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HomeMy WebLinkAbout07-2395GOLDDECK McCAFFERTY & McKEEVER BYE JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 ?7 79S L SUITE 5000 - MELLON INDEPENDENCE CENTER t? ?• i V IL L 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 Plaintiff vs. RACHEL MUKORA Mortgagor and Real Owner 4706 Delbrook Road Mechanicsburg, PA 17050 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL ACTION: MOO"CiAGE ?}R?CLC??`t1flE 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 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 WH,L 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 888-577-4011 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(i?goldbecklaw com. Call Seth 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-1513. 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 EMC MORTGAGE CORPORATION, PO Box 293150, Lewisville, TX 75029. 2. The names and addresses of the Defendant is RACHEL MUKORA, 5041 Haverford Road, Harrisburg, PA 17109, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On April 18, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to LONG BEACH MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1904, Page 3436. The mortgage has been assigned to: EMC MORTGAGE CORPORATION 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 December 01, 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 ................................................................... Interest from 11/01/2006 through 04/30/2007 at 8.9300%.... Per Diem interest rate at $29.01 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 12/01/2006 to 04/30/2007 ....................... Monthly late charge amount at $57.50 Costs of suit and Title Search ................................................ .............$118,583.56 .................$5,250.81 .................. $5,929.18 .....................$287.50 Fees ........................................................................................................... Monthly Escrow amount $146.00 $900.00 ..$27.00 $130,978.05 7. If the Mortgage is reinstated prior to a Sheriff's 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 "in nersonam" 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 $130,978.05, together with interest at the rate of $29.01, 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: O DBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION >ec- 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: ,/G/0---7 EMC rtgage Corporation as Attorney in Fact e'CILI OUr? ? ?\ Assistant Secretary #0003422433 - RACHEL MUKORA ExhibitA ALL TWAT CE2TAIN pieoe or pone of had with the burp sad bttyfre"Mu q ihw= ereetK dUlW to lls,sptio Toweabip, C.YrmberLmd CmoRy, ftmylrawla, and da m*W waxi btg to ¦ Survey merle by Geerit J. )acts. Ileoaaed Surmair. dated -Nevonba ID. Im as bftows, to wit.. BEGWWING at a bub on the mush lade of pal leech Raed (fib &d wide), at the Omer of l,pt No. 3, OW Pout bdug sfra?eto od damp ibo add aide of Dd4WO k Road 2*Jl ties[ Weft d the aotrtbwad eetyw d Det- Be" Road wad SL Mwkl o Road; dtoft eahndlttg hots old pdw of bqome6 sad OwW the dnidm Nw but*wat Lets 3 and 4 Sovth 23 depeee 00 ndwow East the Astaaee of 130 feet to a bAb at the et her of tetra: .sew er hrmifffY of l*R Reeky; ehetatx atoaS Ludt ear or fortaerty of B&N Ratty 3=& 67 dope" so +tmiMAN Wed the & taste of W fist to a hub of the aeneer efLet Na S-r romp a6q do dlvyi? rive bawaeu LOS 4 ad S N elk 23 dwm 00 mhwas grad the d owete or i3o rod to • bub of the career of Lot ft. $; dw""t9te dlvMim Jim btiwaao A,ola 4 and i Nwo 23 dtOfoet w odmom Wat d% daeaw d 13D ttw to a hub on the aid lade of Dd-Rew* Read; &Not melts laid side of De4Smit itosd North 67 jkp 00 ntklutea EW !be tltARM Of 63 !lest to a PoW, the Flow of E$GINMM. BEING Lot No. 4 on the Plan of &. Mark' s Plate, r wrded Its Ilea no* 1, pew S. BEING known as No. 4706 Dd4k-wk Rood. UNDER AND S1 W'T, NRVBBTXXLVw, is eeseteetW, rvotrictilf"a, rewvatkm, usatbtty end ria w away of record BEING the sates premises which STEPHEN J. BOND, SR. by doed dated May 12, 2004 and ncarded may 18, 2001 ?n Sts ORtoe of the Recorder of Deeds in and for Cuntbedand Comty, in Book 283, Pape 268, PWVWA anla harsMM. g W*W and tDrtveyad tnb BMW LLC, a Panrtaylvanio Limited LisbW CoMpartp, In hft. E?hibit (B EMC Mortgage Corporation February 8, 2007 I 00 6 6 Rachel Mukora 4706 Delbrook Rd Mechanicsburg, PA 17050 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 foreclosure. 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 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 iv once. it you nave any questions you may ca a ennsy vania Housing 14 inane gency o ee a - persons wi impaired hearing can call 717-780-18691 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La 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 llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa liamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME: Rachel Mukora PROPERTY ADDRESS: 4706 Delbrook Rd Mechanicsburg, PA 17050 LOAN ACCOUNT NUMBER: 0003422433 CURRENT SERVICER 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. Page two 0003422433 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 property 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 immediatelyof 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 4706 Delbrook Rd Mechanicsburg, PA 17050 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 12/01/2006: $3,313.14 (b) Late charge(s) : $115.00 (c) Other charge(s): NSF and Advances $0.00 (d) Less: Credit Balance $0.00 (e) Total amount required as of 02/07/2007: $3,428.14 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 $3,428.14, 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 0003422433 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-beiold by the-Sheri€fto-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 pay attorneys' 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 would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: EMC Mortgage Corporation Address: Mac Arthur Ridge II, 909 Hidden Ridge Drive, Suite 200, Irving, Texas 75038 Telephone Number: 1-888-609-2379 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 sheriffs sale, a lawsuit to remove you and your furniture 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 YOU MAY ALSO HAVE THE RIGHT - To sell the property to obtain money to pay off the mortgage debt, or borrow money from another lending institution to pay off this debt. - To have this default cured by any third party acting on your behalf. - To have the mortgage restored to the same position as if no default had occurred. (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. Page four 0003422433 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_verificadon_oi the debt or a copy of u _,iudgement_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 Appendix B Consumer Credit Counseling Agency Notification To: Name of Mortgagee: Address: In accordance with the Pennslyvania Homeowner's Emergency Mortgage Assistance Program (Act 91 of 1983), we have been approached for mortgage counseling assistance by: Name of Applicant Address Telephone Number Mortgage Loan Number Address of property on which mortgage is in default, If different from above. The counseling agency met with the above named applicant on Date Who have indicated that they are more than sixty (60) days delinquent on their mortgage payments and have received notification to foreclosure from: of In accordance with the Homeowner's Emergency Mortgage Assistance Program, this is to inform you that: 1. If the delinquency cannot be resolved with in the 30 day forbearance period as provided by the Servicer, the applicant listed above may apply to the Pennsylvania Housing Finance Agency for Homeowner's Emergency Mortgage Assistance. 