security Instrument. If (a) Borrower fails to per'orm the covenants and agreements contained in this Security Instrument, (b) there is a legal proceeding that night signifuntly al'i:ct Let tier's interest in the Property and/or rights under this Security Instrument (such as a proceeding io pankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain'prorir;! over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned fire Prope ty then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest ir. the Property and rights under this Security Instrument, including protecting and/or assessang the value of the Property, and severing and/or repairing - the Property. Lender's Pctions can include, bm ate not imited to: (a) paying any sums secured by a lien, which has priority over this Security Instrument; (b) acpearing in court; and (c) paying reasonable attorneys' fees to protect its interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy procceding. Secur'of the Property includes, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take action.under this S vxion 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lerder incurs no liability for not taking any or all actions authorized under this Section 9. 002742'7 d11Ye:?_ ®®6IPAt roost v,?.e of 3 Form 3039 1/01' Any amounts disb=ed by Lender eider tlrs Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts sha 1 bear interest at the Note rate from the date of disbursement and shall t•e payable, with such inl,;rest, pan notice from Lender to Borrower requesting payment. If this Security Instrument is on a leasc:iold, Borr ws shall comply with all the provsions of the lease. If Borrower ncidies fee tide to the Pm:3 r!y, the 'easehold and the fee title shall not merge unless Lender agrees to the merger in writing.' 10. Mortgage Insurance. If Lender regniral Mart; ag_ Insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain th.- Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance coverage requited by Lender cer.:e5 to be available from the mortgage insurer that previously provided such insurance and Borrower was enaired to make separately designated payments toward the premiums for Mortgage Insurance, Borrower. shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage hhso m-e previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mori„age 1 isurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to pay to Lender the maml of the separately designated payments that were due when Lie insdranoe coverage. ceased to be it effect. Lender will accept, use and retain these payments as a non-refuidable loss reserve in h.u of :Wrtgage Insurance. Such loss reserve shall be non-refundable, notwahstanding the fact that the ',am i ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on soh loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in t:: amount and for the period that Lender requires) provided. by an insurer selected by Lender agar beccmes available, is obtained, and Lrnder requires separately designated payments toward the premiums for 46stgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to mate separately designated payments toward the premiums for Mortgage hisuranc e, Borrower shall pay the premiums required to maintain Mortgage Insurance. in effect, or to. provide a non-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest a. the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for chain losses it may incur if Borrower does not repay the Loan as ri;reed. Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into agreements with other parties drat share or nhcdify their risk, or reduce losses. These agreements are on terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. These agreements may require be mcrtgage insurer to make payments using any source of funds that the mortgage insurer may have a,::a ahle ( vhich may include funds obtained from Mortgage Insurance premiums). - As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsurer. any other entity, or any affiliate of any of the foregoing., may receive (directly or indirectly) amounts that derive from (or might be characterized aa) a portion of Borrower's payments for Mortgage Insurance, is exchange for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid in the insurer, the arrangement is cften termed "captive reinsurance." Further: (a) Any such agreements will. not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of thx Loan, Such agreements will not Increase the amount Borrower will owe for Mortgage Insurance, mal they All not entitle Borrower to any refund. 0(1274227 't CD -G(PA) roocai ;•w am 6 Form 3039 110 (b) Any such agreements will not affect the right; Borrower has - if any - with respect to the Mortgage Insurance ender the Homeowners Proteetiol Act of 1998 of any other law. These rights may include the right to receive certain disclosures t ) request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Inset ance erninated automatically, and/or to receive a refund of. any Mortgage Insu ante premiums thrt wei. unearned at the time of such cancellation or termination. 11. Assignment of Miscellaneous Proceeds.. Fort tit.,re. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Linder. If the Property is damaged, such Miscellaneous Pro,:eeds shall be applied to restoration or repair of the Property, if the restoration or repair is econoinicllly feasible and Leader's security is not lessened. During such repair and restoration period, Lender small hc,e the right to bold such Miscellaneous Proceeds until lender. has had an opportunity to inspect such Prop cry to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall ;re undertaken promptly. Lender may pay for the . repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to, pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or lender's security would be lessened, the Miscellaneous Proceeds shall be applied w the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid. to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the even, of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by eiis Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. In the event of a partial taking, destruction, or loss n value of the Property in which the fair market value of the Property immediately before the partial l.M?ng, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Se;:urity Instrument immediately, before the partial taking, destruction, or loss in value, unless Borrower aqd Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following fraction: (a) the tote mot nt of the sums secured immediately before the partial taking, destruction, or loss in value divided sy (b) the fair market value of the Property immediately before the partial taking, destruction, it loss in value. Any balance shall be paid to Borrower. In the event of a partial taking, destruction, or loss it value of the Property in which the fair market value of, the Property immediately before the pailial ink'ng., destruction, or loss in value is less than the amount of the sums seci imd immediately before the pal:ied taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sours secured by this Security Instrument whether or not ;he subs are ther. due. If the Property is abandoned by Borrower, or it. after notice by lender to Borrower that the Opposing Party (as defined in the next sentence) offers o make an award to settle a claim for damages, Borrower fails U respond to Lender within 30 dal-; after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceetfi ither a restoration or repair of the Property or to the sums secured by this Saccriry Instmmera, whether w not lea due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party a, Lint whom Borrower has a right of action in regard to Miscellaneous Proceeds. - Borrower shall be in default if any action or precee lit,;, whether civil or criminal, is begun that, in Lender's judgment, could result in forfeiture of she Po perty or other material impairment of Lender's interest in the Property or rights under this Secrr'r; lnst urent. