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Home My WebLink About07-0638GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. DELORES J. TAYLOR Mortgagor and Real Owner 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant Term No. CIVIL ACTION: MORTGAGE IECL LlME 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 the 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 claim in the Complaint of 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. 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES 07- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO,I-STA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretentionagoldbecklaw com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of EMC-1389. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB, 909 Hidden Ridge Drive, Suite 200 Irving, TX 75038. 2. The names and addresses of the Defendant is DELORES J. TAYLOR, 427 York Street a/k/a 427 South York Street, Mechanicsburg, PA 17055, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On December 20, 2000 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to ALLIANCE FUNDING, A DIVISION OF SUPERIOR BANK FSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1670, Page 735. The mortgage has been assigned to: LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for February 26, 2006 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$48,289.14 Interest from 01/26/2006 through 01/31/2007 at 7.9900% .......................$3,921.47 Per Diem interest rate at $10.57 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,414.46 Late Charges from 02/26/2006 to 01/31/2007 .............................................$340.44 Monthly late charge amount at $28.37 Costs of suit and Title Search ......................................................................$900.00 Escrow ....................................................................................................... $4,236.42 Fees ..............................................................................................................$439.49 Recoverable Balance ....................................................................................$196.59 $60,738.01 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at ' Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "i_personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $60,738.01, together with interest at the rate of $10.57, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By:-,qolftr4 C, . ? .? XOLDBECK McCAFFERTY & MCKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I Rashal Peterson , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date E'L r: IaSalle Bank ational Association ( Assignee ), formerly known as LaSalle National Bank, in its capacity as indenture trustee under that certain Sale and Servicing Agreement dated December 1, 2000 among AFC Trust Series 2000-4, as Issuer, Superior Bank F by EMC Mortgage Corporation as Attorney in Fact Rashal Peterson Assistant Secretary #0007601784 - DELORES J. TAYLOR ExhibitA EXHIBIT A Commitment No. RT011727 BEING ALL THAT CERTAIN LOT OF GROUND SITUATE ON THE EAST SIDE OF SOUTH YORK STREET, IN THE FIFTH WARD OF THE BOROUGH OF MECHANICSBURG, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: ON THE NORTH BY LOT NOW OF FORMERLY OF EZRA T. HEISEY; ON THE EAST BY TWENTY (20) FEET WIDE ALLEY; ON THE SOUTH BY LOT NOW OR FORMERLY OF ELWOOD W. NEWHART, BEING THE REMAINING PORTION OF A LARGER LOT OF GROUND OWNED BY SAID ELWOOD W. NEWHART, A PORTION OF WHICH IS HEREIN DESCRIBED; AND ON THE WEST BY SOUTH YORK STREET. HAVING A FRONTAGE OF THIRTY (30) FEET ON SOUTH YORK STREET, AND EXTENDING IN DEPTH, AN EQUAL WIDTH, ONE HUNDRED AND SIXTY-ONE (161) FEET TO SAID PUBLIC ALLEY, AND HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING HOUSE (BEING THE NORTHERN ONE-HALF OF A DOUBLE HOUSE), KNOWN AND NUMBERED AS NO. 427 SOUTH YORK STREET, MECHANICSBURG, PENNSYLVANIA. BEING THE SAME LOT OR PARCEL OF GROUND WHICH BY DEED DATED FEBRUARY 19, 1959 AND RECORDED AMONG THE LAND RECORDS OF CUMBERLAND COUNTY IN BOOK 418 PAGE 66 WAS GRANTED AND CONVEYED BY CHARLES M. SHANK AND FRANCES S. SHANK, HIS WIFE UNTO NATHAN TAYLOR AND DOLORES J. TAYLOR, HIS WIFE. THE SAID NATHAN TAYLOR DEPARTED THIS LIFE ON AUGUST 24, 1983, THEREBY VESTING TITLE UNTO DOLORES J. TAYLOR, SURVIVING SPOUSE. E..x.hibit (B EM Mortgage Corporation December 05, 2006 *0003530514* Delores J. Taylor 427 York St Mechanicsburg, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou when you meet with the counselor a enc . The name address and hone number of Consumer Credit Counseling Agencies serving our coun are listed at the end of this Notice. If ou have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1 