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HomeMy WebLinkAbout07-1409GOLDBECK 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 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 Plaintiff VS. WALTER R. STANSBURY JR. Mortgagor and Real Owner 130-10 W. Portland Street Mechanicsburg, PA 17055 Defendant .1?.V 1iL A496N: MORTGAGE, F7E!Cl.0SUiRF 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 NECESSARIO QUE USTED, 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 ? t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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, ESTA 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 1-866-413-2311 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 CITX-1823. 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 TRAVELERS BANK & TRUST, FSB, 1111 Northpoint Drive, Building 4, Suite 100 Coppell, TX 75019. 2. The names and addresses of the Defendant is WALTER R. STANSBURY JR., 130-10 W. Portland Street, Mechanicsburg, PA 17055, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On July 15, 2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to TRAVELERS BANK & TRUST, FSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book: 1765, Page: 2699.. 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 October 22, 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 ....................................................................................$62,153.06 Interest from 09/22/2006 through 03/31/2007 at 8.5500% .......................$2,821.06 Per Diem interest rate at $14.77 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$3,107.65 Costs of suit and Title Search ......................................................................$900.00 Corporate Advance ......................................................................................$198.00 Escrow Advance .......................................................................................$1.526.53 $70,706.30 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 Sheriffs 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 "in 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 $70,706.30, together with interest at the rate of $14.77, 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 Sheriff's Sale of the Property. By: uu BECIK McCAFFERTY & MCKEEVER BY OSEPH A. GOLDBECK, JR., ESQUIRE A RNEY FOR PLAINTIFF VERIFICATION I, Frankie Ward, Asst. VP, 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: D ? d FRANKIA WARD, SIST.V CITIMORTGAGE INC. S/B/M CITIFINANCIAL INANCIAL MORTGAGE CO INC. E..x..hibit A ALL THAT CERTAIN Unit in the property knownf nAmed and 14entifie4 in the Peclaxation referred to below as "Portland Court, Condominiums," located in MechAnicaburg Borough, Cumberland County, Pennsylvania, which has heretofore been submitted to the provislona of the POnnsylvAnLa Uniform Condominium Act, 68 Pa.C.S.A. 3181 by the recording in the Office of the Recorder of Deeds of Cumberland County of a Declaration dated ,January 9, 1989, and recorded on May 18, 1989, in Miscellaneous Book 363, page 1$47, and also the amendments dater] July 28, 1989 and recorde4 in Miscellaneous Book 387, Page 338, ana dated August 11,,1989, and recorded in Miscellaneous Hook 3672 Page 835, as tha same shall be amended from time to time, being and designated in such DeclarAtion, as the sAme is Amended from time to time, as Unit No. 126-34, being and designated in such Declaration, as the same may be amended from time to time, together with a proportionate undivided interest in the Common Elements (as defined in $sid DeclArAtion) of 2.77%. SAID unit having a mailing address of 138--10 West Portland Btreat, Mechanie*burg, Cumberland County, Pearlsylvania.' Ey,Fi6it B 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. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (7171780-1869.) 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 any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Homeowners Name: WALTER R. STANSBURY JR. Property Address: 130-10 W. Portland Street, Mechanicsburg, PA 17055 Loan Account No.: 3943266 Original Lender: TRAVELERS BANK & TRUST, FSB Current Lender/Servicer: CITIFINANCIAL MORTGAGE CO., INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (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 meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set 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 Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-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 your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 130-10 W. Portland Street, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 10/22/2006 thru 2/7/2007 (5 mos. at $528.68/month) $2,643.40 (b) Late charges (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $2,643.40 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,643.40 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: CITIFINANCIAL MORTGAGE CO., INC. 4050 Regent Blvd. Mail Stop MS-NIB-165 Attn: Department ATM Irving, TX 75063 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour 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 the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY Period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and 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 or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4 to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIFINANCIAL MORTGAGE CO., INC. Address: 4050 Regent Blvd Mail Stop: MS-NIB-165 Attn: Department ATM Irving, TX 75063 Phone Number: 800-422-1498 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: CTTIFINANCIAL MORTGAGE CO., INC. Phone Number: 800-422-1498 -PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY MOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717)334-1518 FAX (717) 334-8326 i g J .1 !L, a 61 r ?