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided jr, Sectil it 19, by causing the action or proceeding to be 002742,7 IN+4Y: . -61PA11ooo81 rear 10.113 Form 3030 1101 dismissed with a ruling that, in Lender's judgmear, prmladrz forfeiture of the Property or other material impairment of Lender's interest in the Property or rights antler this Security Insimment. The proceeds of any award or claim for damages that are attributable, to the. impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender. All Miscellaneous Froceeds that are not applied it, restoration or repair of the Property shall be applied in the order provided for in Section 2. - 12. Borrower Not .Released; Forbearmrce By Lender Not a Waiver. Extension of the time for payment or modific tioa c f amortization of the sums seem :d by this Security Instrument granted by Lender to Borrower or any Successorin Interest of Boropcr she. l rent operate to release the liability of Borrower or any Successors in Interest of Borrower. Lendri, shall rut be required to commence proceedings against any Successor in Interesi of Borrower or to ml se u) extend time for payment or otherwise modify amortization of the sums secured by this Security lnstrume it by reason of any demand made by the original Borrower or any Successors in Interest of Borrowei. Any for oearance by Lender in exercising any right or remedy including, without limitation, Lender's acceptar ae of payments from third persons. entities or Successors in Interest of Borrower or in amounts leas than. f i amount then due, shall not be a waiver of or preclude the exercise of arty right or remedy. 13. Joint and Several Liability; Co-signer: Sues. ssors and Assigns Bound. Borrower covenants and agrees that Borrower's obligations and liability shall 1:= joint and several. However, any Borrower who co-signs this Security Inetrumem but does not execute :ht Note (a "co-signer"): (a) is co-signing this Security Instrument only to mortgage, grant and convey he co-signer's interest in the Property under the terms of this Security Instrument; (b) is not persor-ally oaigated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terras of .rig Security Instrument or the Note without the co-signer's consent. Subject to the provisions of Section 1E, any Si c_ssor in Interest of Borrower who assumes Borrower's obligations under this Security Instrument in :writing, and is approved by Lender, shall obtain all of Borrower's rights end benefits under this Security In..trument. Borrower shall not be released from Borrower's obligations ard liability under this Security I stcument unless Lender agrees to such release in writing. The covenants and agreements of this Security, instrument shall bind (except as provided in Section 20) and benefit the successors and assigns of leneer. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lende- s interest in the Property and rights under this Security Instrument, including, but not limited to, attorr: ys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express author,ty :n this Security Instrument to charge a specific fee to Borrower shall not be construed as a prohibition or the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security Inmunr:m or by Applicable Law. If the Loan is subject to a law which sets inaxunum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be co: ected in connection with the Loan exceed the permitted limits, then: (a) any such loan charge shall b:: reduced by the amount necessary to reduce the charge to the permitted limit and (b) any sums sit eady c )11?cted from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choore to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment wiu:out any prepayment charge (whether or not a prepayment charge is provided for under the Note). Bo7rcwer's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of ar y right of action Borrower might have arising out of such overcharge. 15. Notices. All notices given by Borrower or Leader in connection with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to 41274221 -6(PA) iooom >,e n ai a Farm 3039 1101 have been given to Borrower when mailed by Ent ciiss mail or when actually delivered to Borrower's notice address if sent by other means. Notice to ;:ry one ;orrower shall constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. Tha notice address shall be the Property Address unless Borrower has designated a substitute nonce address by notice to Lender. Borrower shall promptly notify Lender of Botrower's change of address. If Lende sl,ecifies a procedure for reporting Borrower's change of address, then Borrower shall only mror.. a ehn tge. of address through that specified procedure. There may be oily one cesignated notice address under this Security Instrument at any one time. Any notice to Lender shall be• given by delivering it or by n riling it by first class mail to Lender's address stated herein unless Lender has designated another ac drrss by notice to Borrower. Any notice in connection with this Security Instrument shail not be dee nej to have been given to Lender until actually received by Lender. If any notice required by this Secur,;y Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the 'co responding requirement. under this Security Instrument _ 16. Governing Law; Severability, Rules of Cc kslfuction. This Security Instrument shall be governed by federal law and Lie law of the juuisd)ction n which the Property is located. All rights and obligations contained in this Security Instrument are :,Juicer to any requirements and limitations or Applicable Law. Applicable Law might explicitly or imp lcidy allow the parties to agree by contract or it might be silent, but such silence shed not be consimed a. a prohibition against agreement by contract. In the event that any provision or clause of this Security li.strument or the Note conflicts with Applicable Law, such conflict shall not affect other provisions of th s Security Instrument or the Note which can be given effect without the conflicting provision. As used in this Security Instrument: (a) words m the masculine gender shall mean and include corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include the plural and vice versa; and (c) the word "may' gives sole discretion without any obligation to take any action. 17. Borrower's Copy. Borrower shall be given one :opy of the Note and of this Security Instrument. 18. Transfer of the Property or a Beneficial Interest in Borrower: As used in this Section 18, "Interest in the Property" means any legal or beneficial irterest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of tibe by Borrower at a future date to a purchaser. If all or any part of the Property or any Interest in tie Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Leader's prior written consent, Lender may require immediate payme?d in full of all sums secured by this Security Instrument. However, this option shall not be ;:xercistd by Lender if such exemise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Itorrower notice of acceleration. The notice shall. provide a period of not less than 30 days from the date tae notice is given in accordance with Section 15 within which Borrower must pay all sums termed by tl.is Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lem''.er may invoke any remedies permitted by this Security Instrument without further notice or dematd on Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of 0 is Security Instrument discontinued at any time prior to the earliest of: (a) five days before sale of the Pr,perty pursuant to any power of sale contained in this Security Instrument;' (b) such other period a; Aprilcable Law might specify for the termination of Borrower's right to. reir;state; or (c) entry . of a judgr rew enforcing this Security Instrument. Those conditions are that Bonpwer. (a) pays Lender ail sums; which then would be due under this Security Instrument and the Note is if no acceleration had cccurm 1; (b) cures any default of any other covenants or 00'2'42:1 ®6(PA) iaoom va. 12 0 1 Form, 3039 1101 agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inepecGou and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property mud rights under this Security Instrimarrit; and (it) takes such action as Lender may reasonably require to a;scre that Lender's interest in the Property and rights under this Security Instrument, and Borrower'sobligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender quay require that Borrower pay such reinstatement sums and expenses in one or more of the following forma, as soh cted by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a fedc:al ngtacy, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Se.urily histroment and obligations secured hereby shall remain fully effecti,.e as if no acceleration had me aced. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer; Noticz of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) an be sold one or more times without prior notice to Borrower. A sale might result in a change in th-a entity tknown as the "Loan Servicer") that collects Periodic Payments due under the Note and this Securit- Instrument and performs other mortgage loan servicing obligations undo the Note, thin Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer unrek to:f to a Tale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the eir ng,, which will state the name and address of the new Loan Servicer, the address to which payments sho ild be made and any other information RESPA requires in connection with a notice of transfer of servici. ig If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of ;he Note, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be traasterred to a successor Loan Servicer and are not assumed by the Note purchaser un "a otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, e, be joined to any judicial action (as either an individual litigant or the member of a class) that arises trim the other party's actions pursuant to this Security Instrument or that alleges that the other party ha: breached arty provision of, or any duty owed by reason of, this Security Instrument, until such Borrower )r i.ender has notified tie other party (with such notice given in compliance with the requirements of See ion 15) of such alleged breach and afforded the other party hereto a rm4onable period after the givirg of such notice to take corrective action. If Applicable Law provides a time period which must elarse before certain action can be taken, that time period will be deemed to be. reasonable for purposes o' this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Secticn 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to mut if_y the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined as toxic or hazardous substances, polatams, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammaAc or toxic petroleum products, toxic pesticides and herbicides, volatile. solvents, materials containing asbestos or formaldehyde, and radioactive materials;' (b) "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (c) "Environmental Cleanup" includes any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition" means a condition that can cause, contrif.ute to, or otherwise trigger so Environmental Cleanup. 002'4227 Initials:AWg M0-61PAI warn vase 13 of • 6 Form 3039 1/01; Borrower shall not cause or permit. the presence, List, disposal, storage, or release of any Hazardous Substances, or threaten to release any Hazardous Substanc'-s, on or in the Property. Borrower shall not do, nor allow anyone else to In, anything affecting the Pmpt try (a) that is in violation of any Environmental Law, (b) which creates an Environmental Conditiix, or ((.o chich, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely aff;ets the value of the Property. The preceding two sentences shall not apply to the p'r=nce, use, or storage on the Property of small c'=lines of Hazardous Substair m that are generally recog_?fztd to I e ;appropriate to normal residential uses and to maintenance of the Property (including, but not limited to. hazardous substances in consumer products). Borrower shall promptly give lender written notice of (a) any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agent} or private party involving the Property and any Hazardous Substance or Environmental Law of win It Borrower has actual knowledge, (b) any Environmental Condition, including but not limited to, ary spilling, leaking, discharge, release or threat of release of any Hazardous Substance, acid (c) my condiEon,caused by the presence, use or release of a Hazardous Substance which adversely affects the value ci the Property. If Borrower lesion, or is notified - by any govermnemal or regulatory authority, or any pri+ ate party, that any removal or other remediatioq . of any Hazardous Substance affecting th:n Property is Lieu vat y, Borrower shall promptly take all necessary remedial actions in accordance with Fsvimitmental Lav. lothing herein shall create any obligation on Lender for an Environmennal Cleanup. NON-UNIFORM COVENANTS. Eorrower and Le-de, further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give urn ce to Borrower prior to acceleration following Borrower's breach of any covenant or. agreement i t this Security Instrument (but not prior to acceleration under Section 18 unless Appli-,able Lnw provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) tae action required to cure the default; (c) when the. default must be cured;. and (d) that failure to cure the default m specified may result in acceleration of the snms secured I:y this Security Ins[, uraeny foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-e;dstence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Leader at its option may require immediate payment in full. oi' all sums secured.by this Security Instrument without further demand and may foreclose this Secut fly Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in put sai.ng the remedies provided in this Section 22, including, but not find ed to, attorneys' fees and costs of title evidence to the extent permitted. by Applicable Law. . 23, Release. Upon payment of all sums secured by this Security Instrument, this Security Instm nit and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy tl»s Security Instrument. Borrower shall tav any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, 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. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in proceedings to enforce this Security Instmmenu, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and We, and homestead exemption 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour, prior to the commencement of bidding L: a shera't'ssale or other sale pursuant to this Security Instrument. 26. Purchase Money Mortgage. If any of the debt secured by this Security Instmment'is lent to Borrower to acquire title to the Property, this Security In;ntiment shall be a purchase money mortgage. 27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is. entered on the Note or is an action of mortgage foreclosure shall be the rate payable from time to time under the Note. - OC274227 MOSIe (M•BIPA) iooos) r.,e•ta 0 ia Form 3039 1101; BY SIGNING BELOW, Borrower accepts acid agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Birrow Ir end recorded with it. Witnesses: (Seat) AR 1R HIEBER -smrawer - -- --- (Seat) -Borrower (Sea:? _ (Seal) -Borrower -Borrower (Seal) _ _ (Seal) -Barraw6r -Borrower (Seal) __ (Seal) -BOfroWCf -Borrower 00274217 CD -BIPA) toaosi Pape 15 ot'6 i Form 3039 1101: 1 Certificate of Residence 1, Michelle Pierce ' , do hereby certify that the correct address ofthewithin-named Mortgagee is 40J Lippincott Drive, Marlton, NJ 08053 Witness my hand thi: 21st day u' August. 2001 Michelle'i-rce Agent ofMongegm COMMONWEALTH 02? PENNSYLVANIA, County ss: On this, the 21st day of August.. 2001 , before me, the undersigned officer, personally appeared ARTHUR HIEBFR known to me (or satisfactorily proven) to 'le the person(s) whose ,ame(s is/we subscribed to the within instrument and acknowledged that helshehhey executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand end official seal. My., Commission Expires: to's I l\) Tiac of Officer m-61PA1 moss -, 00274227 w: rs. to of ti: Form 3039 1101 BALLOON NOTE; R ,* (Fix :A R a I e) SAL THIS LOAN IS PAYABLE IN FULL AT MATURITY. YOU MUST REPAY THL. ENTIRE PRINCIPAL BALANCE OF THE LOAN AND UNPAID INTEREST THEN DUE. LENDER IS UNDER NO OBLIGATION TO REFINANCE THE LOAN AT THAT TIME. YOU WILL, THEREFORE, BE RECUIRED TO MAKE PAYMENT OUT OF OTHER ASSETS THAT YOU MAY OWN, OR YOU WILL HAVE TO FIND A LENDER, WHICH MAY BE THE LENOER YOU HAVE THIS LOAN WITH, WILLING TO LEND YO 1 THE MONEY. IF YOU REFINANCE THIS LOAN AT MATURITY, YOU MAY HAVE TO PAY. SOME OR ALL OF THE CLOSING COSTS NORMALLY ASSOCU,TED WITH A NEW LOAN EVEN IF YOU OBTAIN REFINANCING FROM THE SAME LENDER. August 21. 2001 Marltoli New Jersey IDatel [City) lsawl 1712 CHATHAM ROAD.