800 342 2397 (persons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente Ilamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa Ilamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) : PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT SERVICER Delores J. Taylor 427 York St Mechanicsbu, PA 17055 0007601784 EMC Mortgage Corporation 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 provision of the Homeowners' 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, 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. s Page two 0007601784 TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of the 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 designated consumer counseling agencies listed at the end of this Notice. This meeting must occur within the next thirty (30) days. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counseling agencies for the county in which your nronerty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). 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 Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed 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 IMMEDIATELY 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 you application. During that additional 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 Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 427 York St Mechanicsbu, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 02/26/2006: (b) Late charge(s) : $114141 $5,.85 .85 (c) Other charge(s): NSF & Advances (d) Less: Credit Balance $651.08 $.00 (e) Total amount required as of 12/04/2006: $6,751.82 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $6,751.82, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to EMC Mortgage Corporation at PO BOX 660530, DALLAS, TX 75266-0530. Page three 0007601784 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right 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 amount of default is not made within THIRTY (30) days of the letter date, EMC Mortgage Corporation also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will 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 actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to Ray ttomeys' 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 foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' 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 sheriffs sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of EMC Mortgage Corporation Lender: Address: Mac Arthur Ridge II, 909 Hidden Ridge Drive, Suite 200, Irving, Texas 75038 Telephone 1-888-609-2379 Number: EFFECT OF SHERIFF'S SALE - You should realize that a sheriffs sale would end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriff s sale, a lawsuit to remove you and your fumiture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You 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 attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT • To sell the property to obtain money to pay off the mortgage debt, or borrower money from another lending institution to pay off this debt. • To have this default cured by any third party acting on your behalf. • To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a calendar year). • To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents. • To assert any other defense you believe you may have to such action by the lender. • To seek protection under the federal bankruptcy law. ti Page four 0007601784 EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address above within the thirty day period that the debt, or any portion thereof, is disputed, we will: a) Provide to you verification of the debt or a copy of any judgment entered against you. b) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, EMC Mortgage Corporation Mac Arthur Ridge II, 909 Hidden Ridge Drive, Suite 200, Irving, Texas 75038 MAILING ADDRESS: P.O. Box 141358, Irving, Texas 75014-1358 v VT C W OW GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-638 Civil Term PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff rv O - 72 3? y7 y '? r r 0 In the Court of Common Pleas of Cumberland County LASALLE BANK NATIONAL ASSOCIATION, F KNOWN AS LASALLE NATIONAL BANK, IN T] CAP,W.ITY AS INDENTURE TRUSTEE UNDER ,&:ERTAIN SALE AND SERVICING AGREEMEN DECEMBER 1, 2000 AMONG AFC TRUST SERI] AS ISSUER, SUPERIOR BANK FSB idge Drive Suite 200 Irving, TX 75038 Plaintif vs. DELORES J. TAYLOR (Mortgagor(s) and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defend PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DELORES J. TAYLOR by default for want of an Answer. Assess damages as follows: $61,615.87 Debt Interest from 04/17/07 to Date