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HomeMy WebLinkAbout06-6764 t T f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO.at- -~'1t.'f c.;o;L <-y-~ v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE NOTICE TO DEFEND YOU HAVE BEEN SUED I N 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 any further notice for any money or relief requested by the Defendant. 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 OUR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania Phone (717)249-3166 f r r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO, v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en persona 0 por abogado y presentar en la Corte por escrito sus defensas 0 sus objeciones alas demandas en su contra. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso 0 notificacion por cualquier dinero reclamado en la demanda 0 por cualquier otra queja 0 compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, 0 PROPRIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI USTED NO TIENE 0 NO CONOCE UN ABOGADO, VAYA 0 LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania Phone (717) 249-3166 y , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. Ct. -{.. 7~l/ (!,:"'cl/€Li v. CIVIL ACTION-LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE AND NOW, TO WIT, this J{t'day of November, 2006 comes the Plaintiff, Acco York Federal Credit Union, by its attorneys, Kagen, MacDonald & France, P.C., and more specifically Edward A. Paskey, Esquire and files the within Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff, Acco York Federal Credit Union, is a Pennsylvania lending corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having an office at 1529 Rodney Road, York, York County, Pennsylvania 17404. 2. Defendant is Jeannie Mohmand, an adult individual, who resides at 4020 Lisburn Road, Mechanicsburg, Pennsylvania 17055. 3. At all relevant times, the Defendant has been the real owner of a tract or parcel of land, with buildings and other improvements thereon, located at 4020 Lisburn Road, Mechanicsburg, Pennsylvania 17055 (the "Premises"). The Premises are more specifically described hereinafter. A copy of the deed is attached hereto as Exhibit "A" and incorporated herein by reference. 4. On or about July 13, 2005, in consideration of a loan of $25,000.00, made by Plaintiff to Defendant, which funds were received by Defendant, the Defendant, as Promisors, executed and delivered to the Plaintiff, as Promisee, a mortgage note dated July 12, 2005, (the "Note"), in the principal amount of $25,000.00 (the "Principal"), and requiring the payment of interest on the Principal at the rate of 9 percent per year (the "Interest"). A true and correct copy of the Note is attached hereto as Exhibit "B" and incorporated herein. 5. The Note obligates the Defendant to pay to Plaintiff the Principal and Interest in equal, consecutive installment payments of $401.69 each (the "Installment Payments"), on the 30th day of each month beginning July 30,2005, until the Principal and Interest are paid in full. 6. The payment to Plaintiff by Defendant of, inter alia, the Installment Payments due under the Note is secured by a purchase money mortgage on the Premises dated July 13, 2005 (the "Mortgage"), executed, conveyed and delivered by Defendant, as Mortgagor, to Plaintiff, as Mortgagee. A true and correct copy of the Mortgage is attached hereto as Exhibit "C" and incorporated herein. 7. The Mortgage was duly recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania on August 9, 2005 in Record Book 1918, Page 0441. 8. The failure of the Defendants, inter alia, to pay when due and payable the Installment Payments and Renegotiated Installment Payments constitutes "default" as defined under the terms of the Mortgage. 9. The Defendant has failed or refused to pay the Installment Payments due and payable on the 30th day of June, 2006, through October 30, 2006 constituting defaults under the terms of the Mortgage. The sum of these amounts is $2,412.55. 10. The Premises subject to the lien of the Mortgage are described as follows: A. Land: See Exhibit "A", the deed dated B. Imorovements: All buildings and improvements erected upon the Premises. Fixtures: All fixtures attached to the Premises. Prooertv Rights: All hereditaments, appurtenances, reversions and reminders, rents, issues and profits therefrom. 11. The terms of the Mortgage provide that upon the occurrence of a default by the Defendant that the Plaintiff may accelerate and demand immediate payment of all sums secured by the Mortgage. 12. The sums presently due and payable to Plaintiff by Defendants and secured by the Mortgage are computed as follows: A. Unpaid principal B. Unpaid interest through October 30, 2006 C. Attorney's commission C. D. TOTAL $22,661.60 $ 538.79 $ 1,500.00 $24,700.39 13. Plaintiff has duly complied with the provisions of the Emergency Mortgage Assistance Act of 1983 ("Act 91 ") in that the prescribed notice of eligibility was sent to the Defendant by United States Mail on October 10,2006. The temporary stay of enforcement of the Mortgage by reason of Act 91 has expired in that the Defendants have failed to file an application for assistance within thirty (30) days of the face-to-face meeting with Plaintiff or the designated Consumer Credit Counseling Agency. 