(AM' HILL, PA 17011 IPmpe¢y Add. essl 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.! --. $112,500. 00 (this amount is called "Principal"), plus interest, tottecrder of Lender. Lender is Equ t;y On2. inc., dba Popular Financial Services I will make all payments under this Note in the form Of cash, thee;: m money order. 1 understand that Lender may transfer this Note. Lender or a•.ryone who takes this Note by transfer and who is entitled to receive payments under this Nwe is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal will the fall ziao-m of : rmcip3l has been paid. I will pay interest at a yearly rate of 10.7500 %. The interest rate required by this Secion 2 is the rate I will nay both. hcinre and after any default described in Section 6(B) of this Note. - 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a paymer t ::very month. I will make my monthly payments on the 1St day of each month beginning on October 1, 2001 I will make these payments every month until I have paid all of he principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal;. If, on . Septemb?r 1. 2016 , 1 still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at400 Lippinectt Drive. Marlton, NJ 08053 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. S 1, 050. 17 00274227 00274227 MULTISTATE BALLOON FIXED RATE NOTE, Single Family -FANNIE MAE UNIFORM INSTRUMENT P. tars ®-870N IW0el Mw O65b VMP MOmGAGE FOAMS. N0015211291 Form 3260 1101 InIn w4: 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at :ray lime b, fore they are due. A payment of Principal only is known as a "Prepayment." When I sake a Prepayment, I will tell the Note Heider in writing that I am doing so. i may not designate a payment as a Prepayment if I have not made al I tie mo thly payments due under this Note. I may make a full Prepayment or partial Prepuymene with., a paying any Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal 1I.; i f owe i rider this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid hrterest on the !'repaya:err amount before applying my Prepayment to reduce the Principal amount of this Note. If ; make a partial Prepay m. fit, tit! re will to no .hinges in the due date or in the amount of my monthly payment unless the Note Holder agrees in w: 118 to 4,ose chan,;es. 5. LOAN CHARGES If a law, which applies to th:ls loan mud which sets r.raximun' loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connexion with this lox: cxceed the permitted limits, then: (a) any suit loan charge shall be reduced by the amount necessary tc reduce the charge to kite permitted limit; and (b) any sums already collected from me that exceeded remtitted limits will be refunded to me. Tice Note Holder may choose to make thin refund by reducing the Principal I owe ender this Note or by mxiiag a.direc. payment to me. Lf a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charges for Overdue Payments If the Note Holder has not received the full amount of arty monthly payment b/ the end of 15 calendar days after. the date it is cue, I will pay a late charge to thr Note Holder. The amount of Ste charge will be 5.0000 % of my overdue payment of pi incipa. and interest. I will pay this late charge promptly but only once on each late payment (B) Default If I do not pay the full amount of each momhdy payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Solder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay irrurcdiately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to mo or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I aria in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in fell as described above, the Note Holder will have the right to be paid back by one for all of its costs and expenses in enforcirg this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Pre?erty Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this. Note will be given by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fulh and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who tal. -s over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person indivi; wally or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Nou waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to den,md payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other person , that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note. a Mortgage, Deed of Trtst, or Security Deed (the "Security Instrument"), dated the lime date as this Note, protects the Note Holder from possible losses that might 'result if Ido not keep the promises that 1 make in this Note. That Security Instrument describes how and wider whit conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those condin ions read as follows: 00274 )2t Form 3; Transfer of the Property Ora Beneficial Interest is Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest in the Pre perty, including, but not limited to, those beneficial interests transferred in a bond for deed contract for deed, inste9ment sales mlibact or escrow agreement, dte intent of which is the transfer of title,by Borrower ai a fume d, re to a purchaser. If all or any part of the property or any Interest in the /rcperty is sold or transferred (or if Petrower is not a natural person and a beneficial interest in B=ower is ;u;lci o! transferred) without Lender's prior written cousent, Lender may require immediate payment in fall of all sums secued by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice iy gi_•en in accordance with Section 15 within which Borrower most pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period Lender may invoke any reme dies pgrnlitted by this Security basbument without further notice or demand on Borrowe . SS E HAND( ) AND SEAL(S) OF THE UNDERS'G JED. (Slat ) ARTHUR HIEBER Bowe - B(rro?w (Sul) __ (Seal) -BOOtiwel -Borrower (Seal) _ -0..n, wet -Borrower (Seal) ..aer. -Borrower [Sigr, Original Only] SAW (DUM) a d Pag 3 03 Gpm 32ro 1A1 1B0]Ip}r 03-n-0I 00274(.2' PRE, PA17It4ENT Rlf)ER TO NOTE This PREPAYMENT RIDER TO NOTE in made t'.is 2 1 day of 0 8 12 0 01 and is incoporated into and amends, modifies and sup dements the Note of the same date given by the undersigned (the "Borrower") to F , i n i ; y One, I n c. , d b a Popular Financial Se (the "Lender") and any riders or modifications tl,areto "Note"). In addition to the agreements made in the Note, Cor. ower and Lender further agrees as follows: 1. The section of the Vote entitled "Boi romor!s Mgt: to Prepay", is hereby deleted in its entirety and repo,,, i with [he follcveing language: 4. BORROWES,'S RIGHT TO RF ' T'REPAYTAENT CHARGE I have the right to rnake payments of pi at trv time before they are due, but the Note Holder may apply any+.endered paymums fir t to any amounts then due and owing under this Note or under the Security Ins romc? t and tl-, -i to principal not yet due. A payment of principal only is known as a "prspayrror'." A prepayment of all the unpaid principal is known as a "full prepayment. A pr;pay;nciii cl only pat ut the unpaid principal is known as "partial prepaymer r". If I make a partial prepayment, therp w.11 b _ no cI' anges in the due dates or amounts of my subsequent scheduled monthhi paymi nta unless the Note Holder agrees in writing to those changes. Partial prepayments :;had ba e.pplied to the Iasi scheduled installments in reverse chronological order, urdcss off ervise required by applicable law, starting with the final scheduled monthly insta!In lent. I, a aggregate amount of principal prepaid in any twelve (12) month period axcE:eoa twenty percent (20%) of the original principal amount of this Note during the first ht E E ( 3 ) years commencing from the date of this Note, then as consideration for the acceptance of such prepayment, and in addition to any other sum payable hereunder, ! agree o pay the Note Holder a prepayment charge equal to six (6) months' interest on the amount of any prepayment exceeding twenty percent (20%) of the original principal loan amount. 2. Section 3 of the Note regarding application of pa; ments is hereby amended by adding prepayment charges to the list of "caner charges". ARTHUR H I E R F R r.(Seal) - . (L? m,m v aom ao"Pwer E?„a.e, PREPAYME RMER 10 NTe Pi "limo,lam MATTLEMAN, NVEWOTH & MILLER A PROFESSIONAL CC. RPORAnoN wcouNS¢ NATA G. SAVA Af COUNSELLORS IT LAW s{Ero1xmNNVSm91e .: , OAWE B.CMROLL (9'eORG01. M'EW0.0IH LMK{ 1®IHAN MATIIF1VOl' FAMD. PAGLG.AMON60N WLOBPSMBOIw EFIC I.SffIN AUREllA AGIC!