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Home My WebLink About07-2797GOLDBECK 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 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST Mortgagor and Real Owner 1220 Pine Road Carlisle, PA 17013 Defendant Term a7- a7y? C?J CIVIL ACTION: MORTGAGE ;Z()tI!CL_C '1 mr- 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 866-296-8937 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@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 WM-1223. 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 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, 9451 Corbin Avenue, Northridge, CA 91324. 2. The names and addresses of the Defendant is LORIE L. YOST, 1220 Pine Road, Carlisle, PA 17013, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On January 31, 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 1896, Page 57. 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 ..................................................................................$115,014.50 Interest from 11/01/2006 through 05/31/2007 at 8.0000% .......................$5,342.39 Per Diem interest rate at $25.20 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$5,750.73 Late Charges from 12/01/2006 to 05/31/2007 ..........................................$1,140.60 Monthly late charge amount at $51.51 Costs of suit and Title Search ...................................................................... $900.00 Fees ................................................................................................................$74.80 NSF Charges ..................................................................................................$30.00 Suspense ..................................................................................................... -$550.14 $127,702.88 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $127,702.88, together with interest at the rate of $25.20, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: DBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF .. VERIFICATION I , Chris Anderson , 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: cr-- l 07 /"-x 1 1 Washington Mutual Bank, as Successor-in- Interest to Long Beach Mortgage Company by Operation of Law. Chris Anderson - AVP #0666779905 - LORIE L. YOST E.rhibitA SCHEDULE A CONTINUED ALL that oatain house end lot of Wound situate in Dickinson Township, Cumberland County, Pmnsylvm* bounded and described as follows: MaNNM U a point in the curter line of Pine Mosel, also known a Legislative hoot 21001; thence along Inds off .irl6er R Nevm and Tekh A. Neviw, bu wife, Sou& l l degrees 06 rieiI 51 seoads East 331.96 fimtlospoint; thence slang lards now or forromiy of Vernon Dye, SmA S6 depm 14 nrioieles S7 secards Wass 89.79 inset to a shot thence by odrer lads of the acid Larry L. Watnerr raid Jonietts E. Wanner. his wife, North 13 degrees 37 minutes 02 seconds Weet 32531 feet to a point in the center line of the aforesaid Pine Road; thence along said IF line, North 55 deWas 49 minutes 56 seconds East 105.52 fat to a point, the Place of BEGUMM. CONTARM40 0.685 saes. SAID premises laving thereon erected a ranch styledwelling house. SAlb premises at described aeeordaeg to a Subdivision Phu of Larry V. Ncidlinga, P.E., at Lot No. 3, isoordp in the Office of the Recorder of Dads in and for C ambaland County in Plan Book 25, Page 148. The premises are conveyed subject to on ultimate ri* of way line existing 25 fat southwadly from the center line of said Piers Road as the am appeas an said Plan. UNDBR AND SUBJECT, NEVERTHPI.ESS to the following restrictions: 1. That no mobile home or trader: shad be pieced an flee pranises basin conveyed BEM Ste same propety with Otis H. Stevppt and bnd& N. Stevbm his wife, Wanted std conveyed to Stephen N. Martin and Susm B. Martin, his wife, by dead ddod Ano* 26.1983 and teoa IF an August 26.1983 in the Office of the Recorder of Duds for Qimberlmd County in Deed Book 'r. Volume 30, Page 773. Sd dule "A" Goolio led - Ccasailmmr No, 11417.1 E.rtFiidit (B . .01 Washington Mutual PO Box 2441 Mailstop N010207 Chatsworth, CA 91313-2441 February 28, 2007 LORIE L YOST 1220 PINE RD CARLISLE PA 17013 11111111111111111111111 0666" 7100 4047 5100 3858 4078 000044 /PC WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0666779905 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. SP999 ' r HOMEOWNER'S NAME(S): Lorie L. Yost PROPERTY ADDRESS: 1220 Pine Rd Carlisle PA 17013 LOAN ACCT. NUMBER: 0666779905 ORIGINAL LENDER: Lbm CURRENT LENDERISERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses. and telephone numbers of designated cons um r credit counseling agencies for the county in which the property is looted are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE. ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your 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 your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) 000044/SP999 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). - The MORTGAGE debt held by the above lender on your property located at: 1220 Pine Rd Carlisle PA 17013 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 12/01!2006 $856.86 01/01/2007 $856.86 02/01/2007 $856.86 Other charges (explain/itemize): Uncollected Late Charges $1028.20 Uncollected Fees: $47.80 Corporate advances $0.00 Less Credits $550.14 TOTAL AMOUNT PAST DUE: $3096.44 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3096.44, PLUS ANY MORTGAGE PAYMENTS AND LATE 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 and sent to: Washington Mutual Bank 9451 Corbin Avenue Northridge, CA 91324 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURE THE D .FA 1LT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise ite rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose anon your mortgaged property. *IF THE MORTGAGE L.a FOREcngED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY period you will not be required to pay attorney's fees. OTHER ..ND .R REMEDIES. - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. SP999 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 may still have the right to cure the default and pr v nt the sale at ny time up to one hour the lender and bynerforminp, 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. SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property F ==' i1OT POSSIBLE could be held would be approximately 9 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. Name of Lender: Washington Mutual Bank Address: 9451 Corbin Avenue Northridge, CA 91324 Phone Number: 1-888-852-1745 Fax Number: 1-818-775-6260 Contact Person: Collection Department Email Address: www.wamuhomeloans.com EFFECTS OF SHERIFF'S SALE: - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE 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, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. SP999 j o SHERIFF'S RETURN - REGULAR CASE NO: 2007-02797 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS YOST LORIE L WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon YOST LORIE L the DEFENDANT at 1747:00 HOURS, on the 16th day of May , 2007 at 1220 PINE ROAD CARLISLE, PA 17013 by handing to LORIE L YOST a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.56 Affidavit .00 Surcharge 10.00 .00 SJ3,1 a 1 6" / 3 8. 