2. By a copy of this Notice, we are notifying all other mortgagees, if any, which the applicant has indicated as also having a mortgage on the property identified above. 3. It is our understanding that the 30 day forbearance period in which we are now in ends on 4. No legal action to enforce the mortgage may occur during this forbearance period, unless procedural time limits were not met by the homeowner. * Indicates Counties Serviced JFK Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 * Crawford, Elk, Erie, Jefferson, McKean, Venango Northern Tier Community Action Corp. P.O. Box 389 135 West 4th St. Emporium, PA 15834 (814) 486-1161 * Cameron, Elk, McKean, Potter CCCS of Western PA 1138 N. Main St. Extension Butler, PA 16001 888-511-2227 * Butler, Clarion, Jefferson, Mercer, Venango Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (724) 981-5310 * Crawford, Lawrence, Mercer CCCS of Northeastern PA 202 W. Hamilton Ave. State College, PA 16801 (814) 238-3668 ' Blair, Centre, Clearfield, Clinton, Huntingdon, Juniata, Mifflin CCCS of Western PA, Inc. 217 E. Plank Road Altoona, PA 16602 888-511-2227 * Armstrong, Bedford, Blair, Cambria, Centre, Clearfield, Huntingdon Juniata, Mifflin, Union Huntingdon County Housing Services Weatherization Inc. 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2343 * Bedford, Blair, Fulton, Huntingdon, Juniata, Mifflin Community Action Development Comm-CADCOM 113 E Main St Norristown, PA 19401 (610) 277-6363 * Montgomery Germantown Settlement 218 W, Chelten Avenue Philadelphia, PA 19144 215-849-3104 * Bucks, Chester, Delaware, Montgomery, Philadelphia HACE 167 W. Allegheny Ave. 2nd Floor Philadelphia, PA 19140 (215) 426-8025 * Bucks, Chester, Delware, Philadelphis Housing Assoc. of Delaware Valley 658 North Watts Street Philadelphia, PA 19123 (215) 978-0224 * Philadelphia Community Action Committee of the Lehigh Valley 1337 East Fifth Street Bethlehem, PA 18015 610-691-5620 * Berks, Carbon, Lehigh, Monroe, Northhampton Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 * Bucks, Chester, Delaware, Montgomery, Philadelphia CCCS of Northeastern PA 201 Basin Street Suite 6 Williamsport, PA 17701 (570) 323-0627 * Centre, Clinton, Lycoming, Northumberland, Union American Credit Counseling Institute 845 Coates St. Coatesville, PA 19320 (888) 212-6741 1400 Abington Executive Park Suite 1 Clarks Summitt, PA 18411 570-587-9163 ' Bradford, Carbon, Columbia, Lackawanna, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Tioga, Union, Wayne Wyoming CCCS of Northeastern PA Genetti Towers 77 E Market Street, 7th Floor Wilkes-Barre, PA 18702 570-821-0837 Bradford, Carbon, Columbia, Lackawanna, Luzeme, Lycoming, Monroe * Montour, Pike, Susquehanna, Sullivan, Tioga, Union, Wayne, Wyoming CCCS of Northeastern PA 411 Main Street Suite 102E Stroudsburg, PA 18360 (570) 420-8980 or 800-922-9537 * Bradford, Carbon, Monroe, Pike, Wayne * Bucks, Chester, Montgomery, Philadelphia American Credit Counseling Institute 530 West Street Rd Suite 201 Warminster, PA 18974 * Bucks, Montgomery, Philadelphia American Credit Counseling Institute 528 Dekalb Street Norristown, PA 19401 (610) 971-2210 * Montgomery The Trehab Center of Northeastern PA 10 Public Ave Po Box 366 Montrose, PA 18801 (570) 278-3338 or 1-800-982-4045 *Susquehanna * Indicates Counties Serviced Keystone Economic Develop. Corp 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 * Bedford, Blair, Cambria, Clearfield, Indiana, Somerset, Westmoreland Tableland Services Inc. 535 East Main Street Somerset, PA 15501 (814) 445-9628 - 1-800-452-0148 * Armstrong, Cambria, Fayette, Somerset, Westmoreland The Trehab Center of Northeastern PA German Street PO Box 389 Dushore, PA 18614 (570) 928-9667 * Sullivan Indiana Co. Community Action Program 827 Water Street Box 187 Indiana, PA 15701 (724) 465-2657 ' Armstrong, Cambria, Clearfield, Indiana, Jefferson * Westmoreland New Life Commun Housing Devel Corp 712 Hawkins Avenue Braddock, PA 15104 412-351-4077 * Allegheny, Washington, Westmoreland Community Action Southwest 150 West Beau Street Suite 304 Washington, PA 15301 (724) 225-9550 * Washington Action Housing, Inc FOB CDC 425 6th Avenue Suite 950 1201 West Olney Avenue Pittsburgh, PA 15219 (800) 792-2801 or Philadelphia, PA 19141 (412) 391-1956 or (412) 281-2102 215-549-8755 * Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland * Chester, Delaware, Philadelphia CCCS of Western PA, Inc. 90 East Chestnut Street Washington, PA 15301 888-511-2227 * Washington Community Action Southwest 58 East Greene Street Waynesburg, PA 15370 (724) 852-2893 * Allegheny, Fayette, Greene, Washington, Westmoreland Tabor Community Services, Inc. 439 E. King Street PO Box 1676 Lancaster, PA 17608 (717) 397-5182 OR 1-800-788-5062 * Chester, Lancaster, Lebanon American Financial Counseling Services 906 Penn Avenue Wyomissing, PA 19610 610-378-5140 * Barks CCCS of Western PA, Inc. 199 Edison Street Uniontown, PA 15401 888-511-2227 * Fayette County Bucks County Housing Group 349 Durham Road Penndel, PA 19047 866-866-0280 ' Bucks County American Credit Counseling Institute 300 North Pottstown Pike Suite 210 Exton, PA 19341 888-212-6741 * Berks, Bucks, Montgomery Pennsylvania Housing Finance Agency 2275 Swallow Hill road Bldg 200 Pittsburgh, PA 15220 (412) 429-2842 *Allegheny CCCS of Western PA 4402 Peach Street Erie, PA 16509 1-888-511-2227 ext 108 * Erie County American Financial Counseling Svcs, Inc. 175 Strafford Avenue, Suite One Wayne, PA 19087 800-490-3039 * Delaware County CCCS of Western PA 917A Logan Blvd: Royal/Remax Plaza Altoona, PA 16602 888-511-2227 * Cameron The Trehab Center of Northeastern PA The Enterprise Center 703 S. Elmer Avenue Sayre, PA 18840 (570) 888-0412 * Bradford Bucks County Housing Group 470 Old Dublin Pike Doylestown, PA 18901 866-866-0280 The Trehab Center of Northeastern PA 144 E. East Avenue Wellsboro, PA 16901 (570) 724-5252 * Tioga County * Indicates Counties Serviced APM 2147 North Sixth Street Philadelphia, PA 19122 (215) 235-6788 * Chester, Delaware, Philadelphia Carroll Park Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 * Chester, Delaware, Philadelphia CCCS of Delaware Valley One Cherry Hill Suite 215 Chevy Hill, PA 08002 (215) 563-5665 * Philadelphia Urban League Of Pittsburgh Bldg. For Equal Opportunity One Smithfield St. Pittsburgh, PA 15222 (412) 227-4802 * Allegheny CCCS of Western PA, Inc. Colonial Shopping Center 970 S. George St York, PA 17403 888-511-227 * Franklin, Fulton, Lancaster, York Housing Council of York 35 South Duke Street York, PA 17401 (717) 8541541 * York American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 (610) 874-1484 * Chester, Delaware CCCS of Western Pennsylvania 312 Chestnut Street Suite 227 Meadville, PA 16335 888-511-2227 * Lawrence CCCS of Delaware Valley Catholic Social Services Building 7340 Jackson Street Philadelphia, PA 19136 (215) 563-5665 -* Bucks, Philadelphia Comm. Devel. Corp of Frankford Group Ministry 4620 Griscom Street Philadelphia, PA 19124 (215) 744-2990 ' Philadelphia Lycom-Clntn Co Comm fo Comm Action 2138 Lincoln Street PO Box 3568 