¢?1 pl1AANTa SNA&ON WASMGRGAN ANIGWETIE0.NOUANG? ADw0.Ei(IABTf EPEE N. W,ARUS LYNNM BOwIBY! PEEK], MsmA + - PluvPatto: CHERRY HILL AGiLAME I. iH(MMbssGNp MIGBMSMAC[? F M N ? ?n II. °`F11N0. GA ]+ C eEUE Ea 415/58415 wsm B. wmmoms{uw KATHEBME G. SAMANGGG O DN p T s SHANNON G. . S SFAMAT®E A@.IDERE OF TI6 NIA lABMd pN]&FLBAES +Nl,lAk1.IDEA0.4 'IA BARONET SARS E& D a AEONLY + BARS m f?A MS v GE BARpG.v December 14, 2001 { W. . PA PA & M BAPS ACT 91 NOTICE TAKE ACTION TO SAVE i YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your Lome is in default, and the lender intends to !D foreclose. Specific information about the nature of the default is provided in the attacheo cages The HOMEOWNER's MORTGAGE ASSISTANCF. PROGRAM (HEMAP) may be able to help to save your home. This Notice exNains how the Proaram works can call (717) 780-1869. 401R VF OlmvW 8*42MBrv010N FAx: (a56)R9A9]6 LwBTmBmmnnc scoregam BAwBACxmnBSnm9 BdPMS 19110 PeownEa :n1 (21 5)9]}aam Taa: 199 CpBmuNrM mrve.slmeail 1Y)1] NSWAU(3M)73.V1LSN9 F.:Mt] II]5BlwnEn¢r,FMEm) C.,NeN]vs MB M(9n)mm .0 FAa:(9n)]s 43 P 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 iMORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SI CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADOARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE DALVAR SU CASA DE LA PERDOD DEL DERECHO A REDMIR SU HIPOTECA HOMEOWNERS' NAME: Arthur Hieber i MORTGAGED PROPERTY: 1712 Chatam Road Camp Hill, PA 1,7011 LOAN ACCT. NO.: 274227 CURRENT LENDER/SERVICER: Equity One YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY TEMPORARY STAY OF FORECLOSURE - Under the Act, you are enfitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. 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. DATE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of desianated consumer counseling agencies for-the ceJnty in which the property is located are set forth at the end of this Notirg.. It is only necessary to s?,hedule ore 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 or your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners Emergency Mortgage 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. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDSATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 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). 1 I NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 1712 Chatham Road Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: October 1, 2001 to December 1, 2001 at $1,050.17 per month Late Charges: $105.02 TOTAL AMOUNT PAST DUE: $3,255.53 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of this date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $3,255.53, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash Eguity one 400 Lij)pIncott Drive Marlton. NJ 06053 IF YOU DON'T CURE THE DEFAULT - If you do nat 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 mada within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal actor to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - TI,e mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any Attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30 ) DAY period, you will not be required to pay attorney's fees. ' OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - if you have not cured the default within the THIRTY (30) DAY period and forecloses: proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately FIVE (5) months from the date of this kotice. A notice oi the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amourc: needed to cure the default will increase the longer you wait. You may find out at any time exectly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Equity One Phone Number: 800 383 2292 Contact Person: Loan Counseling Unit EFFECT OF SHERIFF'S SALE - You should raalize that a Sheriff 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 may not 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 it at the sale and that the other requirements of the mortgage are satisfied. Please contact: YOU MAY ALSO HAVE THE RIGHT: PAY DEBT TO SELL THE PROPERTY TO OBTAIN MONEY TO ORTOBORROW MONEY FROMANOTHER NDNGINSTITUTIONTTOPAYOFFTHE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF TO HAVE THE MORTGAGE RESTORED TO `. HE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE r i THIS RIGHT TO CURE YOUR DEFAULT tIORE THAN THREE TIMES IN ANY CALENDAR YEAR) T FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT RJSTITUTED UNDER Y THE MORTGAGE DOCUMENTS TO ASSERT ANY OTHER DEFENSE YOU BEL,EVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BNKRUPTCY LAW. CONSUMER CREDIT COUNSELING, AGENCIES SERVING YOUR COUNTY IS INCLUDED. 1 Sharon Oras Morgan, Esq ire Mattleman, Weinroth & Ml ler CS4 CA ? ?_?- v/ ' 1 ?` N SHERIFF'S RETURN - REGULAR CASE NO: 2002-02683 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS HIEBER ARTHUR KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HIEBER ARTHUR the DEFENDANT , at 1943:00 HOURS, on the 6th day of June , 2002 at 1712 CHATHAM ROAD CAMP HILL. PA ARTHUR HIEBER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.04 Affidavit .00 Surcharge 10.00 .00 39.04 Sworn and Subscribed to before me this /7 If, day of zooms A. D. Prothonotary So Answers: R. Thomas Kline i 06/10/2002 MICHAEL J MILSTEAD By: eput S er' THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC BY: THOMAS J. COLEMAN, III, ESQUIRE Attorney ID# 58607 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP Morgan Chase Bank, as Trustee for Equity : COURT OF COMMON PLEAS One, ABS, Inc., Mortgage Pass-Through : CUMBERLAND COUNTY Certificates, Series 2001-1 Plaintiff VS. No.: 02-2683 Civil Term Arthur Heiber Defendants TO THE PROTHONOTARY PRAECIPE TO ENTER DEFAULT JUDGMENT Kindly enter Default Judgment in favor of Plaintiff, JP Morgan Chase Bank, as Trustee for Equity One, ABS, hie., Mortgage Pass-Through Certificates, Series 2001-1 and against the\ defendant, Arthur Heiber for failure to Answer the Complaint in Civil Action - Mortgage Foreclosure. Service was made on the Defendant, Arthur Heiber via the Sheriff of Cumberland County on June 6, 2002. Assess damages as follows: Total Debt as of 5/20/2002: Interest from 5/20/02 thru 7/23/2002 Increase in Late Charges since 5/20/02 Increase in Escrow Deficiency since 5/20/02 Costs TOTAL AMOUNT OF JUDGMENT $ 127,342.01 2,120.32 105.02 697.28 207.50 $ 130,472.13 The Law Office of z #5 III, Esquire THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC BY: THOMAS J. COLEMAN, III, ESQUIRE Attorney ID# 58607 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP Morgan Chase Bank, as Trustee for Equity One, ABS, Inc., Mortgage Pass-Through Certificates, Series 2001-1 Plaintiff VS. Arthur Heiber Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY No.: 02-2683 Civil Term AFFIDAVIT OF ADDRESSES COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SS I, Thomas J. Coleman, III., Esquire, being duly sworn according to law, upon my oath, depose and say: 1. I certify that the Plaintiff's address is 400 Lippincott Drive, Marlton, NJ 08057. 2. I certify that the Defendant's address is as follows: 1712 Chatham Road, Camp Hill, PA 17011. 3. I certify that the foregoing information is true and correct to the best of my knowledge, information and belief. Sworn and Subscribed to before me this (96-1 day of 3L) / L/ 2002. USA L BECK NOTARY PUBLIC OF NEW JERSEY ConxNsdon Expires 11912001 The Law Office ofMiccjiad?. Milstead, LLC in, III, Esquire 58607 THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC BY: THOMAS J. COLEMAN, III, ESQUIRE Attorney ID# 58607 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP Morgan Chase Bank, as Trustee for Equity : COURT OF COMMON PLEAS One, ABS, Inc., Mortgage Pass-Through : CUMBERLAND COUNTY Certificates, Series 2001-1 Plaintiff VS. No.: 02-2683 Civil Term Arthur Heiber Defendants AFFIDAVIT OF NON- MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS I, Thomas J. Coleman, III, Esquire, Attorney at Law, being duly sworn according to law, upon my oath, depose and say: 1. That the Defendants are not in the Military, Naval of Air Services of the United States of any other Country within the provision of the Soldiers' and Sailors' Civil Relief Action of Congress, as amended; and 2. That the Defendant is at least 21 years of age and resides at 1712 Chatham Road, Cam Hill, PA 17011. The affiant has ascertained the foregoing information by personal inquiry and knowledge and makes this Affidavit with the authority. Sworn and Subscribed to before me this c26-thday oU02. LISA L. BECK IIOTARYPUBLICOFNEWS y Cororo>SM1011 E"m 119/007 THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC BY: THOMAS J. COLEMAN, III, ESQUIRE Attorney ID# 58607 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP Morgan Chase Bank, as Trustee for Equity : COURT OF COMMON PLEAS One, ABS, Inc., Mortgage Pass-Through : CUMBERLAND COUNTY Certificates, Series 2001-1 Plaintiff VS. Arthur Heiber Defendants No.: 02-2683 Civil Term AFFIDAVIT OF SERVICE COMMON WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS I, Thomas J. Coleman, III, Esquire, Attorney at Law, being duly sworn according to law, upon my oath, depose and say: 1. I am a member of the Law Office of Michael J. Milstead, LLC, attorneys for Plaintiff in the above entitled cause of action. 