of Sale Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPEC WD AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN M THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delive ed to a party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and a least en days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. Gol b c r. Attorney for Pl tiff I.D. #16132 AND NOW t , .0200 2 , `.htSgment is entered in favor of LASALLE BANK NA ALASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB and against DELORES J. TAYLOR by default for want of an Answer and damages assessed in the sum of $61,615.87 as per the above certification. _ A Pro#ionotary ??' ' O 4b Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff vs. DELORES J. TAYLOR (Mortgagors and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) No. 07-638 Civil Term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long By: If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 EMC-1389 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. V DATE OF THIS NOTICE: April 4, 2007 TO: DELORES J. TAYLOR 427 York Street aWa 427 South York Street Mechanicsburg, PA 17055 LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. DELORES J. TAYLOR (Mortgagor(s) and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) TO: DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Tenn No. 07-638 Civil Term 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 (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 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. DELORES J. TAYLOR (Mortgagor(s) and Record owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS ACTION OF MORTGAGE FORECLOSURE No. 07-638 Civil Term ORDER FOR JUDGMENT . Please enter Judgment in favor of LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB, and aga' t ELORES J. TAYLOR for failure to file an Answer in the above action within (20) days (or sixty (60) day if de dant is the United States of of Cumberland County CIVIL ACTION LAW Joseph A. G Attorney for I hereby certify that the above names are correct and that the prec se r Bence address of the judgment creditor is LASALLE BANK NATIONAL ASSOCIATION, FORMERLY-KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 and that the name(s) and last known address(es) of the Defendant(s) is/are DELORES J. TAYLOR, 4flork Street a/k/a 427 South York Street Mechanicsburg, PA 17055; GOLDBECK MI BY: Joseph A. G Attorney for Plai Jr. & McKEEVER TO THE PROTHONOTARY: ASSESSMENT OF DAMAGES Kindly assess the damages in this case to be as follows: -- Principal-Balance- Interest from 01/26/2006 through $4,714.22 04/16/2007 Reasonable Attorney's Fee $2,414.46 Late Charges $425.55 Costs of Suit and Title Search $900.00 Escrow $4,236.42 Fees $439.49 Recoverable Balance $196.59 $61,615.87 GOLDBECK] BY: Joseph A. Jr. & McKEEVER AND NOW, this I ,day of ?XL -? , 2007 damages are assessed as above. Pro Kathy VERIFICATION OF NON-MILITARY SERVICE The iinc3ers_ ned, as the r _presentati ye for the P1 ainti ff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DELORES J. TAYLOR, is about unknown years of age, that Defendant's last known residence is 427 York Street a/k/a 427 South York Street, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the nr.-?:-i o4 __o --F +- 1,- C.-.1 Ai -r- 1 -,.. 4 C-4 1 ---1 f \`-, S _a T - ?: - - _Lc Congress of 1940 and its Amendments. Date: 49- C ?. 9 Zoo Zo PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbe, k, Jr. Attomey I.D.#16132 Suite 50001 Mellon Independence Center 701 Market Street Fbia,-PA--191(? - 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff vs. DELORES J. TAYLOR Mortgagor(s) and Record Owner(s) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-638 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: $61,615.87 Interest from 04/17/07 to Date of Sale at 7.9900% (Costs to be added) GOLDBECK McCAF RTY McKEEVER BY: Joseph A. Goldbe k' Jr Attorney for Plaintiff ti H w w ?o?¢ a`?, ??JL7c?,7o d Sow V U p ¢ W HMO QVai?,z °H Zd?,WW,-• z° a?,,dE-?Ac°? H W d Z. y U d •-, y N J4 ?N E'' ? N M ? W d ? 'J ? ? N i ° W bD Y N W (? y tt a+ M N W? ? y P C WX v 1 1 p pe t,, U, 7 --7L w ' Il 4 Zi. Qs V 1I n CY ,., lot C? SHORT DESCRIPTION y IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 SOLD as the property of DELORES J. TAYLOR TAX PARCEL # 20-24-0785-409 f \ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-638 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB, Plaintiff (s) From DELORES J. TAYLOR (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 $61,615.87 L.L. $.50 Interest FROM 4/17/07 TO DATE OF SALE AT 7.9900% Atty's Comm % Due Prothy $2.00 Atty Paid $170.40 Other Costs Plaintiff Paid Date: APRIL 19, 2007 (Seal) Curtis R. ong, Protho By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 1%. Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Mark%t Street Philadelphia, PA 19106 215-'627-1322 LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. DELORES J. TAYLOR (Mortgagor(s) and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-638 Civil Term LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. NWnt and address of the last recorded holder of every mortgage of record: IFAS E-B?hTi?,-AS-TRi3?'FE? 450 W 33RD STREET, 15TH FLOOR NEW YORK, NY 10001 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and coi information and belief. I understand that false statements herein are made relating to unsworn falsification to authorities. DATED: April 16, 2007 GOLDBECK] BY: Joseph A. Attorney for P t of my personal knowledge or penalties of 18 Pa. C.S. Section 4904 'Y & McKEEVER ., Esq. C am', vo -cf 0 rn N w ?' 07-638 Civil Term GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. DELORES J. TAYLOR Mortgagor(s) and Record Owner(s) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s; IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-638 Civil Term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TAYLOR, DELORES J. DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Your house at 427 York Street a/k/a 427 South York Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $61,615.87 obtained by LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB against you. NOTICE OF OWNER'S RIGHTS 07-638 Civil Term 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 LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below on 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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 I 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 within thirty (30) days from the date of the 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-638 Civil Term Resources available for Homeowners in Foreclosure ACT NOW! :1 A! A f Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretentionaa,goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of EMC-1389. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. C.) IV : cil 2> i'h M ?v W "? In the Court of Common Pleas of Cumberland County LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff vs. DELORES J. TAYLOR (Mortgagor(s) and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-638 Civil Term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DELORES J. TAYLOR by default for want of an Answer. Assess damages as follows: Debt Interest from 04/17/07 to Date of Sale Total $61,615.87 (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed pr4elivered to the p against whom judgment is to be entered and to his attorney of record, if any, after the default occ ed least t ays prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 1 IV Jr. AND NOW aaa J - 19 136 7 v , Judgment is entered in favor of LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB and against DELORES J. TAYLOR by default for want of an Answer and damages assessed in the sum of $61,615.87 as per the above certification. n A Protonotary • Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff No. 07-638 Civil Term VS. DELORES J. TAYLOR (Mortgagors and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotarv By: If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 EMC-1389 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: Apri14, 2007 TO: DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. DELORES J. TAYLOR (Mortgagor(s) and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) TO: DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-638 Civil Term 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 (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 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. LEGAL SERVICES INC 8 Wine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 -?o sevh ?. Q?cfheck Vr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The l,nriPrsicr.?nP_d, as the representative fnr the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DELORES J. TAYLOR, is about unknown years of age, that Defendant's last known residence is 427 York Street a/k/a 427 South York Street, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or Q`therwise within the Congress of 1940 and its Amendments. Date: SHERIFF'S RETURN - NOT SERVED CASE NO: 2007-00638 P 16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSN VS TAYLOR DELORES J R. Thomas Kline Sheriff who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: TAYLOR DELORES J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT , TAYLOR DELORES J NOT SERVED , as to 427 YORK STREET A/K/A 427 SOUTH