Williamsport, PA 17703 (570) 326-0587 * Centre, Clinton, Lycoming, Union Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 (814) 337-8450 * Crawford, Venango Diversified Community Service Dixon House 1920 South 20th Street Philadelphia, PA 19145 215-336-3511 * Bucks, Chester, Delaware, Philadelphia Adams County Interfaith Housing Authority 40 E. High St Gettysburg, PA 17325 (717) 334-1518 * Adams, Cumberland, Franklin, York Acorn Housing of Pittsburg 5907 Penn Avenue Suite 300 Pittsburgh, PA 15206 412-441-7240 * Allegheny CCCS of Western PA, Inc. River Park Commons 2403 Sidney Street, Suite 400 Pittsburgh, PA 15203 888-511-2227 * Allegheny CCCS of Delaware Valley 280 North Providence Road Media, PA 19063 (215) 563-5665 * Delaware American Red Cross-Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 * Adams, Franklin, York Armstrong Co Community Action Agency 124 Armsdale Road Suite 211 Kittanning, PA 16201 (724) 548-3405 * Armstrong CCCS of Western PA, Inc. 971 Third Street Beaver, PA 15009 888-511-2227 * Beaver Housing Opportunities of Beaver County 650 Corporation St. Suite 207 Beaver, PA 15009 (724) 728-7511 * Beaver, Lawrence CCCS of Delaware Valley 790 E. Market St. Suite 170 Marshall Bldg West Chester, PA 19382 (215) 563-5665 * Chester, Delaware The Trehab Center of Northeastern PA 232 Sunrise Avenue Suite Al Honesdale, PA 18431 Bucks County Housing Group 515 West End Boulevard Quakertown, PA 18951 866-866-0280 * Bucks CCCS of Delaware Valley Catholic Social Services Building 607 West Street Road Warminister, PA 18974 (215) 563-5665 * Bucks American Credit Counseling Institute 937 North Hanover Street Pottstown, PA 19460 888-212-6741 * Barks County PHFA 211 North Front Street Harrisburg, PA 17110 800-342-2397 * Cumberland, Dauphin Bucks County Housing Group, Inc 2324 Second Street Pike Suite 17 Wrightstown, PA 18940 866-866-0280 ' Bucks The Trehab Center of Northeastern PA 115 SR 92S Tunkhannock, PA 18657 (570) 836-6840 * Wyoming ' Wayne Bucks County Housing Group 200 West Bridge Street Morrisville, PA 19067 866-866-0280 * Bucks American Credit Counseling Institute 21 South Church Street West Chester, PA 19380 1-888-212-6741 * Chester * Indicates Counties Serviced Housing Assoc. of Delaware Valley Urban League of Philadelphia Community Action Commission 1500 Walnut Street Suite 601 Tenn Penn Ctr - 1801 Market St. Suite 250 of Capital Region Philadelphia, PA 19102 Philadelphia, PA 19103 1514 Deny Street (215) 545-6010 (215) 561-6070 Harrisburg, PA 17094 * Philadelphia * Bucks, Delaware, Philadelphia * Snyder Housing Partnership of Chester Coun eBaoc-r T: Washington Center CCCS of Wes et m P- -- 41 West Lancaster Ave 1720 Holland Street 219-A College Park Plaza Downingtown, PA 19335 Erie, PA 16503 Johnstown, PA 15904 610-518-1522 (814) 453-5744 888-511-2227 * Chester, Delaware, Montgomery * Crawford, Erie, Warren * Cambria, Clearfield, Indiana, Somerset Northwest Counseling Service 5001 North Broad Street Philadelphia, PA 19141 (215) 324-7500 ' Bucks, Chester, Delaware, Montgomery * Philadelphia Philadelphia Council for Commun. Action 100 North 17th Street Suite 600 Philadelphia, PA 19103 (215) 567-7803 * Chester, Delaware, Montgomery, Philadelphia American Financial Counseling Services 1 Abington Plaza, Suite 403 Old York Road and Township Line Jenkintown, PA 19046 800-490-3039 * Delaware, Montgomer Greater Erie Commun. Action Committee 18 West 9TH Street Erie, PA 16501 (814) 459-4581 * Crawford, Erie, Warren, Venango St. Martin Center 1701 Parade Street Erie, PA 16503 (814) 452-6113 * Crawford, Erie, Warren, Venango Warren-Forest Counties Economic Opportunity Council 1209 Pennsylvania Ave, West P.O. Box 547 Warren, PA 16365 (814) 726-2400 * Forest, Warren CCCS of Western PA, Inc. 1 North Gate Square #2 Garden Center Dr Greensburg, PA 15601 888-511-2227 ' Somerset, Westmoreloand, Washington * Fayette, Greene, Indiana Center for Community Services 10241 Lincoln Highway Everett, PA 15537 (814) 623-9129 ' Somerset, Blair, Bedford, Cambria Fulton, Huntingdon CCCS of Western PA 4402 Peach Street Erie, PA 16509 1-888-511-2227 ext 108 * Crawford, Warren American Financial Counseling Services, Inc. CCCS of Lehigh Valley Huntington Co Housing Svcs. 175 Strafford Avenue, Suite One 3671 Crescent Court East Weatherization Inc. Wayne, PA 19087 Whitehall, PA 18052 917 Mifflin Street 800-490-3039 (610) 821-4011 OR 1-800-220-2733 Huntingdon, PA 16652 * Bucks, Chester, Delaware, Montgomery ' Barks, Bucks, Carbon, Lancaster, Lehigh (814) 643-2343 * Philadelphia * Northhampton, Schuylkill * Perry CCCS of Delaware Valley Budget Counseling Center Loveship, Inc. 1777 Sentry Parkway West 247 North Fifth Street 2320 North 5th Street Blue Bell, PA 19422 Reading, PA 19601 Harrisburg, PA 17110 (215) 563-5665 (610) 375-7866 (717) 232-2207 * Montgomery * Barks, Chester, Schuylkill * Cumberland, Dauphin, Perry 1515 Market Street Suite 1325 Philadelphia, PA 19107 (215) 563-5665 * Bucks, Delaware, Montgomery, Philadelphia Chester Community Improvement Project 412 Avenue of the States PO Box 541 Chester, PA 19016 * Chester, Delaware, Montgomery, Philadelphia Community Action Agency of Delaware County 2nd and Orange Streets Media, PA 19063 610-891-5101 * Chester, Delaware, Montgomery Comm. on Econ Opportunity of Luzeme 163 Amber Lane Wilkes-Bane, PA 18702 (570) 826-0510 OR 1-800-822-0359 * Carbon, Luzeme, Schuylkill, Wyoming 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 * Adams, Cumberland, Franklin, Fulton, Perry Schuylkill Community Action Fayette Co. 225 N. Centre Street Community Action Agency Inc Pottsville, PA 17901 137 North Beeson Avenue (570) 622-1995 Uniontown, PA 15401 * Barks, Carbon, Lebanon, Lehigh, Luzeme (724) 437-6050 OR 1-800-427-INFO ' Northhampton, Schuylkill * Fayette, Somerset CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888-511-2227 * Adams, Cumberland, Dauphin, Franklin ' Perry, Snyder, York Maranatha The Trehab Center of Northeastern PA 144 E. East Avenue Wellsboro, PA 16901 (570) 724-5252 * Susequehanna o Fn ?y??? = c f A rn ?'J In the Court of Common Pleas of Cumberland County EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 Plaintiff vs. RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, PA 17050 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-2395 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 RACHEL MUKORA by default for want of an Answer. Assess damages as follows: $132,632.48 Debt Interest from 06/13/2007 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 CERTAIN FR HE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered t the p against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at leas ten da s prior t44ie date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. G Attorney for I.D. #16132 AND NOW Jud nt is entered in favor of EMC MORTGAGE CORPORATION and against RACHEL MUKORA by default for want Answer and damages assessed in the sum of $132,632.48 as per the above certification. XrthonPotar1y"ZL-)2 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 Plaintiff VS. RACHEL MUKORA (Mortgagors and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, PA 17050 Defendant(s) No. 07-2395 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 Prothonotary 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-1513 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. TO: RACHEL MUKORA 4706 Delbrook Road M biM PA 17050 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 Plaindff