2. Notice, Rule 237.1 was forwarded to the Defendant(s), place of residence by regular mail on June 28, 2002 and has not been returned to this office, so it can be assumed that same has been delivered to Defendant. Sworn and Subscribe to before me this ?I?day of X01 ti - - 2002. LISA L. BECK NOTARY PUBLIC OF N1 #MW Commiss(on Expires 1/9/W The Law Office OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary TO: Arthur Hieber June 28, 2002 JP Morgan Chase Bank, as Trustee for Equity One, ABS, Inc.,Mortgage Pass-Through Certificates, Series 2001-1 Plaintiff VS. Arthur Hieber Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 02-2683 Civil Term NOTICE, RULE 237.1 IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within ten (10) 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 on Pracde nt To 1Pab Debt Cope t? - Dlotic collect a debt and any ?O This is an attempt for that Purpo obtained wW be used CA O: 2002-003 P COMMONWEALTH O.F PEB VS SHERIFF'S RETURN - RE AR ?y r?l YLVANIA: v KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE HIEBER ARTHUR was served upon the DEFENDANT , at 1943:00 HOURS, on the 6th day of June 2002 at 1712 CHATHAM ROAD CAMP HILL, PA 17011 by handing to ARTHUR HIEBER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 11.04(?+? p Affidavit .00 •?/'? Surcharge 10.00 R. Thomas Kline .00 39.04 06/10/2002 MICHAEL J MILSTEAD Sworn and Subscribed to before By: me this day of., eput S er' A.D.- Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary TO: Arthur Heiber JP Morgan Chase Bank, as Trustee for Equity One, ABS, Inc., Mortgage Pass-Through Certificates, Series 2001-1 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Plaintiff VS. No.: 02-2683 Civil Term Arthur Heiber Defendant : NOTICE PURSUANT TO RULE 236 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: THOMAS J. COLEMAN, III, ESQUIRE #58607 THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC 856-222-1508 NOHce____-- •?i? T, ?n attempt to eo?eet t be used for that purPOM LAW OFFICE OF MICHAEL J. MILSTEAD, LLC Attorneys at Law 325 New Albany Road Moorestown, NJ 08057 TEL(856)222-1508 FAX(856)222-1580 Michael J. Milstead miChu *milst %a W.com liaa Mn Thomes, Admi "W, INomasrAmiLeha0law.com Of Counsel Thomas J. Coleman, III Licensed Pennsylvania Adomey Please Reply To: NJ Office Our File No.: Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940, specifically, 60 U.S.C.A. Section 601 et sec., please provide us with the current Military Status of the following persons: NAME SSN/DOB NOT IN IL IN MIL SERVICE u 1'1 - 4b 75cb Virginia Or a: Deborah Watson Date: Date: JUL 0 3 2002 k w a l THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Eric Meth, Esquire Attorney ID#59439 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 02-1-00581 Attorneys for Plaintiff JP MORGAN CHASE BANK, as Trustee for : COURT OF COMMON PLEAS Equity One, ABS, Inc. Mortgage Pass Through : CUMBERLAND COUNTY Certificate Series 2000-1 Plaintiff VS. ARTHUR HEIBER Defendant No.: 02-2683 Civil WITHDRAWAL OF APPEARANCE TO THE COURT: et al. Kindly withdraw my appearance on behalf of the above Plaintiff, JP Morgan Chase Bank, TO THE COURT: Kindly enter my appearance on behalf of the above Plaintiff, JP Morgan Chase Bank, et al. E& Meth, E quire Attorney ID No. 59439 C) C= r? Q Zj ? Y Pv w -;:x m s , E'S'1 N nn cr. ? THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Eric Meth, Esquire Attorney ID#59439 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP MORGAN CHASE BANK, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificates, Series 2001-1 Plaintiff vs. ARTHUR HEIBER Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 02-2683 Civil Term PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Directed to the Sheriff of Cumberland County; 2. 4. Against the Defendants in the above captioned matter; And index this writ against the Defendants as follows: Arthur Heiber Real Property involved: Amount Due Interest from 09/05/02 to TOTAL (Costs to be added) Dated: September 24, 2002 1712 Chatham Road Camphill, PA 17011 $ 130,472.13 $ 4,965.36 Respectfully?ed, Zte ffic e of Mich . Milste d, LLC ?q ire 459439 ALL that certain property situated in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, being more fully described in a fee simple deed dated 02/25/2000 and recorded 03/01/2000, among the land records of the county and state set forth above, in volume 240 page 163. IMPROVEMENTS THEREON: RESIDENTIAL DWELLING Tax Parcel ID.: 13-23-0547-038 Address: 1712 Chatham Road Camp Hill, PA 17011 P-1 (J t? lq -0 h 74" ? I r o? THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Eric Meth, Esquire Attorney ID#59439 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JPMORGAN CHASE BANK, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificate Series 2001-3 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.:02-2683 Civil Term Arthur Heiber REAL PROPERTY PURSUANT NOTICE OF SHERIFF'S SALE OF Defendant TO PENNSYLVANIA RULE OF :CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 1712 Chatam Road, Camphill, PA 17011 is scheduled to be sold at Sheriffs Sale on March 5, 2003 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of $130,472.13 obtained by JPMorgan Chase Bank, et al. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Eric Meth, Attorney for plaintiff, back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Eric Meth at 856-222-1508. 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 also 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 on following page and 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. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Eric Meth at 856-222-1508. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Eric Meth at 856-222-1508. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property 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. A Schedule of distribution of the money bid for your house will be filed by the Sheriff approximately 30 days after the date of Sheriffs 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. 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 YOU 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. Lawyer Referral Service Cumberland County Bar Association Carlisile, PA 17013 (800) 990-9108 02-1-00574 ALL that certain property situated in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, being more fully described in a fee simple deed dated 02/25/2000 and recorded 03/01/2000, among the land records of the county and state set forth above, in volume 240 page 163. "ROVEMENTS THEREON. RESIDENTIAL DWELLING Tax Parcel ID.: 13-23-0547-038 Address: 1712 Chatham Road Camp Hill, PA 17011 c> C- ?? CJ -7.';: .. ? ...? -_ _y _ G i ? ..?; r, ,,_ r. -i. hJ ? ? ?7 i -'r '? cj .U -t THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Eric Meth, Esquire Attorney ID#59439 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JPMORGAN CHASE BANK, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificates, Series 2001-1 Plaintiff vs. ARTHUR HEIBER Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 02-2683 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JPMorgan Chase Bank, et al., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 1712 Chatham Rd., Camphill, PA 17011: 1. Name and address of Owner(s) or Reputed Owner(s): Arthur Heiber 1712 Chatham Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment: Arthur Heiber 1712 Chatham 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: JPMorgan Chase Bank, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificate Series 2001-1 (Plaintiff herein) 301 Lippincott Drive Marlton, NJ 08053 Child Support Enforcement Agency Domestic Relations 13 N. Hanover St Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificate Series 2001-3 (Plaintiff herein) 301 Lippincott Drive Marlton, NJ 08053 5. Name and address of every other person who has any record lien on the property: None known. 