YORK STREET MECHANICSBURG, PA 17055 DEFENDANT FILED BANKRUPTCY. ATTORNEY JAMES EACH 737-2033. Sheriff's Costs: So answe Docketing 18.00 Service 8.80 Affidavit .00 R. Thomas Klin Surcharge 10.00 Sheriff of Cumberland County .00 36.80/ GOLDBECK MCCAFFERTY MCKEEVER ai5 1 02/08/2007 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-00638 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSN VS TAYLOR DELORES J TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TAYLOR DELORES J the DEFENDANT , at 1851:00 HOURS, on the 14th day of March , 2007 at 427 S YORK STREET MECHANICSBURG, PA 17055 DELORES J TAYLOR by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 37.60 Sworn and Subscibed to before me this of , So Answers: 18.00 9.60 ? . 00 10.00 R. Thomas Kline 03/15/2007 GOLDBECK MCCAFFERTY MCKEEVER By: D p y Sh riff A.D. day ' GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 EMC-1389 CF: 02/01/2007 SD: 09/05/2007 $61,615.87 LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. DELORES J. TAYLOR Mortgagor(s) and Record Owner(s) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-638 Civil Term CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs eompowm t (copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subjec :)the penalties provided by 18 P.S. Section 4904. /1 ZI for Plaintiff I 4b VO C4 -92- i t? v C> v 4?q, LL, r a v U- C4 Try E ?? Z ? ?QQQ ? ? W c ? eWt? F ? Z t?A ? Q V N "' ? O ? g 3°? . V !rO. o N= vo w w to r' c*i C-i 0112 r ? m?l ?? N 14 SO a 4 s 'tit0 V!ui a, 0 O aT N ?s d N v? N 0 r 1 C r O C r d sl: 1, aa N c a J ? d v r N a, N N w o `? a Lasalle Bank National Association, Formerly Known as Lasalle National Bank, in its Capacity as Indenture Trustee Under that Certain Sale and Servicing Agreement Dated December 1, 2000 Among AFC Trust Series 2000-4, as Issuer, Superior Bank FSB VS Delores J. Taylor In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-638 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 23, 2007 at 1423 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Delores J. Taylor, by making known unto Delores J. Taylor personally, at 427 York Street a/k/a 427 South York Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on July 6, 2007 at 1459 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Delores J. Taylor located at 427 York Street a/k/a 427 South York Street, Mechanicsburg, Cumberland County, Pennsylvania 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 the within named defendant, to wit: Delores J. Taylor, by regular mail to her last known address of 427 York Street a/k/a 427 South York Street, Mechanicsburg, PA 17055. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. S R. Thomas Kline, Sheriff B Real Estate ergeant GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff vs. DELORES J. TAYLOR Mortgagor(s) and Record Owner(s) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-638 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: JP MORGAN CHASE BANK, AS TRUSTEE 450 W 33RD STREET, 15TH FLOOR NEW YORK, NY 10001 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 TENANTS/OCCUPANTS 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. 1- -) DATED: August 15, 2007 GOrrphA. K McCAFFERTY & 11 BY: Jos Goldbeck, Jr., Esq. Attorne r Plaintiff Cn ::Z 'Tr ?_;, nZ 1 ro -ij ?. 2 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which LaSalle Bank N A Tr is the grantee the same having been sold to said grantee on the 5th day of Sept A.D., 2007, under and by virtue of a writ Execution issued on the 19th day of April, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 638, at the suit of LaSalle Bank N A Tr against Delores J Taylor is duly recorded as Instrument Number 200737371. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ?J day of 'A.D. c20-07 !uy Cor?wfts on E?Nes the Fitt y?2610 Lasalle Bank National Association, In the Court of Common Pleas of Formerly Known as Lasalle National Cumberland County, Pennsylvania Bank, in its Capacity as Indenture Writ No. 2007-638 Civil Term Trustee Under that Certain Sale and Servicing Agreement Dated December 1, 2000 Among AFC Trust Series 2000-4, as Issuer, Superior Bank FSB VS Delores J. Taylor Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 23, 2007 at 1423 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Delores J. Taylor, by making known unto Delores J. Taylor personally, at 427 York Street a/k/a 427 South York Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on July 6, 2007 at 1459 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Delores J. Taylor located at 427 York Street a/k/a 427 South York Street, Mechanicsburg, Cumberland County, Pennsylvania 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 