+ _t a3 In the Court of Common Pleas of Cumberland County TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 VS. Plaintiff (Mortgagor(s) and Record Owner(s)) 130-10 W. Portland Street Mechanicsburg, PA 17055 No. 07-1409 Defendant(s) 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. Answer. Enter the Judgment in favor of Plaintiff and against WALTER R. STANSBURY JR. by default for want of an Assess damages as follows: $70,957.39 Debt Interest from 04/18107 to Date of Sale Total (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 CERTAOM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or is to be entered and to his attorney of record, if any, after the default occurred filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 the party against, whom judgment ten days priqrfo the date of the Joseph A. G r. Attorney fo laintiff I.D. #161 AND NOW , J ent is entered in favor of TRAVELERS BANK & TRUST, FSB and against WALTER R. STANSBURY JR. efault for want of an Answer and damages assessed in the sum of $70,957.39 as per the above certification. Proth otary - ? A Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 Plaintiff VS. WALTER R. STANSBURY JR. (Mortgagors and Record Owner(s)) 130-10 W. Portland Street Mechanicsburg, PA 17055 Defendant(s) No. 07-1409 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 Prothonotam By: If you have any questi g 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 04/26/2007 10:16 FAX 215 627 7734 GOLDBECIt 002 CITX-1823 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: April 5, 2007 TO: WALTER R. STANSBURY JR. 130-10 W, Portland Street Mechanicsburg, PA 17055 TRAVELERS BANK & TROST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 vs. WALTER R. STANSBURY X. (Mortgagor(s) and Record Owner(s)) 130-10 W. Portland Street Mechanicsburg, PA 17055 TO_ WALTER R. STANSBURY JR. 130-10 W. Portland Street Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-1409 IMPORTANT NOXIC.F. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND TILE 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 IlvII'ORTANT RIGHTS- YOU SHOULD TAKE THIS PATER 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 A13OUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR No FFF. LEGAL SERVICES INC 8 Inine Row Carlisle. PA 17013 It 7-2434400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 I -colih 4.- GO(AFC `fir GOLDBECK McCAFFERTY & McKEEYER BY, Joseph A. Goldbeck, Jr_, Esq_ Attomey for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE - 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, WALTER R. STANSBURY JR., is about unknown years of age, that Defendant's last known residence is 130-10 W. Portland 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, ga-otherwise within the Congress of 1940 and its Amendments. Date: 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 TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 vs. WALTER R. STANSBURY JR. (Mortgagor(s) and Record owner(s)) 130-10 W. Portland Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 07-1409 ORDER FOR JUDGMENT Please enter Judgment in favor of TRAVELERS BANK & TRUS STANSBURY JR. for failure to file an Answer in the above action within defendant is the United States of America) from the date of service of the Joseph A. G Attorney for creditor is TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive E 75019 and that the name(s) and last known address(es) of the Defendant(s) JR., 130-10 W. Portland Street Mechanicsburg, PA 17055; GOLDBECK McC. BY: Joseph A. Gob Attorney for Plainti and against WALTER R. s (or sixty (60) days if .it, in the sum of $70,957.39. 1, Suite 100 Coppell, TX 'ALTER R. STANSBURY ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Interest from 09/22/2006 through $3,072.15 04/17/2007 Reasonable Attorney's Fee $3,107.65 Late Charges $0.00 Costs of Suit and Title Search $900.00 Corporate Advance $198.00 Escrow Advance $1,526.53 70,957.39 GOLDBECK M(C & McKEEVER BY: Joseph A. Goldb k, Jr. Attorney for Plaintiff AND NOW, this )Q?day of h??A-IL `,, 2007 damages are assessed as above. Pro P othy V ? d ri r d i r' PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street 215-627-1322 Attorney for Plaintiff TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 VS. WALTER R. STANSBURY JR. Mortgagor(s) and Record Owner(s) 130-10 W. Portland Street Mechanicsburg, PA 17055 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-1409 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 04/18/07 8.5500% (Costs to be added) $70,957.39 d W Pa, O oI 0 0 r. N W H oO z? O 6 W H Qt ON r? c cam, o 6 "xi 0 F ? M a°i ?ij U ti N b O C7 d IJa• 4 V v v V V s 14 r z 0 ?W W O i? W Y V 0 M v J A ? 'br ?U a? o N ? N ?g a v V_ ALL THAT CERTAIN UNIT IN THE PROPERTY KNOWN, NAMED AND IDENTIFIED IN THE DECLARATION REFERRED TO BELOW AS "PORTLAND COURT CONDOMINIUMS," LOCATED IN MECHANICSBURG BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH HAS HERETOFORE BEEN SUBMITTED TO THE PROVISIONS OF THE PENNSYLVANIA UNIFORM CONDOMINIUM ACT, 68 PA.C.S.A. 3101 BY THE RECORDING IN THE OFFICE OF THE A D , RECORDER OF DEEDS OF C EREAND COUNTY OF 1989, AND RECORDED ON MAY 10, 1989, IN MISCELLANEOUS BOOK 363, PAGE 1047, AND ALSO THE AMENDMENTS DATED JULY 28, 1989 AND RECORDED IN MISCELLANEOUS BOOK 367, PAGE 338, AND DATED AUGUST 11, 1989, AND RECORDED IN MISCELLANEOUS BOOK 367, PAGE 835, AS THE SAME SHALL BE AMENDED FROM TIME TO TIME, BEING AND DESIGNATED IN SUCH DECLARATION, AS THE SAME IS AMENDED FROM TIME TO TIME, AS UNIT NO. 126-34, BEING AND DESIGNATED IN SUCH