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: Occupant, 1712 Chatham Road Camp Hill, PA 17011 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant, 1712 Chatham Road Camp Hill, PA 17011 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 th se statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relat unsworn falo authorities. RIC ME T , ESQUIRE #59439 Sworn and Subscribed to before me this oday of QC-1Dbff 2002. LIS L. BECK NOTARY PUBLIC OF 11E1t AM CMnftm Expla 1/9/2001 C7 Q L_ h? t'h T?i ilY ,. J -1 r, ,r:1 .i ? ' _ ?'.. ,, a J7 "? f < WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2683 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE FOR EQUITY ONE, ABS, INC. MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2001-1 Plaintiff (s) From ARTHUR HEIBER,1712 CHATHAM ROAD, CAMPHILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $130,472.13 L.L. $30 Interest FROM 9/5/02 -$4,965.36 Arty's Comm % Due Prothy $1.00 Arty Paid $111.04 Other Costs Plaintiff Paid Date: OCTOBER 4, 2002 CURTIS R. LONG Prothonot ? ? (Seal) ? /I Di. O Deputy REQUESTING PARTY: Name ERIC METH, EQUIRE Address: THE LAW OFFICE OF MICHAE L J. MILSTEAD, LLC 325 NEW ALBANY ROAD MOORESTOWN, NJ 08057 Attorney for: PLAINTIFF Telephone: 856-222-1508 Supreme Court ID No. 59439 THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Eric Meth, Esquire Attorney ID#59439 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JP MORGAN CHASE BANK, as trustee for Equity One, COURT OF COMMON PLEAS ABS, Inc. Mortgage Pass Through Certificates, Series CUMBERLAND COUNTY 2001-1 Plaintiff vs. : No.: 02-2683 CIVIL TERM ARTHUR HEIBER AFFIDAVIT PURSUANT TO Defendant RULE: 3129.2 COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) I, Eric Meth, Esquire, of full age, being duly sworn according to law, upon my oath, depose and say: 1. I am a member of the The Law Office of Michael J. Milstead, LLC, attorney for the Plaintiff in the above entitled cause of action. 2. On October 4, 2002, a copy of the Notice of Sheriff's Sale of Real Property was served on the defendant, Donald Moses by certified mail, return receipt requested. A copy of the return receipts is attached hereto and made part hereof as Exhibit "A". 3. On or about October 10, 2002 a notice of Sheriff's Sale was sent to all lien holders of record by certified mail, return receipt requested. Copies of the proof of mailings are attached hereto and made a part hereof as Exhibit "B." 4. A Notice of Intention to Foreclose Mortgage and a Notice of Homeowners' Emergency Mortgage Assistance was sent to the defendant by regular and certified mail on December 14, 2001. Sworn and Subscribed to before me this (y, Day of 2003 Notary Public DAWN HOFFMAN NOTARY PUBLIC OF NEW JERSEY Connis w Expires 1!9!2007 J D r ¦ ¦ ¦ O o ? 3 y CD 3 C _ -- (D O, J '= 0 0 w Er 33 r a Er c a a m 5 CD CD M = 2 N N W ?*. `c am 332.3 o - N O m CL o y 3 C' -0 2) CD CID L CD 0 c7 y ° ao a-> O rD go'mo C3 (D o ?' C> P m=` pa 3 <. 3 L - - p C (D - CD ?; M O m C7 O ? co m ? ? ? C CD ° z m m CD 4 m p y `D ca m y °_-' a a Z. n 3 m ?0 ? CD z $ nm x p a a 12) CD ??2 a m t om 3 cc, m .m N et D 3 m ( m a = o m F 3 o o N O - O CD ? 0 w p 0 _ .. .. 3 y c N z \ D N a O N a CD .?. y _. CCU fD c ?D y Cl) ¦ Complete items 1, 2. J 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ?d X-11 I PPOr? LnFc>rCe . J?>rrnc-??c I?ela?cs?5 t Nt leayyver ?trc-? -l e, ?--I '?)l- A. Signature X ?/! , ???1 ? Agent ? Addressee B. Received by (Printed Name) C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. jervice Type F-1 Express Mail Certified Mail t,O.D. ? Registered .- eturn Receipt for Merchandise ? Insured Mail 4: -Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (Transfer from service label) 7001 1940 0000 7,091 104u PS Form 3811, August 2001 Domestic Return Receipt 102595-01 -M-250 SENDER: COMPLETE THIS SECTION ¦ Complete items 1E . j 3. Also complete A. ignat t item 4 if Restricted Delivery is desired. ¦ P X ? Agent rint your name and address on the reverse ' ' Addressee so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, B. Recery by ( Printed Name) f A C. Date of Delivery or on the front if space permits. r U. Y - d --?? -D Z 1. Article Addressed to: D. Is delivery address different from item 1? ? Yes ?a!.,`CLA[-A0? 1 If YES, enter delivery address below : ? No rn p V'" 1 U? I 3 S i i . erv ce Type Certified Mail ? Express Mail ? Registered Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (rransfer from service label) 7001 1940 0 0 0 0 .7 0 91 1033 PS Form 3811, August 2001 Domestic Return Receipt 102595-01 -M-25C .= r) ?`. C.a?+ -i7 ?' ?? t,'. .-? : J . ?' ? ?.ti, r... ? . '1.7 .. C .? - Y. .. .. __ R _ ? ? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I Robert P. Ziegler, Recorder of Deeds in and for said County and State ?o hereby certify that the Sheriff s Deed in which Certificates Series 2001-1 is the grantee the same having been sold to said grante6 on the 5th day of March A.D., 2003, under and by virtue of a writ Execution issued on the 4th day 6f October, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Numbel 2683, at the suit of JP Morgan Chase Bank tr for Equity One ABS Inc MtgLPas through Certificates Spies 2001-1 against Athur Heiber is duly recorded in Sheriff's Deed Book No. 256, Page 632. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office; this day of A.D. 2003 6 Recorder of Deeds JP Morgan Chase Bank, as Trustee In The Court of Common Pleas of For Equity One, ABS, Inc. Mortgage Cumberland County, Pennsylvania Pass Through Certificates Series 2001-1 Writ No. 2002-2683 Civil Term VS Arthur Heiber Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on November 5, 2002 at 2:40 o'clock PM, he served a true copy of thew thin Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Arthur Heiber, by making known unto Arthur Heiber ersonally, at 1712 Chatham Road, Camp Hill, Cumberland County, Pennsylvania, its ontents and at the same time handing to him personally the said true and correct copy o the same. Valerie Weary, Deputy Sheriff, who being duly sworn according law, states that on January 7, 2003 at 7:26 o'clock P.M., she posted a true copy of th within Real Estate Writ, Notice, Poster and Description, in the above entitled action, pon the property of Arthur Heiber located at 1712 Chatham Road, Camp Hill, Per sylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Arthur Heiber by regular mail to his last know address of 1712 Chatham Road, Camp Hill, PA 17011. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 5, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Eric Meth for JP Morgan Chase Bank, as Truste for Equity One ABS, Inc., Mortgage Pass Trough Certificates, Series 2001-1. It bein the highest bid and best price received for the same, JP Morgan Chase Bank, as Truste for Equity One, ABS, Inc. Mortgage Pass Through Certificates, Series 2001-1 of 301 Lippincott Dr., Marlton, NJ 08053, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $582.32, it being costs. Sheriffs Costs: Docketing $30.00 Poundage 11.41 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 22.08 Certified Mail 3.60 Levy 15.00 Surcharge 20.00 Law Journal 139.85 Patriot News 179.17 Share of Bills 25.21 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $582.32 Sworn and subscribed to before me So Answers: This day of 2003, A.D. R. Thomas Kll.ne, Sheriff r thonota 7yy BY Real Estate (Deputy 3D C.