the within named defendant, to wit: Delores J. Taylor, by regular mail to her last known address of 427 York Street a/k/a 427 South York Street, Mechanicsburg, PA 17055. This letter was mailed under the date of July 2, 2007 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 September 5, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck, on behalf of LaSalle Bank National AADciation, formerly known as LaSalle National Bank, in its Capacity as Indenture Trustee under that Certain Sale and Servicing Agreement Dated December 1, 2000, Among AFC Trust Series 2000-4, As Issuer, Superior Bank FSB, as Seller and Servicer, and LaSalle Bank National Association, as Indenture Trustee, AFC Mortgage Loan Asset Backed Notes, Series 2000-4, and any Amendments Thereto. It being the highest bid and best price received for the same, LaSalle Bank National Association, formerly known as LaSalle National Bank, in its Capacity as Indenture Trustee under that Certain Sale and Servicing Agreement Dated December 1, 2000, Among AFC Trust Series 2000-4, As Issuer, Superior Bank FSB, as Seller and Servicer, and LaSalle Bank National Association, as Indenture Trustee, AFC Mortgage Loan Asset Backed Notes, Series 2000-4, and any Amendments Thereto of 909 Hidden Ridge Drive, Suite 200, Irving TX 75038 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $974.80. Sheriffs Costs: Docketing $30.00 Poundage 19.11 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 19.20 Levy 15.00 Surcharge 20.00 Law Journal 355.00 Patriot News 345.80 Share of Bills 15.69 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 974.80 So Answers: R. Thomas Kline, Sheriff BY Real Estate rgeant V C? ,0) DO V'7 ?Y a- ?, /9'g/9G Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center --- 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL. ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DELORES J. TAYLOR (Mortgagor(s) and Record Owner(s)) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-638 Civil Term LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: lVll\Tlil`I V , 450 W 33RD STREET, 15TH FLOOR NEW YORK, NY 10001 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 TVNANT4/--C TPANTS 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correc o the est of my personal knowledge or information and belief. I understand that false statements herein are made su ject to a penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 16.2007 GOLDBECK McCWERTY & McKEEVER BY: Joseph A. Gol beck, ., Esq. Attorney for Plainti 07-638 Civil Term GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff VS. Term No. 07-638 Civil Term DELORES J. TAYLOR Mortgagor(s) and Record Owner(s) 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Defendants; THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TAYLOR, DELORES I DELORES J. TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 Your house at 427 York Street a/k/a 427 South York Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $61,615.87 obtained by LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB against you. NOTICE OF OWNER'S RIGHTS 07-638 Civil Term 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 LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 20004, AS ISSUER, SUPERIOR BANK FSB, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 below on 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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. I 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 within thirty (30) days from the date of the 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-638 Civil Term Resources available for Homeowners in Foreclosure ACT NOW! Even though you le nder kanu our bent)-has fr Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretentionnjzoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of EMC-1389. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 05/02/2Q07 15:01 F_AX 215 627 7734 GOLDBECK ? aMBERLAND SGT 2002 All that certain lot of ground situate on the east side of South York Street, in the Fifth Ward of the Borough of Mechanicsburg, County of Cumberland, and State of Pennsylvania, bounded and described as follows, to wit: On the North by lot now or formerly of Ezra T_ Heise, on the East by a twenty (20) feet wide alley; on the South by lot now or formerly of Elwood W. Newhart, being the remaining portion of a larger lot of ground owned by said Elwood W. Newhart, a portion of a larger lot of ground owned by said South York Street, having a frontage of thirty (30) feet on South York Street, and extending in depth, an equal width, one hundred and sixty-one (161) feet to said public alley, and having thereon erected a two and one-half story