14. Written Notice of Intention to Foreclose, dated October 10, 2006, was sent to the Defendant pursuant to 9403(a) of the Act of January 30, 1974, P.L. 13, No.6, as amended, 41 P.S.9403(a). The appropriate time period has elapsed since the Notice of Intention to Foreclose was served upon the Defendants. The Defendants have, nevertheless, failed to cure the said defaults. True and correct copies of the Notices are attached hereto as Exhibit "0". 15. The Notices were sent via U.S. Mail, Certified Mail, Restricted Delivery, Return Receipt Requested and First Class Mail. The Certified Mail receipts are attached hereto as Exhibit "E" and incorporated herein. 16. The Mortgage has not been assigned. WHEREFORE, Plaintiff demands judgment in the sum of $24,700.39, together with costs and interest from the date hereof, and demands foreclosure and judicial sale of the interests of the Defendants, in the mortgaged Premises. Respectfully Submitted: Edward A. Paskey, Esquire Attorney 10 No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: 11 Jilt} Jo l." '1 I By: l~ JI~l C~i) Penny Gentzler, EO ) Acco York Federal Credit Union f't\ch tM^ 4 NOV-16-20~6 09:21 FROM:CUMBERLAND TO: 18667327243 I'_.~I'" 4 s-a.7 ROBERT P. ZIEGLER ~;:COROER OF DEEDS 1"'''-' -n' ",r 1",!\;_J~:'IO co:'rri"'t_r,\ . ", /}1'< '_~ C THIS DEErf'Ff8 8 RI'l1035 , TAX PARCEL U.J-IJ..(}27o-040 Made the /sf day of.. h.iru: n'Y in lhlfl ye.QT two thousandftve. (2005). BETWEEN NAE H. F ARK and WON J. PARK. hu9band and wife, af Cumberlalld County Pennsylvania, hereinafter nfe'l'Ted to as the GRANTOR AND JEANNiE B. MOHMAND an im;/hJidual pe"son, of Cumberland COImIy Pen1UJ11vania. herei1'lQfter referred to as the GRANTEE WITNESSETH, That in consideration. of THREE lRJNDRED NINETY-NINE THOUSAND NINE HUNDRED DOLURS ($399,900.00), in hand paid. the receipt whereof is hereby acknowledged, the said grantor.'t do hereby grant and conve)' to the said grantee, her heirs and assigns, ALL THA T CERT AlN piece or parcel of land sitJIate in the Township of Lower Allen, Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with survey made July 7, 1966 fly D,P. RajJensberger, Registered SurPeJlOr. asfollows, to wit: BEGINNING at a point in the center line of the Public Road leading from Lisburn to Slate Hill, L.R. 21014, at the Northeast corner aflands now or formerly a/Harry Deckman; thence along said lands now or jrJrmerly of Harry Deckman and Lanth now or late of Mary Herr North Eighty- fou.r (84) degrees fifteen (15) minutes West FiYt Hundred Sixty (560) /eet to an iron pin; thence a[(}ng other lands now or formerly of George N. and Martha M. Lfmur, ofwhic;h the tract of land herein described Waf a pan, North Thirty-e;ght (38) degrees Thirty (30) minutes East Five Hundred rhirl)l-eight (538) feet to a point in the center line of the aforesaid publiC road; lhsnce along the center line of the aforesaid public road South Forty-seven (47) degrees Nineteen (19) minutes East Two Hundred Twenty-eight (228) feet to a point,' thence further by ,Same South Twenty (20) degrees rorty-$even minutes east Two Hundr~d rhirfeen and nine-tenths (213.9) feet to Q ]XJ;nt; thern:e stilf ~;fi" 267 fi\c~231 NOV-16-2006 09:26 FROM:CUMBERLAND . . TO: 18667327243 by the center line af the aforesaid public road South Swen (7) degrees Thirty (30) mi1lUtes West One Hundred Fifteen and SixMtenths (115.6) feet to 1M point and place of BEGINNING. CONTAINING three and oneMhoIf (3 *) acres of land, more or llUs. HA VING thereon erected a two story brick ranch type dwelling known and number~d 4020 Lisbum Road, Mechanicsburg, Pennsylvania. BEING THE PREM.ISES which Eugene E. Costello and JtXln L. Costello In,t,band and wife, b)J Deed dated June 30, 1976 granted and conveyed unto Nae H. Park and Won J. Park, husband and wife, and recorded in Deed Book R 26. Page 9J. in the Office of the Recorder of Deeds in and for Cumberland County, Grgmol's herein, TOG ETHER with all and singular, the tenements, hereditaments and appurte1'ltZ1'lces to the same belonging or in anywise appertaining, and the reversion and rever&ions, remainder and remainders, rents, issues, and profi/$ thereof; AND also all the estale, right, tille, ;ntt!"esl. property, claim and demand whatsof!l1er, both in law and equity, of the &aid parties of the first part, of, in, to or oul oflhe said premises, and every part and parcel thereof TO HA VE AND TO HOLD the SQid premise9, 'with all and singular the appurtenances, unto the said partie.f of the second part their heirs and assigns, to and for the only proper use and behalf oftht parties oflhe second part, theiT heirs and assignsforf!VflT, AND THE said Grantor henby covenan.t and agree that they will WARRANT SPECIALLY the property hueby conJ>eyed.. IN WITNESS WHEREOF, Ihe said party of the first part have hereunto set their haruI and seal, the day and year first written above. L~i Witness: ~~ {SEAL} (}.A Ii ._ t:V ttv- dr f0- WOII J Park - (SEtfL) ------.- Witness; 2 800K 267 PACE2320 NOV-16-20~6 09:26 FROM:CUMBERLAND' . TO: 18667327243 . , Commonwetllth 0/ PennsylWlnia: County olG -.&A {)4' : ; SS On this, the Isf day of "04. 