Vs. RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, PA 17050 Defendant(s) TO: RACHEL MUKORA 4706 Delbrook Road Mechanicgw& PA 17050 DATE OF THIS NOTICE:: May 29, 2007 IN THE COURT OF COMMON PLEAS of Cumberland County CML ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-2395 EM=RTANT NMTCT YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE TN vau nNG WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO TIM CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WrfHN 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 OTTER 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. LBGAL SERVICES INC 9 bvioe Raw Cad iSle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR AssociA l10N 2 LAx2ty Avmue Carlisle, PA 17013 1 B aseph A. Gokbeck, Jr.. Esq. Attamey f r Plemtiff Suite 5000- Melba MdVmdeace Ce nta 701 Market Street Philadelplria, PA 19106 215-627-1322 EMC-1513 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: May 29, 2007 TO: RACHEL, MUKORA 5041 Haverford Road Harrisburg, PA 17109 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 V9. RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, PA 17050 TO: RACHEL MUKORA 5041 Haverford Road Harrisburg, PA 17109 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE Term No. 07-2395 Defendant(s) IMPCIRTANT NCITICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAMED 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 WtI HN 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 WM-1 INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Raw Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avmw Carlisle, PA 17013 rln coan?i - ?.?L1?l?2eC?1' 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 undersigned, as the representative for 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, RACHEL MUKORA, is about unknown years of age, that Defendant's last known residence is 5041 Haverford Road, Harrisburg, PA 17109, 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 provisions of the Soldier of Congress of 1940 and its Amendments. Date: i" 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 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 vs. RACHEL MUKORA (Mortgagor(s) and Record owner(s)) 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS Plaintiff Defendant(s) of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 07-2395 ORDER FOR JUDGMENT Please enter Judgment in favor of EMC MORTGAGE CORPO ION, an against RACHEL MUKORA for failure to file an Answer in the above action within ( 20) d s (or sixty 60) days if a dart is the United States of America) from the date of service of the Complaint, in t sum of $ 32,632 j Joseph A. Gi Attorney for I hereby certify that the above names are correct and that the prec' resid creditor is EMC MORTGAGE CORPORATION PO Box 293150 Lewis I e, TX last known address(es) of the Defendant(s) is/are RACHEL MUKORA, 5'4 Hai 17109; [dress of the judgment and that the name(s) and RoHarrisburg, PA GOLDBECK McC FERTY McKEEVER BY: Joseph A. Gol beck, Jr. Attorney for Plaint ff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $118,583.56 Interest from 11/01/2006 through $6,498.24 06/12/2007 Reasonable Attorney's Fee $5,929.18 Late Charges $402.50 Costs of Suit and Title Search $900.00 Fees $319.00 AND NOW, this /.;4k day of ju'oe, 2007 damages are assessed as above. Pr rothy `?j? n ? ?. 0 ? ?p M -C W ?/. C7 N C'- _, --- ` 1?_ _ •- `?... PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 VS. Plaintiff IN THE COURT OF COMMON PLEAS RACHEL MUKORA Mortgagor(s) and Record Owner(s) 4706 Delbrook Road Mechanicsburg, PA 17050 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-2395 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 06/13/2007 to Date of Sale at 8.9300% (Costs to be added) $132,632.48 GOLDBECK McCAFFE McKEEVER BY: Joseph A. Goldbec Attorney for Plaintiff Y z >U z O ti- P4 o d ° w c'3 `o Mp ? °'ooo it Ica F,op d W ?q ? pG? oQ Uo a zH o ??? o o ti ?o o U ? ;aJ r-4 - rlo j ` v y \J LL? ;:a :.. V ? V ci Ln rn- V ICY- v ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected, situate in Hampden Township, Cumberland County, Pennsylvania, and described according to a Survey made by Gerick J. Betz, Registered Surveyor, dated November 10, 1972 as follows, to wit: BEGINNING at a hub on the south side of Del-Brook Road (50 feet wide), at the owner of Lot No.3, said point being measured along the said side of Del-Brook Road 249.50 feet West of the southwest corner of Del-Brook Road and St. Mark's Road; thence extending from said point of beginning and along the division line between Lots 3 and 4 South 23 degrees 00 minutes East the distance of 130 feet to a hub at the corner of lands now or formerly of B & k Realty; thence along lands now or formerly of B & K Realty South 67 degrees 00 minutes West the distance of 65 feet to a hub at the corner of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to hub at the corner of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub on the said side of Del-Brook Road; thence along said side of Del-Brook Road North 67 degrees 00 minutes East the distance of 65 feet to a point, the place of BEGINNING. BEING Lot No. 4 on Plan of St. Mark's Place, recorded in Plan Book 8, Page 8. BEING known as No. 4706 Del-Brook Road. UNDER AND SUBJECT NEVERTHELESS, to covenants, restrictions, reservations, conditions and rights of way of record. TAX PARCEL NO: 10-22-0527-062 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 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 VS. RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 07-2395 AFFIDAVIT PURSUANT TO RULE 3129 EMC MORTGAGE CORPORATION, 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: 4706 Delbrook Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): RACHEL MUKORA 5041 Haverford Road Harrisburg, PA 17109 2. Name and address of Defendant(s) in the judgment: RACHEL MUKORA 5041 Haverford Road Harrisburg, PA 17109 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 LONG BEACH MORTGAGE CO. 9451 CORBIN AVENUE r NORTHRIDGE, CA 91324 4. Name and address of the last recorded holder of every mortgage of record: CITIGROUP GLOBAL MARKETS REALTY C/O QUANTUM SERVICING 2 CORPORATE DRIVE, STE 350 SHELTON, CT 06484 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 4706 Delbrook Road Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the bes of my p oral knowle a or information and belief. I understand that false statements herein are made subject to th penalties f 18 Pa. C .Section 4904 relating to unworn falsification to authorities. DATED: June 12.2007 GOLDBECK MCCAFFER c4 BY: Joseph A. Goldbeck, , Esq. Attorney for Plaintiff ? n.3 c..a ' Q C ? -r1 " " ? ? ? ? ?? ' i-F y ? r ; r i C"7 f tt7 ...u.. "= E. r - ..... .? t C'i --i .. ??? - ?? . ? ti ?_ • % 07-2395 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 Plaintiff vs. RACHEL MUKORA Mortgagor(s) and Record Owner(s) 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-2395 Defendant(s' , 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: MUKORA, RACHEL RACHEL MUKORA 5041 Haverford Road Harrisburg, PA 17109 Your house at 4706 Delbrook Road, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, December 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $132,632.48 obtained by EMC MORTGAGE CORPORATION 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 EMC MORTGAGE CORPORATION, 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. 