frame dwelling house (being the northern one-half story frame dwelling house (being the northern one-half of a double house), known and numbered as No. 427 South York Street, Mechanicsburg, Pennsylvania. See Miscellaneous Book No. 81, at Page 210, for agreement concerning encroachment of building over property line. BEING THE SAME PREMISES BY DEED FROM CHARLES M. SHANK AND FRANCES S. SHANK DATED: 02/19/59 AND RECORDED: 02/19/59 IN BOOK Y18 PAGE 66 GRANTED AND CONVEYED UNTO NATHAN TAYLOR AND DELORES J. TAYLOR, HUSBAND AND WIFE. TAX PARCEL NO: 20-24-0785-409 WRIT OF EXECUTION and/or ATTACHMENT 3 COMMONWEALTH OF PENNSYLVANIA) NO 07-638 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB, Plaintiff (s) From DELORES J. TAYLOR (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 $61,615.87 L.L. $.50 Interest FROM 4/17/07 TO DATE OF SALE AT 7.9900% Atty's Comm % Due Prothy $2.00 Atty Paid $170.40 Other Costs Plaintiff Paid Date: APRIL 19, 2007 C is R. Long, Pr otary (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 L?s.?.-• l L Real Estate Sale # 22 On May 2, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA Known and numbered as 427 York Street a/k/a 427 South York Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 2, 2007 By: , ; Real Est e Sergeant i I .b V 9z do Lou ??i??, ; , 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 Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with 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 in the 18th and 25th day(s) of July and the 1st day(s) of August 2007. 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, place 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 SALE #22 &a . ................. Sworn to and subscribed be:?%WOMJRLJ -* D. Notari?.111 Seal Terry L Russeii, ; •lut?uy Public City Of Harrisburg, Dauphin County Commission Expires June 6, 2010 _ pr, Pp?navlvaniti 4,ggpr.IPttinn of NntgriF?S 96iAR PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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: July 20, July 27, and August 3, 2007 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. sa Mari e yne/t di tor SWORN TO AND SUBSCRIBED before me this 3 day of August, 2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My COmm"on EXpiroa Apr 28, 2010 FAUL ]MWAIM "LZ 90. 22 Writ No. 2007-638 Civil Lasalle Bank National Association, Formerly Known as Lasalle National Bank, in its Capacity as Indenture Trustee Under that Certain Sale and Servicing Agreement Dated December 1, 2000 Among AFC Trust Series 2000-4, as Issuer, Superior Bank FSB vs. Delores J. Taylor Atty.: Joseph Goldbeck DESCRIPTION All that certain lot of ground situate on the east side of South York Street, in the Fifth Ward of the Borough of Mechanicsburg, County of Cumberland, and State of Penn- sylvania, bounded and described as follows, to wit: On the North by lot now or for- merly of Ezra T. Heisey; on the East by a twenty (20) fret wide alley; on the South by lot now or formerly of El- wood W. Newhat, being the rem#An- ing portion of a larger lot of ground owned by said Elwood W. Newhart, a portion of a larger lot of ground owned by said South York Street, having a frontage of thirty (30) feet on South York Street, and extending in depth, an equal width, one hundred and sixty-one (161) feet to said public alley, and having thereon erected a two and one-half story frame dwelling house (being the northern one-half story frame dwelling house (being the northern one-half of a double house), known and numbered as No. 427 South York Street, Mechanicsburg, Pennsylvania. See Miscellaneous Book No. 81, at Page 210, for agreement concern- ing encroachment of building over property line. BEING the same premises by deed from Charles M. Shank and Frances S. Shank dated: 02/19/59 and recorded: 02 / 19/ 59 in Book Y 18 Page 66 granted and conveyed unto Nathan Taylor and Delores J. Taylor, husband and wife. TAX PARCEL NO: 20-24-0785- 409. Assignment of Bid NO. 07-638 Civil Term - TAYLOR 427 York Street a/k/a 427 South York Street Mechanicsburg, PA 17055 I, Joseph A. Goldbeck, Jr., Esquire, as attorney for the successful bidder, hereby assign my bid at the Sheriff Sale dated September 05, 2007 to: LASALLE BANK NATIONAL ASSOCIATION, FORMERLY KNOWN AS LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE AND SERVICING AGREEMENT DATED DECEMBER 1, 2000 AMONG AFC TRUST SERIES 2000-4, AS ISSUER, SUPERIOR BANK FSB, AS SELLER ANS SERVICER, AND LASALLE BANK NATIONAL ASSOCIATION, AS INDENTURE TRUSTEE, AFC MORTGAGELOAN ASSET BACKED NOTES, SERIES 2000-4, AND ANY AMENDMENTS THERETO 909 Hidden Ridge Drive Suite 200 Irving, TX 75038 GOLDBECK MCCAFFERTY & MCKEEVER Date: September 12, 2007 JOSEPH A. GOLDBECK, JR.