9ft' 2005, before me a Notary Public, the undersigned officer, per.sonally appe~red Nae . PARK, husband find wije, known to me (or satisfactorily p7VJ11sn) to be the person whose l2a",e is subscribed to the within instrument, and acknuw/edged thai they ~uted the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWeAlTH OF PENNSYLVANIA . NclI8tIaI See! Rerr'Mw1 Ml;O;lnllld, NoIaIy P\dc. LfJI'l'IO'jrle Stwo. C...nberIand CoIln1r My Co..\ .,1l8eb I Expi/'l!!l Nov. 17. '1JX1T MemlMr. "'''IItylvllllla .....aclalloll Of NOl:a,," t:.... GiiiJi NO'tdRYPUBUC {SEAL} CommonWet1lth of Pennsy/Vtlnill: COll1lty of ~4b\ 4,L : :$S On this, the I sf day of 6lJ/'a ~ 2005, before me a Notary Public, the undersigned officer. personally appeared WON'J. PA.M ~band and wift, /mown to me (or .,ati9j'actorily pt'owm) to be the plrson wh~e name is subscribed to the within instrument, and acknowledged thot they executed the same for the purpose therein contained IN WITNESS WHEREOF, I hereunto set my hand and officiol seal. ~~ NOTA.RY PU~C {SEiiL} OMMONWEAL. TH ~)F PENNSVLVANIA NolaIlaI SeIll RermIlIt McDonald. ~ ~ I..erna,tIe 9oro. Currt1ertand CoutlCy My Cut........, ElqlIres Nov. 17, 2007 MomtMlr. PttnnBylVBni. As$OC;jllIO" or ~r1n 3 ~oo~ 267 PACE2321 NOV-16-2006 09:26 FROM:CUMBERLAND ._-_..~, . . . CERTIFICATE OF RESIDENCE J. hereby certify that the precise residence of the grantee +1--f1 LlS8Um f.A'J 11~~slW~ J 7JI. {SEAL} ComtnOlltHlJlth of Pmnsy/wJlfia: :ss County of ; TO: 18667327243 herein is OJ' follows: J""r~ RECORDED in the Offlce for Recording of Deeds, etc., in and for said County, in Deed Book ~ Volume _' rage WITNESS my Hand and Official Seal this day of R#cQnJu of Deer/3 -., ~ 5:2 ;0 r,;.: ,.... '"' ~ ;-. ~ IJ' ~;;?, ~,.,,;pibc!l~h,...l~W~;""~ ~ ~ !Ioi!- ~. s: "'" ~ ~ .-. '01 Q .;- =_--o;~~. I ,~~ ~ I , ;.r.: ~ ~ a; ~ ..-! ..., . :k~ ~~ ~ ~~ ~ ~~ ;i ~ ~ ;J;: ~ !'r-: .~ ~ .c.':: ....... r:'!J ....4 (1") ~. '.] 0:-..:; ,_.: ~ :Jj : ~ .~ .. ''U ;:;:r :; r;,,-' e; eOQl ~67 r~eE2322 ....- - 1:\;1I""" - u ~Q Q ::-J~+Ct ~~ c;... ......_ ...-;,..[;1~ ..... ar: .~ .... ~ ~ r~ c.. ...., .t;:} .,::;0 ~ ..... "" ::.. u. be::" c.. <.,' G: ;"", ::.. t., ~" IC3' C;I c'':' a 0 Q 4C" ..., <~ 0 C) ........> p..":'~ -~. c.r Q~ ,*, I ~~ e r"~ ~ .-i ? ..., ,2005. {SEAL} J Cc:-m fy f ~i Tn Cum.1x l~ -. -~ 1:( ~' .. .:u .... :o!- ~ ~ ,-;, rr ~ ~? fill ~-..,. -:0 "'" ..~ ..... o. '::'11.. ~.J ..:. .'of! 1 ~ -- <...', !oJ -:I .",' ,-,; I"J ... ;i :or. 1- ."""\ ~ c;, ~4 ~~ ..... ;y ,:::;"" ~ .~'. ;s ,I; ......'., (',,-1 .,.,";) ,,4. ~'. ...... c't'l -.... ~ coli C3 ..... ";';2 '10 .~ ~ N -.. ~-': j:.J ~ '-~. ~~ ~ "-~ - "R J:. <';~I .,:0:, c..... r " ..~'" ...."L.d , " ~.... l-~~ NOTE Note Number 789495 JULY 12, 2005 [Date] MECHANICSBURG [City] PENNSYLVANIA [State] 10556 4020 LISBURN ROAD (property Address) BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to Pay U.S. $25,000.00-- --------------------------------00100 DOLLARS--------------------- (this amount is called "principal"), plus interest, to the order of the Lender. The Lender is: ACCO YORK FEDERAL CREDIT UNION 1529 RODNEY ROAD YORK PA 17404 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of9.00 % The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6 (B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. I will make my monthly payments on the 30TH day of each month beginning on JULY 30" 2005. I will make these payments every month until I have paid all the principal and interest and any other charges described below that I may owe under this Note. My monthly payments will be applied to interest before principal. If, On JUNE 30, 2012 amounts under this Note, are still owing, I will pay those amounts in full on that date, which is called the "Maturity Date". I will make my monthly payments at 1529 RODNEY ROAD, YORK, PENNSYLVANIA 17404 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments $401.69 BORROWER'S RIGHT TO PREPAY I have the right to make payments of principal at any time before they are due. A payment of principal only is known as a "prepayment". When I have a prepayment, I will tell the Note Holder in writing that I am doing so. I may make a full prepayment or partial prepayments without paying any prepayment charge. The Note Holder will use all of my prepayments to reduce the amount of principal that I owe under this Note. If! make a partial prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is fmally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (i) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (ii) any sums already collected from me which exceeded permitted will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of OOcalender days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 00% of my overdue payment of principal 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 monthly payment on the date it is due, I will be in default. MULTISTATE FIXED RATE NOTE - Single Family - Fannie MaelFreddie Mae Uniform Instrument Form 2200 Page I of2 (C) Notice of Default If! am in default, the Note Holder may send me a written notice telling me that If! do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is delivered or mailed to me. (0) No Waiver By Note Holder Even if, at a time when I am 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! am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICE Unless applicable law required 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 Property Address above or at a different address if! 