{? y b o y ? ?uta. 13 G 07 THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Eric Meth, Esquire Attorney ID#59439 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JYMURUAN CHASE BANK, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificates, Series 2001-1 Plaintiff vs. ARTHUR HEIBER Defendants COURT OF COMMON PLEAS CUMBERL COUNTY NO.: 02-2683 Civil Term AFFIDAVIT] PURSUANT TO RULE 3129.11 IUMMUNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JPMorgan Chase Bank, et al., Plaintiff in the above entitled cause f action, sets forth as of the date the Praecipe for Writ of Execution was filed the following info ation concerning the real property located at 1712 Chatham Rd., Camphill, PA 17011: 1 1. Name and address of Owner(s) or Reputed Owner(s): Arthur Heiber 1712 Chatham Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment: Arthur Heiber 1712 Chatham 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: JPMorgan Chase Bank, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificate Series 2001-1 (Plaintiff herein) 301 Lippincott Drive Marlton, NJ 08053 Child Support Enforcement Agency Domestic Relations 13 N. Hanover St Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificate Series 2001-3 (Plaintiff herein) 301 Lippincott Drive Marlton, NJ 08053 5. Name and address of every other person who has any record lien on the property: None known. 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: Occupant, 1712 Chatham Road Camp Hill, PA 17011 7. Name and address of every person of whom the plaintiff has interest in the property which may be affected by the sale: who has any Occupant, 1712 Chatham Road Camp Hill, PA 17011 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 th se statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relat* unworn fal % authorities. - ? META,-ESQ #59439 Sworn and Subscribed to before me this day of Nabff 2002. U L. BECK NOTARY PUBLIC OF NEW JERSEY - COMMUM EXPh% 1/9/2407 THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC By: Eric Meth, Esquire Attorney ID#59439 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff JPMORGAN CHASE BANK, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificate Series 2001-3 Plaintiff vs. Arthur Heiber Defenda TAKE NOTICE: COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.:02-2683 Civil Term :REAL PROPERTY :PURSUANT Your house (real estate) at 1712 Chatam Road, Camphill, PA 17011 is scheduled to be sold at Sheriffs Sale on March 5, 2003 at 10:00 am in the Commissioner's Haring Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of $130,472.13 obtained by JPMorgan Chase Bank, et al. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S S1LE To prevent this Sheriff s Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Eric Meth, Attorney for Pl?intiff, back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Eric Meth at 856-222-1508. 2. You may be able to stop the Sale by filing a petition asking the cou o strike or open the Judgment, if the Judgment was improperly entered. You may also ask ?Court to postpone the Sale for good cause. 3. You may also 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 chan?e you will have of stopping the Sale. (See Notice on following page and how to obtain an attor?ey). 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Eric Meth at 856-222-1508. 2. You may be able to petition the Court to set aside the Sale if the W price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Eric Meth at 856-222-150. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property 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. A Schedule of distribution of the money bid for your house will be filed by the Sheriff approximately 30 days after the date of Sheriffs 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 (1?0) days after. 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 YOU LAWYER AT ONCE. I' 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. Lawyer Referral Service Cumberland County Bar Association Carlisile, PA 17013 (800) 990-9108 02-1-00574 ALL that certain property situated in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, being more fully described in a fee simple deed dated 02/25/2000 and recorded 03/01/2000, among the land records of the county rd state set forth above, in volume 240 page 163. IMPROVEMENTS THEREON: RESIDENTIAL DWELLING Tax Parcel ID.: 13-23-0547-038 Address: 1712 Chatham Road Camp Hill, PA 17011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2683 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE FOR EQUITY ONE, ABS, INC. MORTGAGE PASS THROUGH CERTIFICATES, SEAS 2001-1 Plaintiff (s) From ARTHUR HEIBER, 1712 CHATHAM ROAD, CAMPHILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE GAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in t e possession of I GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in 11re possession of anyone other than a named garnishee, you are directed to notify him/her that he/she hays been added as a garnishee and is enjoined as above stated. II Amount Due $130,472.13 Interest FROM 9/5/02 - $4,965.36 Atty's Comm % Atty Paid $111.04 Plaintiff Paid Date: OCTOBER 4, 2002 L.L. $.50 (Seal) REQUESTING PARTY: Name ERIC METH, EQUIRE Address: THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC 325 NEW ALBANY ROAD MOORESTOWN, NJ 08057 Attorney for: PLAINTIFF Telephone: 856-222-1508 Supreme Court ID No. 59439 Due Prothy $1.00 Other Cnctc Real Estate Sale # 4 On October 24, 2002 the sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA known and numbered as 1712 Chatham Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 24, 2002 By: aa ?iM I C;R %rd Real E'state Deputy & ? %. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and sa.ys: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of January and the 4th and 11th day(s) of February 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, pllace and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY Sworn to and su cri d before me this 14 ay o?bruary 2003 A.D. S A L E #4 Notarial Se REAL ESTATE SALE No. 4 Terry L. Russell, Notary Public Writ No. 2002-2683 Fmcy, tyOf Harrisburg, Dauphin County CIAITerm Commission Expires June 6,2006 KC)TARY PUBLIC Morgan Chase ank, One, as s Trustee for r Equity Member, Pennsylvania Assodation Of Notaries My commission expires June 6, 2006 ABS, Inc. Mortgage Pass Through Certificates Series 2001-1 CUMBERLAND COUNTY SHERIFFS OFFICE vs CUMBERLAND COUNTY COURTHOUSE Arthur Helber Atty: Eric Meth CARLISLE, PA. 17013 DESCRIPTION ALL that certain property situated in the Township of Lower Allen in the County of Statement of Advertising CGOsts Cumberland and Commonwealth of To THE PATRIOT-NEWS CO., Dr. Pennsylvania, being more fully described in a fee simple deed dated 02/25/2000 and recorded 031 For publishing the notice or publication attached 01/2000, among the land records of the county and star hereto on the above stated dates $ 177.42 and state set forth above, in volume 240 page 163• Probating same Notary Fee(s) $ 1.75 IMPROVEMENTS THEREON: RESIDENTIAL Total DWELLING $ 179.17 Tax Parcel ID: 13-23-0547-038. Address: 1712 Chatham Road, Camp Hill, Pennsylvania 17011.___ _ Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By ........................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 31, FEBRUARY 7, 14, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 4 Writ No. 2002-2683 Civil JP Morgan Chase Bank, as Trustee for Equity One, ABS, Inc. Mortgage Pass Through Certificates Series 2001-2 vs. Arthur Heiber Atty.: Eric Meth ALL that certain property situ- ated in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, being more fully described in a fee simple deed dated 02/25/2000 and recorded 03/01/2000, among the land records of the county and state set forth above, in volume 240 page 163. IMPROVEMENTS THEREON: RESIDENTIAL DWELLING. Tax Parcel ID.: 13-23-0547-038. Address: 1712 Chatham Road, Camp Hill, PA 17011. WORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY, 2003 --r (L{.1?'S E.' WY'7F y t;8 » ._.: .-di 5,200 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2683 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, A'S TRUSTEE FOR EQUITY ONE, ABS, INC. MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2001-1 Plaintiff (s) From ARTHUR HEIBER, 1712 CHATHAM ROAD, CAMPHILL, PA 1701.1 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $130,472.13 L.L. $.50 Interest FROM 9/5/02 -$4,965.36 Atty's Comm % Due Prothy $1.00 Atty Paid $111.04 Other Costs Plaintiff Paid Date: OCTOBER 4, 2002 CURTIS R. LONG ZProthono •y (Seal) Deputy REQUESTING PARTY: Name ERIC METH, EQUIRE Address: THE LAW OFFICE OF MICHAEL J. MILSTEAD, LLC 325 NEW ALBANY ROAD MOORESTOWN, NJ 08057 Attorney for: PLAINTIFF Telephone: 856-222-1508 Supreme Court ID No. 59439