07-2395 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 r 07-2395 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: or 717-243-9400. 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 888-577-4011 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@gLoldbecklaw.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-1513. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. C`1? C J S i : ? ; ..? ?? C _} ?i ? ''"= • ?`- ??? ?- 07-2395 GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 vs. RACHEL MUKORA Mortgagor(s) and Record Owner(s) 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-2395 Defendant(s 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: MUKORA, RACHEL RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 Your house at 4706 Delbrook Road, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, December 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $132,632.48 obtained by EMC MORTGAGE CORPORATION 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 EMC MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311 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. 07-2395 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-2395 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: or 717-243-9400. 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 888-577-4011 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 homeretention(&,,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. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. c? ^' D WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-2395 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due EMC MORTGAGE CORPORATION, Plaintiff (s) From RACHEL MUKORA, (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 $132,632.48 L.L. $.50 Interest FROM 6/13/007 TO DATE OF SALE AT 8.9300% Atty's Comm % Due Prothy $2.00 Atty Paid $223.20 Plaintiff Paid Other Costs Date: JUNE 13, 2007 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Deputy Supreme Court ID No. 16132 SHERIFF'S RETURN - NOT FOUND CASF NO: 2007 02395 P COMMONTWEALTH F PENNSYLVANIA COUNTY OF CUMB RLAND EMC MORTGAGE CORPORATION MUKORA RACHEL R. Thomas Klin Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for th within named DEFENDANT MUKORA RACHEL but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MO T FORE , the within named DEFENDANT 4706 DELBROOK R] MECHANICSBURG, VA 17050 , MUKORA RACHEL NOT FOUND , as to 4706 DELBROOK R$AD IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge ,/a4/o 1 Sworn and Subscr me this d So answers: 18.00 -? r 9.60J 5.00 R. Thomas'Kline 10.00 Sheriff of Cumberland County .00 V 42.60 GOLDBECK MCCAFFERTY MCKEEVER 05/16/2007 bed to before y of , A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-P2395 P COMMONWEALTH O PENNSYLVANIA: COUNTY OF CUMB RLAND EMC MORTGAGE CPRPORATION S MUKORA RACHEL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry fo the within named DEFENDANT , to wit: MUKORA RACHEL but was unable to locate Her in his bailiwick. He therefore deputized the heriff of DAUPHIN serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On May 16th , 2007 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answer Docketing 6.00 Out of County 9.00 Surcharge 10.00 R. Thomas Klin Dep Dauphin County 35.25 Sheriff of Cumberland County Postage 1.35 61.60 ?/ 3/?9?a7 4,,? 5/16/2007 OLDBECK MCCAFFERTY MCKEEVER Sworn and subsc ibe to before me this da of A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania EMC Mortgage Corporation S. Rachel Mu ora No. 07-2395 civil Now, April P-6, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being ma a at the request and risk of the Plaintiff. Now, within upon at by handing to a copy of the original and made known to So answers, the contents thereof. Sworn and subscribe me this day of _ Sheriff of COSTS SERVICE $ 20 MILEAGE AFFIDAVIT County, PA Sheriff of Cumberland County, PA Affidavit of Service - , 20 , at o'clock M. served the off-ire of t4je,,S§4rrt-ff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth Of Pennsylvania County of AND NOW:iay 8, 2007 EMC MORTGAGE CORPORATION vs MUKORA RACHEL Sheriff's Return No. 0626-T - - -2007 OTHER COUNTY NO. 07 2395 CIVIL Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy at 9:37AM served the within NOTICE & COMPIAINT IN MORTG. FORECLOSURE upon MUKORA RACHEL by personally handing to RACHEL MUKgRA 1 true attested copy(ies) of the origin4l NOTICE & COMPLAINT IN MORTG. FORECLOSURE and making known to him/her th? contents thereof at DAUPHIN COUNTY SHERIFF OFFICE HARRISBURG, PA 17101-0000 Sworn and sub: before me this 10TH cribed to So Answers, ay of MAY, 2007 e Sheriff of Dauphin County, Pa. NOTARIAL S AL MARY JANE SNYDE Notary Public Highspire, Dauphi County My Commission Expire Sept. 1, 2010 Deputy Sheri f Sheriff's Costs:$35.25 PAID BY COUNTY REDMOND GOLDBECK McCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attornev for Plaintiff EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 VS. RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 No. 07-2395 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, David B. Fein, Esq., in support of its Motion for Substituted Service, represents as follows: Plaintiff is the holder of a first mortgage upon the premises 4706 Delbrook Road, Mechanicsburg, PA, 17050, hereinafter, the "mortgaged premises". 2. Defendant, RACHEL MUKORA, is the mortgagor and real owner of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, David Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant, Rachel Mukora, to request her concurrence. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 4. The last known address of Defendant, Rachel Mukora, is 5041 Haverford Road, Apt A, Harrisburg, PA 17109. 5. The Process Server has been unable to effect service of the Notice of Sale upon Defendant, Rachel Mukora, at the property, 4706 Delbrook Road, Mechanicsburg, PA, 17050. Per Process Server, the property is vacant. Service was also attempted, without success, at the last known address, 5041 Haverford Road, Apt A, Harrisburg, PA 17109. Per Sheriff, Defendant never returned the notice to the Sheriff's Office. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Rachel Mukora. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Rachel Mukora, by posting the premises and certified and regular mail to the Defendant's last known address. BY: vi m, Esq. r ' r Y Affidavit of Good Faith Investigation Client provided information: File Number: EMC-1513 Attorney Firm: Goldbeck, McCafferty & McKeever File Name: Mukora Subject Name: Rachel Mukora Property Address: Street: 4706 Delbrook Road City: Mechanicsburg State: PA Zip: 17050 Skip Results: Date of Birth: None Found ProVest File Number: 214089 Last Known Dates: As of 11 /02/2007 Street: 5041 Haverford Road, Apt A Phone: 717-526-6965 City: Harrisburg State: PA Zip: 17109 Death Records: As of 11 /02/2007, the Social Security Administration has no death record on file for Rachel Mukora. Social Security Number search completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Rachel Mukora as 5041 Haverford Road, Apt A, Harrisburg, PA 17109 Department of Motor Vehicle Records: The Pennsylvania Department of Motor Vehicles provided no change for Rachel Mukora from 5041 Haverford Road, Apt A, Harrisburg, PA 17109 Public Licenses (Pilot, Real Estate, etc): Search performed provided no information. Voter Registration Information: The County Voters Registration Office has no listing for Rachel Mukora. National Postal Address Search: Has no change for Rachel Mukora from 5041 Haverford Road, Apt A, Harrisburg, PA 17109 Comments: 717-526-6965: Number listed to Rachel Mukora at 5041 Haverford Road, Apt A, Harrisburg, PA 17109, there was no answer. 