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 my mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if! am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE Ifmore than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in the Note. The Note Holder may enforce its rights under this Note against each persoh individually or against all of us together. This means that anyone 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 Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of dishonor" means the right to require the Note Holder to give notice to other persons 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 Trust or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if! do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person), without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. Ak~, ~eal) /SSN:. ~~~s-.s-cP-3~ - orrower SSN: (Seal) -Borrower (Seal) (Seal) SSN: t, ,~ '6q(p~ , . ,e~ , . '-=- '\, '{O()O l.~ s.bv /,-"" Ro\.., qQ.e~;I(c~b ~ C\ --space above th~e for recording date PG:;EP:'T- F. ZIEGLER :: 0::: C: i\ D E;:t 0 F D E [ !J S ,.,1:' , ('- -~ ~,~;:!) ~~ :'-:~ ~<.~~----- l005 RUG 9 Arl 9 ~8 MORTGAGE THIS MORTGAGE ("Security Instrument") is given on JULY 12, 2005. The mortgagor is JEANNIE B MOHMAND (Borrowers"). This Security Instrument is given to: ACCO YORK FEDERAL CREDIT UNION (LENDER) which is organized and existing under the laws of the State of Pennsylvania, and whose address is 1529 RODNEY ROAD YORK, PENNSYLVANIA 17404 (LENDER) Borrower owes Lender the principal sum of TWENTY FIVE THOUSAND ---------- and --00/100 DOLLARS ($25,000.00) This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on MAY 30, 2012, last payment date. This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to L~nder the following described property located in ,pm Count~ Pennsylvania: Cumberland l:;tf cu~we8BN~ WOWN AS:~ 4020 LISBURN ROAD, MECHANICSBURG PENNSYLVANIA, 17055 which has the address of 4020 L1S8URN ROAD, MECH,A.NICSBURG (street, city) PENNSYLVANIA . ("Property Address"); 17055 (ZIP CODE) PENNSYLVANIA-Single'Family-FNMAlFHLMC UNIFORM INSTRUMENT FORM 3039 91Amended 5/91/96 File No: 95000 (Page 1 of 6) BK , 9 , 8 PG Oq Itl 1 , , , I \ , TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All . of the foregoing is referred to in this Security Instrument as the "Property". BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumberances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Note. 2. Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower shall pay to Lender on the Day monthly payments are due under the Note, until the Note is paid in full, a sum ("Funds") for: (a) yearly taxes and assessments which may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments or ground rents on the property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if any; (e) yearly mortgage insurance premiums, if any; and (f) any sums payable by Borrower to Lender, in accordance with the provisions of paragraph 8, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items". Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of 1974 as amended from time to time, 12 U.S.C. Section 2601 et seq. ("RESP A"), unless another law that applied to the Funds sets a lesser amount. If so, Lender may, at any time, collect and hold Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. However, Lender may require borrower to pay a one-time charge for an independent real estate tax reporting service used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement is made or applicable law requires interest to be paid, lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the funds, showing credits and debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument. If the Funds held by lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower for the excess Funds in accordance with the requirements of applicable law. if the amount of the Funds held by lender at any time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the deficiency. Borrower shall may up the deficiency in no more than twelve monthly payments, at Lender's sold discretion. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sums secured by this Security Instrument. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest due; fourth, to principal due; and last, to any late charges due under the Note. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fmes and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay them on time directly to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. If borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice 5. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage" any other hazards, including floods or flooding, for which 2 nu I n I n nf' n, I " II: ; , . ' , Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. The insurance canier providing the insurance shall be chosen by Borrower subject to Lender's approval which shall not be unreasonable withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof ofloss ifnot made promptly to Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not then due. The 30-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount ofthe payments. If under paragraph 21 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition. 6. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of the Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may cure such a default and reinstate, as procided in paragraph 18, by causing the action or proceeding to be dismissed with a ruling that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Lender's Rights in the Property. If Borrower fails to perform the covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and pay for whatever is necessary. to protect the value of the Property and Lender's rights in the Property. Lender's actions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take action under this paragraph 7, Lender does not have to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these fu"llOunts shall bear interest from the date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 8. Mortgage Insurance. If lender required mortgage insurance as a condition of making the loan secured by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect. If, for any reason, the mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. If substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Lender each month a sum equal to one-twelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in effect. Lender will accept, use and retain these payments as a loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be required, at the option of Lender, if mortgage insurance coverage (in the amount and for the period that Lender requires) provided by an insurer approved by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain MORTgage insurance in Effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with AN Agreement between Borrower and Lender or applicable law. 9. Inspection. Lender or its agent may make reasonable entries upon the inspections of the Property. Lender shall 3 RK I 9 I 8 PG 044 3 '. I i , , , . , , " \--::- GIVE Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection, 10. Condemnation. The proceeds of any award or claim for damages, direct or cosequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender, In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the taking, unless borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, of if, after notice by Lender to Borrower that the dondemnor offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of monthly payments referred to in paragraphs I and 2 or change the amount of such payments. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amorization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Loan Charges. If the loan secured by this Security Instrument is subject to a law sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note. 14. Notices. Any notices to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other addesses' Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 15. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument and the Note are declared to be severable. 16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 17. Transfer ofthe Property or a Beneficial Interest in Borrower. Ifall or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Page 4 of6 4 RK 19 I 8 PG 0 4 4 4 , I I \_ ..& _ tr I) Instru.ment. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by tl).is Security Instrument without further notice or demand on Borrower. 18. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower Shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such other period as applicable alw may specify for reinstatement) before sale of Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action as Lender may reasonably require to assure that the lien of this Security Instrument, Lender's rights in the Property and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under paragraph 17. 19. Sale of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as the "Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. There also may be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change in accordance with paragraph 14 above and applicable law. The notice will state the name and address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other information required by applicable law. 20. Hazardous Substances. Borrower shalL not use or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 20, "Hazardous Substances" are those substances defmed as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 17 unless applicable law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not secured as specified, Lender, at its option, may require immediate payment in full of all sums secured by third Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 21, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by applicable law. 22. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 23. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument. 25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 26. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action mortgage foreclosure shall be the rate payable from time to time under the Not 5 BK,,1,9ISPG 04 4 5 I , I , . '-=- t , ) )" . . I , 27. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement the covenants, and agreements ofthis Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es) Adjustable Rate Rider Condominium Rider 1-4 Family Rider Graduated Payment Rider Planned Unit Development Rider Biweekly Payment Rider Balloon Rider Rate Improvement Rider Second Home Rider V,A. Rider Other(s) [specify] BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses: ~~~ Witne s ~~~SeW) orrower (Seal) Witness Borrower (Seal) Witness Borrower Certificate of Residence I, Penny A. Flohr , do hereby certify that the correct address of the within-named Lender is Acco York Federal Credit Union 1529 Rodney Road, York, Pennsylvania 17404 Witness my hand this 12TH DAY OF JULY, 2005 ~I}\~, ~ Agent 0 ortgage I COMMONWEALTH OF PENNSYLVANIA, YORK County ss: ON JULY 12, 2005 before me, the undersigned officer, Personally appeared JEANNIE B MOHMAND known to me (or satisfactorily proven) to be the person whose names are subscribed to the within instrument and acknowledged that they executed the same for the purpose herein contained. Crn MlNESES WHEREOF, I hereunto set my hand and official sea~l' _ ~ --/!~'/ -7 My ommlSSlon xprres: ~ ~~~ N AND TITLE OF OF CER 0 '--' COMMONWEALTH OF PENNSYLVANIA YJday Notarial Seal Arlene L Sweitzer. Notary PubflC West.MancheslerTwp., Ym County My CommlssIan EXpiI9S Oct. 18. 2008 Member, Pennsylvania Association Of Notaries 6 l. " .. . J I ~ -. ,. , (---- \ '............... ALL THA.T CERTAlN piece or pa1c-I of I(Jltd I;fuatlr in t~ Town.ship of Lower Allen, Cllrnb.t/cmd County, Commonw.lth 0/ PennO'IWllIiQ, b""nd_d and clescri~d tn Qccordtmce with 8fIffly made Jvly 7, J 966 by D.P. RaJ/8ltlhe"er. kgutererJ Sumyor, Qljollows, 10 Vi;t: IJEGlNN1NG at Q point fn th, center line of the Pl/bUe RotJd leodlng from Lisblll7l Ie Slote Hill, L.R. 2JOU. at 1ht1 Northeast corno of/ands JlOW or formerly oj Hat", l),cknrml: thence along said lands now or formerly 01 HQN')J Decim"" t>>tJ lttnds now or late of Ma1'Y He,.,. North Eighty- f01l1' (84) degrees jfft"", (15) mimttu Welt FiVl HIlntlnJ Sixty ('60) Ie" to an i1'OII pin; thlll~ along atlltr lands now 0,. fomwr>ly ofGlt1r" N. and Martha M. Leniu. of which th'tract r>flawti huein dut7ibe4wQI a part. North ThiJ1y~;ght (J8) degrees Thirty (30) 1ninut" EMt Fi~ Hundred Thtrty.eighr (5J8) fiBt to 4 poi"" in 1"- e,m., lint of th~ afo"'Said publlt: TOad; ,he1rt:1l Qlcmg th.' center line of tb, qfor""id pub/l(1 P'OtJd South FOrl)'-sevBn (47) degref.$ Nineteen (J 9) ",iltUht,s us, 1Wo Hundred TwenlJ-'ight (2.28) feR" Q poi"", tire,," furt~r by stlme South TWfnty (10) de8'eu Fort)..uven .",f11Uru Em/Two Hwtdred TltirtNII arrJ ";ne.,,,,,1ts (2Jj.g) feet to Q point; IM1JC(! still .:i 'C'l),; 267 rAc~2319 r 'W... '._.'_'__. ! (_:ertj fy this to be recorded in CUlll berland County P A . -- f\" - r' y,.z,'!?"...lr_ ,"":~ -~.... ....t'i"...r.:....;.....",.;t:.~~.)' /;,r ,.....-.,;.-<-,... ~.:'-'~" V .,' A ',<\ . R ' !..,~t."~.\ Wl1lte ose \<73 Recorder ofDeed~:!~~:~tt ~:~~te~tr~~i York, PA 174031. ,. , 8K.19.18PGOq'~ i SHERIFF'S RETURN - REGULAR CASE NO: 2006-06764 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND VS ACCO YORK FEDERAL CREDIT UNION MOHMAND JEANNIE GERALD WORTHINGTON , Sheriff or Deputy Sheriff f Cumberland County,Pennsylvania, who being duly sworn acco ing to law, says, the within COMPLAINT - MORT FORE was served upo I MOHMAND JEANNIE the DEFENDANT , at 2018:00 HOURS, on the 5th day of Dec er , 2006 at 4020 LISBURN ROAD MECHANICSBURG, PA 17055 by handing to JEANNIE MOHMAND a true and attested copy of COMPLAINT - MORT FORE tog her with and at the same time directing Her attention to the conte s thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: iJ'ct/61 Cf- 18.00 12.32 .00 10.00 .00 'II" 40.32 '~/,. ~ c....<, . .'__ . ..:'I'fc....:,.~';~:::...,.-;.. ~ ~ '.. - .'" R. Thomas Kline 12/06/2006 KAGEN MACDONALD FRANCE Sworn and Subscibed to By: before me this day of A.D. t, . I . \ ' I II _. . ~ t L- KAGEN, MACDoNALD & FRANCE, p.e. LAW OFFICES 2675 EASTERN BOULEVARD YORK, PENNSYLVANIA 17402 ANDREW F. KAGEN GEORGE E. MacDONALD DOUGLAS P. FRANCE EDWARDA. PASKEY MORTON H. KAGEN (1941 -1998) TELEPHONE (717) 757-4565 FAX (717) 755-4708 October 10, 2006 CERTIFIED MAIL RETURN RECEIPT REQUESTED Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, Pa 17055 Dear Ms. Mohmand: NOTICE OF INTENTION TO FORECLOSE MORTGAGE This office has been informed that the Mortgage held by Acee York Federal Credit Union (hereinafter "we, us or ours") on your property located at 4020 Lisburn Road, Mechanicsburg, PA 17055 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $400.91, for the months of June, July, August, September, and October totaling $ 2,004.55. Late charges have also accrued to this date in the amount of $408.00. The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter, is $2,412.55. YOU MAY CURE THIS DEFAULT WITHIN THIRTY (30) DAYS OF THE DATE OF THIS LETTER BY PAYING TO THE MORTGAGEE THE ABOVE AMOUNT OF $, PLUS ANY ADDITIONAL MONTHLY PAYMENTS AND LATE CHARGES WHICH MAY FALL DUE DURING THIS PERIOD. Such payments must be made either by cash, cashier's check, certified check or money order, and made at the office of Kagen, MacDonald & France, P.C., 2675 Eastern Boulevard, York, PA 17402. If you do not cure this default within thirty (30) days, our client intends to exercise his/her/their right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may .......' I .. lA' 6- " . I , October 10, 2006 Page 2 lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of our default is not made within thirty (30) days, we have been instructed by our client to start a lawsuit to foreclose your mortgaged Droperty, If the mortgage is foreclosed. your mortgaged proDerty will be sold by the Sheriff to Day off the mortgage debt. If you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees, Our client may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and Drevent the sale at anv time UD to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unDaid monthly Dayments Dlus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other reauirements under the mortgage), It is estimated that the earliest date for a Sheriffs sale could be held would be approximately May, 2007. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 757-4565. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have the additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY, TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT. OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT, (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT. PROVIDED THAT ALL OUTSTANDING PAYMENTS. CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE. AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO HAVE DETERMINED UNDER WHAT CIRCUMSTANCES THIS RIGHT MAY EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF, ( . I . I .. I . . . . . October 10, 2006 Page 3 If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, KAGEN,MACDONALD &!fJF~NCE' ~::.^ \l I \;: ~ ;uJ~ .', , /G-.J Edward A. Paskey '. EAP:jif 'f._" . . . ., , .. SENDER: COMPLETE THIS SECTION . CoIT\~e Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. . PrInt your name and address on the reverse .80 that we can retum the card to you. . Attach this card to the back of the mailplece, or on the front If space permits. 1. ArtIcle Addressed to: J&1nV\ie V\1oh ~ncL t-/O ~O L;.sbi.l.rV\ (<OCA- tL vy\eLh an,c.s6/Ar3i-PA I 7055 2. ArtIcle Number (Tnmsfer from service label) PS Form 3811, February 2004 - __ I; . cm,7PI El E T HI~ Sf OTlO'V ,)^i DEL IVE RY A. X 3. S8rvIce 1YPe plCertlfled Mall 0 Express Mall o Registered 0 Return ReceIpt for Merchandise o Insured Mall 0 C.O.D. 4. Restrtcted Delivery? (Extra Fee) 0 Yes 7004 1350 0003 4662 0386 102595-02-M-1540 Domestic Return ReceIpt . - -. . (") 1'"...') ,-"" , 0 ^=J () fC}.. ",1 ,..,r. .--j t ~ , , -r tI) -:- !=;:-;=g r,-,) V') --J ~ '" ~ :'J ...... ~ (:) () (.) , on .' oj ~ '0 V ~_.'" .-1 -~,~ :::1 ~ (..) .< ~ ~ ~ -f-. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. 06-6764 CIVIL TERM v, CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT TO: Jeannie Mohmand DATE OF NOTICE: January 8, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (1 0) 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: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 KAGEN, MACDONALD & FRANCE, P.C. ClL~~. \0 Edward A. Paskey, Esquir Attorney 10 No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 t' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. 06-6764-CIVIL TERM v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE AVISO IMPORTANTE A. Jeannie Mohmand FECHA DEL A VISO: January 8, 2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE UN FALLO EN CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDED Y OTROS DERECHOS IMPORT ANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IMMEDIATEMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR A YUDA LEGAL. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 r. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. 06-6764 CIVIL TERM v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE AND NOW, to wit, this 8th day of January, 2007, I, Edward A. Paskey, Esquire, do hereby affirm that I have, on January 8, 2007, served a copy of the Notice of Intention to Enter Default Judgment, a copy of which is attached hereto, by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 KAGEN, MACDONALD & FRANCE, P.C. ~~V~_ Edward A. Paskey, Esquir~ Attorney 10 No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 "'I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO, 06-6764 CIVIL TERM v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT TO: Jeannie Mohmand DATE OF NOTICE: January 8, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (1 0) 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: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bendford Street. Carlisle, Pennsylvania Telephone: (717) 249-3166 KAGEN, MACDONALD & FRANCE, P .C. &,~^ ~ Edward A. Paskey, Esquire -- Attorney 10 No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. 06-6764-CIVIL TERM v. CIVil ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE A VISO IMPORT ANTE A. Jeannie Mohmand FECHA DEL A VISO: January 8,2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) D/AS DE LA FECHA DE ESTE AV/SO, SE PUEDE UN FALLO EN CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDED Y OTROS DERECHOS I MPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IMMED/ATEMENTE A SU ABOGADO. SI USTED NO T/ENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OF/CINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR A YUDA LEGAL. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 r j _. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. 06-6764 CIVIL TERM v, CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE AND NOW, to wit, this 8th day of January, 2007, I, Edward A. Paskey, Esquire, do hereby affirm that I have, on January 8,2007, served a copy of the Notice of Intention to Enter Default Judgment, a copy of which is attached hereto, by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 KAGEN, MACDONALD & FRANCE, P.C. ~q . A ~~h Edward A. Paskey, Esquir~ Attorney 10 No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 (") r; "" -':' tT~ r,-, c, Z.:':~1 '"-:,.:r r'-- to>~ -/ ~!