DECLARATION, AS THE SAME MAY BE AMENDED FROM TIME TO TIME, TOGETHER WITH A PROPORTIONATE UNDIVIDED INTEREST IN THE COMMON ELEMENTS (AS DEFINED IN SAID DECLARATION) OF 2.77%. SAID UNIT HAVING A MAILING ADDRESS OF 130-10 WEST PORTLAND STREET, MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA. TAX PARCEL NO: 19-22-0519-057-UI3010 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1409 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TRAVELERS BANK & TRUST, FSB, Plaintiff (s) From WALTER R. STANSBURY, JR. (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 $70,957.39 L.L. $.50 Interest FROM 4/18/07 TO DATE OF SALE AT 8.5500% Atty's Comm % Due Prothy $2.00 Atty Paid $133.60 Plaintiff Paid Other Costs Date: APRIL 19, 2007 (Seal) 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 Curtis R ong, Pro a By: Deputy Telephone: 215-627-1322 Supreme Court ID No. 16132 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 TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 VS. WALTER R. STANSBURY JR. (Mortgagor(s) and Record Owner(s)) 130-10 W. Portland Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 07-1409 AFFIDAVIT PURSUANT TO RULE 3129 TRAVELERS BANK & TRUST, 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: 130-10 W. Portland Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): WALTER R. STANSBURY JR. 130-10 W. Portland Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: WALTER R. STANSBURY JR. 130-10 W. Portland 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 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ?J .,,, 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. TENANTS/OCCUPANTS 130-10 W. Portland 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 ttest personal knowledge or information and belief. I understand that false statements herein are made subject ies of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: April 17, 2007 GOLDBECK McC & McKEEVER BY: Joseph A. Go e Jr., q. Attorney for Plaintiff ? ?? ? ?? ???'A' / ? s? ? =`? ??:? ?? ??.?~ =? ? ? 07-1409 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelnhia. PA 19106 215-825-6318 Attorney for Plaintiff TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. WALTER R. STANSBURY JR. Mortgagor(s) and Record Owner(s) 130-10 W. Portland Street Mechanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Term No. 07-1409 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: STANSBURY, JR., WALTER R WALTER R. STANSBURY JR. 130-10 W. Portland Street Mechanicsburg, PA 17055 Your house at 130-10 W. Portland 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 $70,957.39 obtained by TRAVELERS BANK & TRUST, FSB against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to TRAVELERS BANK & TRUST, 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. `- M 07-1409 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 stop?in? 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 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 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 r 07-1409 Resources available for Homeowners in Foreclosure ACT NOW! -en- t ou your en er an our c ien as an c ion o o gage 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 1-866-413-2311 or via email at homeretention(a yoldbecklaw.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 CITX-1823. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. e? 9 ?U?? ? -i ???y, ? ?? tP.,4,"?-,, p ??.. ??..., .y ?...++ ? `''' 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 Attornev for Plaintiff TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 Plaintiff vs. WALTER R. STANSBURY JR. (Mortgagor(s) and Record owner(s)) 130-10 W. Portland Street Mechanicsburg, PA 17055 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: No. 07-1409 Kindly vacate the judgment upon payment of your costs only. IN THE COURT OF COMMON PLEAS of Cumberland County -POW JOSEPH A. GOLDBECK, JR., ESQUIRE n IV GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. 416132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 for Plaintiff TRAVELERS BANK & TRUST, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019 Plaintiff VS. WALTER R. STANSBURY JR. (Mortgagor(s) and Record owner(s)) 130-10 W. Portland Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County No. 07-1409 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE Oc ty; y.• to " .G SHERIFF'S RETURN - REGULAR CASE NO: 2007-01409 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS STANSBURY WALTER R JR JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STANSBURY WALTER R JR the DEFENDANT , at 1351:00 HOURS, on the 15th day of March 2007 at 130-10 W PORTLAND STREET MECHANICSBURG, PA 17055 1.11 T -"C'. TT TTCI TTT7',T TT] by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 9.60 Affidavit 00 Surcharge 10.00 R. Thomas Kline . o o ,DO 37.60' 03/16/2007 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to ' By: --7 before me this day Deputy Sheriff of A.D. vvI V2f .6vv1 tv.JJ rnd 410 041 11J$ UULL)bhLA 3 CUMBERLAND SO 10 001 GOLDBECK MCCAFFERTY & MCKEEVER A PROFESSIONAL CORPORATION SUITE 5000 - MELLON INDEPENDENCE CENTER . 701 MARKET STREET PHILADELPHIA, PA 191 Q6-1532 (215) 627-1322 FAX (215) 627-7734 May 4, 2007 R. Thomas Kline ' SHERIFF OF CUMBERLAND COUNTY Sheriffs Office Carlisle, PA 17013 RE: TRAVELERS BANK & TRUST, FSB vs. WALTER R. STANSBUJR. Term No. 07-1409 ?? Property address: 130-10 W. Portland Street Mechanicsburg, PA 97055 Sheriffs Sale Date; September 05, 2007 Cumberland Dear Sir/Madam; Kindly stay the Sheriffs Sale with reference to the above-captioned matter and return any unused costs. I collected $9,702.54 towards my client's debt. Thank you for your cooperation- Very ftGECK, JR.