717-810-1991: Called possible neighbor, Hesan Shibeka, does not speak English. 717-541-8393: Called possible neighbor, R. Barrios, there was no answer. On 11/02/2007, I, Patti Garrett being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. -Above are the results of my investigation. Subscribed and sw om to before me, AW nt ?G(we-ti iNN PG!#1i Notory Publ Date: 11/02/2007 :** KIM ATTESERY ` ,r f= Notary Pubaa ` cF + SUM OF TEXAS `"Aenwh coffaw"on EXP Wi2-2111 t 09 r ' IF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA • AFFIDAVIT OF SERVICE EMC MORTGAGE CORPORATION RACHEL MUKORA Plaintiff (Petitioner) vs. Defendant (Respondent) CASE and/or DOCKET: 07 2395 I, PPYA G 14 ' FN declare that I am a Pennsylvania State Constable and/or Process Server, in and for the County of Berks, that I am not a party to this action, not an employee of a party to this action, or an attorney to the action, and that within the boundaries of the state where service was effected. I was authorized by law to perform the said service. SERVICE UPON: RACHEL MUKORA ADDRESS: 4706 DELBROOK ROAD MECHANICSBURG, PA 17050 On: At: Description: Approximate Age Height Weight Race Sex Hair With Documents: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Manner of Service By handing to: ? DEFENDANT(S) PERSONALLY SERVED ? ADULT FAMILY MEMBER WITH WHOM THE SAID DEFENDANT(S) RESIDES. NAME: RELATIONSHIP: ? ADULT IN CHARGE OF DEFENDANTS RESIDENCE. NAME: RELATIONSHIP: ? POSTED PROPERTY ? AGENT OR PERSON IN CHARGE OF PLACE OF BUSINESS. NAME: TITLE: ? MILITARY STATUS: NO / YES BRANCH: COMMENTS: DEFENDANT WAS NOT SERVED BECAUSE: MOVED UNKNOWN NO ANSWE OTHER: SERVICE WAS ATTEMPTED ON THE FOLLOWING DATES/TIMES: 1.) `IS YK2.) 3.) SWORN TO AND SUBSCRIBED BEF MET IS $ DAY OF d1Y , 2007 NOTARY CO fjy? E_fH_OF PErtrva?,=^'' r?,n X11'"! i SEAL TERE DIA {fir S [votary Public ?) go1S Pd ;, 1 BerkS COUlIty ?- ?? 'e ember 5 2009 PROVEST, LLC. P.O BOX 1180, 93 E MAIN STREET, BAY SHORE NY 11706 631.666.6168 (F) 631. / - P,//-\ lz??_ CO ABLE/PRO SS SERVER ` EMC Mortgage Corporation VS Rachel Mukora In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-2395 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 1139 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 Rachel Mukora located at 4706 Delbrook Road, 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: Rachel Mukora by regular mail to her last known address of 5041 Haverford Road, Harrisburg, PA 17109. This letter was mailed under the date of October 12, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff Bxj 8 o Real Estate ergeant GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY VS. RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 VERIFICATION No. 07-2395 I, David B. Fein, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service 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. BY: GOLDBECK McCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029, IN THE COURT OF COMMON PLEAS Of Cumberland County VS. RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 CERTIFICATE OF SERVICE No. 07-2395 David B. Fein, Esq., does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, Rachel Mukora, this 14th day of November, 2007, by first class mail, postage prepaid. , BY- David B. Fein, Esq. 0 4 f 0 tK 4 _ am .? - _ .: d ...- rte" NOV 192 00701 1 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 ORDER 07-2395 AND NOW, this Zjday of N©v 2007, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Rachel Mukora, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff's Sale upon Defendant, Rachel Mukora , by posting a copy of the Notice upon the premises 4706 Delbrook Road, Mechanicsburg, PA, 17050, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 5041 Haverford Road, Apt A, Harrisburg, PA 17109, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Rachel Mukora, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: D' trib ution list: ?Xlichael T. McKeever, Esquire, Suite 5000 - lion Independence Center, 701 Market Street P 'ladelphia, PA 19106-1532 ,XACHEL MUKORA, 4706 Delbrook Road Mechanicsburg, PA 17050 J CL Q 207 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 VS. RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 07-2395 ORDER AND NOW, this day of ?V. 2007, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Rachel Mukora, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff s Sale upon Defendant, Rachel Mukora , by posting a copy of the Notice upon the premises 4706 Delbrook Road, Mechanicsburg, PA, 17050, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 5041 Haverford Road, Apt A, Harrisburg, PA 17109, and that all further service of legal papers, including but not-lime - -s, CURTIS R. LONG Prothonotary Cumberland County one courthouse Square Carlisle, PA 17013 ?sF NOF? o S AMN WN-NWW .? • . f•.?.,..s fty a 'M? PITNEY BOWES ti 1A $ 00.41 • 02' t4E? ' 0004631598 NOV27 2C MAILED FROM Zip CODE 1 7C ?-3 9? GOLDBECK McCAFFERTY & McKEEVER BV- Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 Plaintiff VS. RACHEL MUKORA Mortgagor(s) and Record Owner(s) 4706 Delbrook Road Mechanicsburg, PA 17050 Defendant(s) EMC-1513 CF: 04/26/2007 SD: 02/06/2008 $132,632.48 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-2395 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 Office/competent adult (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 gkeriffr6ffnca'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). 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I a r H f (dO?*1Ok:) m ' m I N I r 0 rn r 0 r 0 rn r o n U In U In a, (n I I a .i y E I•? (1 I I •.I I N N N N N N ? m ? ? T? 1 F-l I a I In In In v, w a NOV 19 2007 ulr EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY VS. RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 07-2395 ORDER AND NOW, this rd day of of 2007, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Rachel Mukora, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendant, Rachel Mukora , by posting a copy of the Notice upon the premises 4706 Delbrook Road, Mechanicsburg, PA, 17050, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 5041 Haverford Road, Apt A, Harrisburg, PA 17109, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Rachel Mukora, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. Distribution list: Michael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 RACHEL MUKORA, 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS CUM$ERLAND COUNTY PENNSYLVANIA AFFIDAVIT OF SERVICE EMC MORTGAGE CORPORATION RACHEL MUKORA Plaintiff (Petitioner) VS. Defendant (Respondent) CASE and/or DOCKET: 07 2395 I, Eric M. UN Tf Cr- [&-4paC ., declare that I am a Pennsylvania State Constable and/or Process Server, in and for the County of Berks, that I am not a party to this action, not an employee of a party to this action, or an attorney to the action, and that within the boundaries of the state where service was effected. I was authorized by law to perform the said service. SERVICE UPON: RACHEL MUKORA ADDRESS: 4706 DELBROOK ROAD MECHANICSBURG, PA 17050 On: 1 S 0'7 At: Y? ??j pt,h'1 Description]: Approximate Age Height Weight Race Sex Hair With Documents: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Manner of Service By handing to: COMMENTS: ? DEFENDANT(S) PERSONALLY SERVED ? ADULT FAMILY MEMBER WITH WHOM THE SAID DEFENDANT(S) RESIDES. NAME: RELATIONSHIP: ? ADULT IN CHARGE OF DEFENDANTS RESIDENCE. NAME: RELATIONSHIP: X POSTED PROPERTY ? AGENT OR PERSON IN CHARGE OF PLACE OF BUSINESS. NAME: TITLE: MILITARY STATUS: NO / YES BRANCH: DEFENDANT WAS NOT SERVED BECAUSE: MOVED ,UNKNOWN NO ANSWER VACANT OTHER: SERVICE WAS ATTEMPTED ON THE FOLLOWING DATES/TIMES: 1.) 