~ ~ ~ c:":) = -..$ <- > :z::: , U) -0 3: W o W o -n -f :r: m:!.1 ;ghi 06 ::;:J,. ".. .1 f":) --~ ~70 om -'4 ~ -< , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. 06-6764 CIVIL TERM v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE TO THE PROTHONOTARY: ENTER JUDGMENT in the above case for failure to file an Answer to the Plaintiff's Complaint against Jeannie Mohmand, in favor of Acco York Federal Credit Union in the sum of $24,700.39 with interest plus costs of suit ($538.79 for interests and $7,500.00 counsel fees), and demands foreclosure and judicial sale of the interests of Jeannie Mohmand in the mortgaged premises. Total: $24,700.39 I hereby certify that the attached Notice is a true and correct copy of the original Notice of Intention to Enter Default Judgment that was mailed to the Defendant on the 9th day of January, 2007, pursuant to Pa.R.C.P. 237.1. &9~ Attorney for Plaintiff Edward A. Paskey, Esquire ;-.s b / , 206 7 Judgment entered by the Prothonotary this day according to the tenor of the above statement. _aA~ Pro!f'1onotary OFFICE OF THE PROTHONOTARY Of Cumberland County Curtis Long Prothonotary Telephone (717) 240-6195 Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Date: February _ 2007 No : 06-6764 To: Jeannie Mohmand RE: Acco York Federal Credit Union, Plaintiff VS: Jeannie Mohmand, Defendant No~ g}ven that judgment in the above captioned matter has been entered against you on ~". 11:2 OCl7 . Curtis Long PROTHONOTARY OF CUMBERLAND COUNTY BY fu~] If you have any questions concerning the above case, please contact: Edward A. Paskey. Esquire Attorney or Filing Party 2675 Eastern Boulevard Address York. PA 17402 Telephone # 717-757-4565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO. 06.6764 CIVIL TERM v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE ~ AND NOW, to wit, this j)day of January, 2007, I, Edward A. Paskey, Esquire, do hereby affirm that I have, served a copy of the Judgment, a copy of which is attached hereto, by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 KAGEN, MACDONALD & FRANCE, P.C. WQ..... Edward A. Paskey, Esquire Attorney 10 No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO, 06.6764 CIVIL TERM v. CIVIL ACTION/LAW JEANNIE MOHMAND Defendant, MORTGAGE FORECLOSURE (') ~ 0 c ~ " ~ \J co L. ::;:I ~2 'ji 5; ~ fIJ. ~5: t :DE? ~t, ~ ~ft. ~ 1-' :y;; 1) "'1 IMPORTANT NOTICE ~~,: :; ~~~ ~ ~ ~ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIl9'EN' APPEARANCE PERSONALLY OR BY A TIORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (1 0) 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: NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT TO: Jeannie Mohmand DATE OF NOTICE: January 8, 2007 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 KAGEN, MACDONALD & FRANCE, P.C. ~~~. ?~ Edward A. Paskey, EsqUire,:". Attorney 10 No. 80304 -'-J 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO, 06-6764-CIVIL TERM v, CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE AVISO IMPORTANTE A. Jeannie Mohmand FECHA DEL A VISO: January 8, 2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE UN FALLO EN CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDED Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IMMEDIATEMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR A YUDA LEGAL. Cumberland County Bar Association 32 South Bendford Street, Carlisle, Pennsylvania Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACCO YORK FEDERAL CREDIT UNION Plaintiff, NO, 06-6764 CIVIL TERM v, CIVIL ACTION/LAW JEANNIE MOHMAND Defendant. MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE AND NOW, to wit, this 8th day of January, 2007, I, Edward A. Paskey, Esquire, do hereby affirm that I have, on January 8, 2007, served a copy of the Notice of Intention to Enter Default Judgment, a copy of which is attached hereto, by depositing same in the United States Mail, First Class mail, postage prepaid, addressed to the as follows: Jeannie Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 KAGEN, MACDONALD & FRANCE, P.C. ~AV~_ Edward A. Paskey, Esquir~ Attorney ID No. 80304 2675 Eastern Blvd. York, PA 17402-2905 Phone: (717) 757-4565 ~. · Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is desired. · Print your name. and address 0Il:t~"~ ,~verse so that we can return the card to.you; . · Attach this card to the back of the mal/piece, or on the front if space permits. 1. Article Addressed to: J~n(\l'e Mo hft1Antt ~D ~ LLSbLVf\ (<o~d.- t'Y\ec-h~f\ \ CoS blAr-j .,fA IloSS- 3. ETYP6 CertItIed MaD 0 . Aeglsterecl D Return D Insul8dMalI D C.O.D. 4. AestrIcted Delivery? (Extra Fee) DYes 2. ArtlcIe Number (Transfer from service label) PS Fonn 3811, February 2004 7004 1350 0003 4662 1314 Domestic Return Receipt 102595-02-M-1540 i c ?C) (J -c.a.. \ ...() ~ ~ . D cr --- .......... () (-'j 1"-.1 (') t;".~ C-~ 0 \:) f!- L:...:;J ""'- -.,.~J "Tl (;] ..l: " -rJ ::::! ~ ... Fhp ~ c;;; ~ I :~?tJJ t.f-..........: - {'~ (~,i ~' ~ -0 +"r" '''1 ; -~''':.'' ;. ;;-~. --1": ::~~ (~:'5 (.,) ..:fn r---. :::.) J:- _....i ~. . ~D c.." -<