2.) 3.) SWORN TO AND SUBSCRIBED BEFORE ME THIS S DAY OF Dec.eAjoer- , 2007 1 ' Y `--? NOTARY COMMONWEALTH OF PENNSYLVAMA NOTARIAL SEAL TERESA A. MIN.ZOLA, Notary Public Washington Twp., Berks County My C i ' n !=x it [ er mber 9 fAA k_jP4 CONSTABLE/PROCESS SERVER ?L?509 PROVEST, LLC. P.O BOX 1180,93 E MAIN STREET, BAY SHORE NY 11706 631.666.6168 (F)631.666,6295 GOLDBECK MCCAFFERTY & McKEEVER -Bt 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 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 VS. RACHEL MUKORA Mortgagor(s) and Record Owner(s) 4706 Delbrook Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 Term No. 07-2395 EMC MORTGAGE CORPORATION, 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: 4706 Delbrook Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 LONG BEACH MORTGAGE CO. 9451 CORBIN AVENUE NORTHRIDGE, CA 91324 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIGROUP GLOBAL MARKETS REALTY C/O QUANTUM SERVICING 2 CORPORATE DRIVE, STE 350 SHELTON, CT 06484 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 4706 Delbrook Road Mechanicsburg, PA 17050 (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 unworn falsification to authorities. DATED: December 17, 2007 G DBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff pn r#?C- rn C:l r r-o COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which MAX & NINA MYERS is the grantee the same having been sold to said grantee on the 6TH day of FEB A.D., 2008, under and by virtue of a writ Execution issued on the 13 day of JUNE, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 2395, at the suit of EMC MTG CORP against RACHEL MUKORA is duly recorded as Instrument Number 200805471. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this (a/ -Z?e day of A.D. i Recorder of Deeds y Of JWL 2010 EMC Mortgage Corporation In the Court of Common Pleas of VS Cumberland County, Pennsylvania Rachel Mukora Writ No. 2007-2395 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 1139 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 Rachel Mukora located at 4706 Delbrook Road, 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: Rachel Mukora by regular mail to her last known address of 5041 Haverford Road, Harrisburg, PA 17109. This letter was mailed under the date of October 12, 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 February 6, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $100,000.00 to Rev. Max Myers. It being the highest bid and best price received for the same, Rev. Max Myers, of 5015 Ravenwood Road, Mechanicsburg, Pennsylvania 17055, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $104,948.14. Sheriff s Costs: Docketing $30.00 Poundage 2,000.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 11.52 Levy 15.00 Surcharge 20.00 Post Pone Sale 20.00 Law Journal 355.00 Patriot News 314.69 Share of Bills 14.92 ' Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $2,936.13 ? ??a7?bq ?, So Answer • 4 R. Thomas Kline, Sheriff 0- BY 0 Real Estate rgeant ? C?r Co 'j 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 EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 VS. RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 07-2395 AFFIDAVIT PURSUANT TO RULE 3129 EMC MORTGAGE CORPORATION, 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: 4706 Delbrook Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): RACHEL MUKORA 5041 Haverford Road Harrisburg, PA 17109 2. Name and address of Defendant(s) in the judgment: RACHEL MUKORA 5041 Haverford Road Harrisburg, PA 17109 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 LONG BEACH MORTGAGE CO. 9451 CORBIN AVENUE NORTHRIDGE, CA 91324 4. Name and address of the last recorded holder of every mortgage of record: CITIGROUP GLOBAL MARKETS REALTY C/O QUANTUM SERVICING 2 CORPORATE DRIVE, STE 350 SHELTON, CT 06484 r 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 4706 Delbrook Road Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the bes of my p onal knowl a or information and belief. I understand that false statements herein are made subject to thpenalties f 18 Pa. C . Section 4904 relating to unsworn falsification to authorities. DATED: June 12, 2007 GOLDBECK MCCAFFER &4 BY: Joseph A. Goldbeck, ., Esq. Attorney for Plaintiff 07-2395 GOLDBECK MCCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff EMC MORTGAGE CORPORATION PO Box 293150 Lewisville, TX 75029 Plaintiff VS. RACHEL MUKORA Mortgagor(s) and Record Owner(s) 4706 Delbrook Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-2395 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: MUKORA, RACHEL RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 Your house at 4706 Delbrook Road, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, December 05, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $132,632.48 obtained by EMC MORTGAGE CORPORATION 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 EMC MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311 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. 07-2395 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The tooner 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-2395 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: or 717-243-9400. 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 888-577-4011 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,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. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-2395 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due EMC MORTGAGE.CORPORATION, Plaintiff (s) From RACHEL MUKORA, ' (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the 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 $132,632.48 L.L. $.50 Interest FROM 6/13/007 TO DATE OF SALE AT 8.9300% Atty's Comm % Due Prothy $2.00 Atty Paid $223.20 Other Costs Plaintiff Paid Date: JUNE 13, 2007 (Seal) Curtis R. Long, Prothonotary 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 Real Estate Sale # 20 On August 7, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 4706 Delbrook Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 7, 2007 By: I Real Estate ergeant SCHEDULE OF DISTRIBUTION SALIE NO. 20 Date Filed: February 14, 2008 Writ No. 2007-2395 Civil Term EMC Mortgage Corporation VS Rachel Mukora 4706 Delbrook Road Mechanicsburg, PA 17050 Sale Date: Buyer: Bid Price: Real Debt: Interest: Attorney V Total: DISTRIBUTION: February 06, 2008 Rev. Max Myers $100,000.00 $132,632.48 7,723.10 Irit Costs: 223.20 $140,578.78 Receipts: Cash on account (08/07/2007): Cash on account (02/06/2008): Cash on account (02/11/2008): Total Receipts: $ 1,500.00 10,000.00 94,948.14 $106,448.14 Disbursements: Sheriffs Costs Legal Search Transfer Tax, Local Transfer Tax, State Cumberland Co Tax Claim Bureau Marie Huber, Tax Collector Hampden Township Municipal Lien No. 2007.3967 Hampden Township Judgment No. 2007-5787 Civil Term Hampden Township (sewer and refuse) Attorney Joseph Goldbeck EMC Mortgage Corporation Total Disbursements: Balance for distribution: So Answers: $2,936.13 300.00 1,324.07 1,324.07 1,169.37 281.31 1,146.37 100.75 1,026.82 1,500.00 95,339.25 ($106,448.14) 0.00 R. Thomas Kline Sheriff SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Stteet Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale No. 20, held February 6, 2008 EFFECTIVE DATE: January 31, 2008 PREMISES: 4706 Delbrook Road (also sometimes referred to as Del-Brook Road), Hampden Township, Cumberland County, Pennsylvania, Lot No. 4 of the Plan of St. Mark's Place, Plan Book 8, Page 8, Tax Parcel No. 10-22-0527-062 (the "Premises") RECITAL: Being the same premises which Bonite LLC, a PA limited liability company by its Deed dated April 18, 2005 and recorded April 25, 2005 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 268, Page 2765, granted and conveyed unto Rachel Mukora, an adult individual. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2008. 20. Subject to the spousal rights, if any, of any spouse of Rachel Mukora. -2- 21. Mortgage in the amount of $22,000.00 from Mabel O. Rupp to Allfirst Bank dated November 20, 2002 and recorded December 19, 2002 in Mortgage Book 1788, Page 783. 22. Mortgage in the amount of $104,000.00 from Rachel Mukora to Long Beach Mortgage Company dated April 18, 2005 and recorded Apri125, 2005 in Mortgage Book 1904, Page 3436, assigned May 8, 2007 in Misc. Book 736, Page 3581 to EMC Mortgage Corporation. 23. Mortgage in the amount of $26,000.00 from Rachel Mukora to Long Beach Mortgage Company dated April 18, 2005 and recorded April 25, 2005 in Mortgage Book 1904, Page 3444, assigned December 27, 2006 in Misc. Book 733, Page 204 to Citigroup Global Markets Realty. 24. Judgment against Rachel Mukora in favor of Long Beach Mortgage Company in the amount of $118,141.16 entered February 28, 2006 to No. 2006-288 with respect to the Mortgage recorded in Mortgage Book 1904, Page 3436. 25. Judgment against Rachel Mukora in the amount of $132,632.48 in favor of EMC Mortgage Corporation entered June 13, 2007 to No. 2007-2395 with respect to the Mortgage recorded in Mortgage Book 1904, Page 3436. 26. Municipal Lien entered against Rachel Mukora in favor of Hampden Township in the amount of $949.37 entered June 29, 2007 to No. 2007-3967. 27. Judgment against Rachel Mukora in the amount of $1,020.89 in favor of Hampden Township entered October 3, 2007 to No. 2007-5787. 28. Real Estate taxes due Cumberland County Tax Claim Bureau in the amount of $1,163.37, together with possible additional accrued interest, penalties and costs. 29. All building setback lines, easements, notes, conditions and all other matters appearing on the Plan of St. Mark's Place recorded in Plan Book 8, Page 8 and any unrecorded survey of Gerick J. Betz, R.S., dated November 10, 1972. 30. Subject to the sewer right-of-way agreement recorded in Misc. Book 188, Page 502. 31. Subject to the 25-foot drainage easement across the rear of the subject Premises as noted in Deed Book F, Volume 19, Page 139. 32. Subject to the terms and conditions of the Agreement recorded in Misc. Book 140, Page 325. 33. Subject to the rights granted PPL, Bell or Bell of Pennsylvania in Misc. Book 123, Page 271. -3- 34. Subject to the rights granted Bell or Bell of Pennsylvania in Misc. Book 96, Page 534 and Misc. Book 120, Page 523. 35. Subject to the rights of ingress, egress and regress as noted in Deed Book Y, Volume 15, Page 380. 36. Subject to the rights of others in and to any portion of the Premises lying within or adjoining Delbrook Road, also known as Del-Brook Road. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -4- REAL ESTATE SALE NO. 20 Writ No. 2007-2395 Civil EMC Mortgage Corporation vs. Rachel Mukora Atty.: Joseph Goldbeck DESCRIPTION ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected, situate in Hampden Township, Cumberland County, Pennsylvania, and described according to a Survey made by Gerick J. Betz, Registered Surveyor, dated November 10, 1972 as follows, to wit: BEGINNING at a hub on the south side of Del-Brook Road (50 feet wide), at the owner of Lot No. 3, said point being measured along the said side of Del-Brook Road 249.50 feet West of the southwest corner of Del-Brook Road and St. Mark's Road; thence ex- tending from said point of beginning and along the division line between Lots 3 and 4 South 23 degrees 00 minutes East the distance of 130 feet to a hub at the corner of lands now or formerly of B & K Realty; thence along lands now or formerly of B & K Realty South 67 degrees 00 minutes West the distance of 65 feet to a hub at the corner of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub at the corner of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub on the said side of Del-Brook Road; thence along said side of Del-Brook Road North 67 degrees 00 minutes East the distance of 65 feet to a point, the place of BEGINNING. BEING Lot No. 4 on Plan of St. Mark's Place, recorded in Plan Book 8, Page 8. BEING known as No. 4706 Del- Brook Road. UNDER AND SUBJECT NEVER- THELESS, to covenants, restrictions, reservations, conditions and rights of way of record. TAX PARCEL NO: 10-22-0527- 062. EXHIBIT A The Patriot-News Co. • 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE Z4( Pdt1""0t'WX(W5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 This ad ran on the date(s) shown below: 10/24/07 10/31/07 11/07/07 Sworn to an scribed b f e me this 30 day of November, 2007 A.D. J N tary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal James L Clan. Notary Public CRY Of HarftWrg, Dauphin County My CommWbi E)pres June 2, 2008 Member, Pennsylvenis Assoclatlon of NotUrles ..... ..... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW. JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9, 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. Coyne, SWORN` 0 AND SUBSCRIBED before me this 9 day of November, 2007 Notary SEAL F OTARIAL RAH A COLLINS otary Public O, CUMBERLAND COUNTY ion Expires Apr 28, 2010 REAL ESTATE MLE NO. 20 Writ No. 2007-2395 Civil EMC Mortgage Corporation VS. Rachel Mukora Atty.: Joseph Goldbeck DESCRIPTION ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected, situate in Hampden Township, Cumberland County, Pennaylvania, and described according to a Survey made by Gerick J. Betz, Registered Surveyor, dated November 10, 1972 as follows, to wit: BEGINNING at a hub on the south side of Del-Brook Road (50 feet wide), at the owner of Lot No. 3, said point being measured along the said side of Del-Brook Road 249.50 feet West of the southwest comer of Del-Brook Road and St. Mark's Road; thence ex- tending from said point of beginning and along the division line between Lots 3 and 4 South 23 degrees 00 minutes East the distance of 130 feet to a hub at the corner of lands now or formerly of B & K Realty; thence along lands now or formerly of B & K Realty South 67 degrees 00 minutes West the distance of 65 feet to a hub at the corner of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub at the comer of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub on the said side of Del-Brook Road; thence along said side of Del-Brook Road North 67 degrees 00 minutes East the distance of 65 feet to a point, the place of BEGINNING. BEING Lot No. 4 on Plan of St. Mark's Place, recorded in Plan Book 8, Page 8. BEING known as No. 4706 Del- Brook Road. UNDER AND SUBJECT NEVER- THELESS, to covenants, restrictions, reservations, conditions and rights of way of record. TAX PARCEL NO: 10-22-0527- 062.