5 6 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 05/17/2007 GOLDBECK MCCAFFERTY MCKEEVER By:? Deputy Sheriff A. D. In the Court of Common Pleas of Cumberland County WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-2797 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 LORIE L. YOST by default for want of an Answer. Assess damages as follows: Debt Interest from 06/18/2007 to Date of Sale Total (Assessment of Damages attached) $128,207.99 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered t the p y aga" t whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at leas ten d r VpI to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. Gold Y. Attorney for Pl n I.D. #16132 AND NOW J1jA--)P- .2/ ?Q(> 7 dgment " entered in favor of WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST O LONG BEAC GAGE COMPANY BY OPERATION OF LAW and against LORIE L. YOST by default for want of an Answer and damages assessed in the sum of $128,207.99 as per the above certification. Pro onota I- Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff No. 07-2797 VS. LORIE L. YOST (Mortgagors and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothono 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 A WM-1223 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: June 6, 2007 TO LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) TO: LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-2797 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 7n_cv_n 9 Gor AOCIGNO.X 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, LORIE L. YOST, is about unknown years of age, that Defendant's last known residence is 1220 Pine Road, Carlisle, PA 17013, 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: 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 WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST (Mortgagor(s) and Record owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 07-2797 ORDER FOR JUDGMENT Please enter Judgment in favor of WASHINGTON MUTUAL B , TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, and failure to file an Answer in the above action within (20) days (or sixty (60) ays if of America) from the date of service of the Complaint, in the sum of $128, 07.99. Joseph A. Gi Attorney for I hereby certify that the above names are correct and that the r creditor is WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin. name(s) and last known address(es) of the Defendant(s) is/are LORIE 17013; GOLDBECK McCl BY: Joseph A. Gold Attorney for Plaintiff ESSOR-IN-INTEREST LORIE L. YOST for nt is the United States ;nce a dre of the judgment TO L BEACH thrid CA 91324 and that the ?2 a Road Carlisle, PA Jr. McKEEVER ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 11/01/2006 through 06/18/2007 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Fees NSF Charges Suspense $115,014.50 $5,795.99 $5,750.73 $1,192.11 $900.00 $74.80 $30.00 -$550.14 $128,207.99 GOLDBECK MCCAFFE & McKEEVER BY: Joseph A. Goldbec r. Attorney for Plaintiff AND NOW, this 21 day ofd, 2007 damages are 11?w Pro rothy rCJ ? ?' O ,?.? -n C -:?-; 4-? ?? `? .a ?(? ?? n r„ =rte ? ? ? ,? PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW LORIE L. YOST ACTION OF MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 No. 07-2797 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 06/18/2007 to Date of Sale at 8.0000% (Costs to be added) $128,207.99 O O d a UO U d LY. (y Vl b ? ? (, y ?? OO ? v?r" H O r4 > `fi b P. a° CoU W ?o m ae H o ¢W? ?^mN? C ? W ZO W x ZO OF '? " o ` L_?' 1 t 1 tj- I^ o .b} i? ?. I U' 'mod O d CJ -? u br d ? a o y N ^ G ? ? r a? ?..? yG cd N v F. ? o a• 0 b? ?n CT' C,? ALL that certain house and lot of ground situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows; BEGINNING at a point in the center line of Pine Road, also known a Legislative Rout 21008; thence along lands of Luther R Nevius and Telata A. Nevius, his wife, South 11 Degrees 06 minutes 51 seconds East 331.96 feet to a point; thence along lands now or formerly of Vernon Dye, South 56 degrees 14 minutes 57 seconds West 89.79 feet to a stake; thence by other lands of the said Larry L. Warner and Jonietta E. Warner, his wife, North 13 degrees 37 minutes 02 seconds West 325.51 feet to a point in the center line of the aforesaid Pine Road; thence along said center line, North 55 degrees 49 minutes 56 seconds East 105.52 feet to a point, the Place of BEGINNING. CONTAINING 0.685 acres. TAX PARCEL NO: 08-12-0334-082 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-2797 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, Plaintiff (s) From LORIE L. YOST (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 $128,207.99 L.L. $.50 Interest FROM 6/18/07 TO DATE OF SALE AT 8.0000% Atty's Comm % Due Prothy $2.00 Atty Paid $157.56 Other Costs Plaintiff Paid Date: JUNE 21, 2007 (Seal) Curds R. Lo onota By: REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Deputy Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 07-2797 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, 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: 1220 Pine Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 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 IN THE COURT OF COMMON PLEAS 4. Name and address of the last recorded holder of every mortgage of record: 1*1 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 1220 Pine Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the be t of my ersonal knowledge or information and belief. I understand that false statements herein are made subject to the enalti of 18 Pa.,C.S. Section 4904 relating to unworn falsification to authorities. DATED: June 18, 2007 GOLDBECK MCCAF E & cKEEVER BY: Joseph A. Goldb ck r., Esq. Attorney for Plainti n ? ---? , c? .?- -; , r __._ ; . a .?? ' r.3 =? ? _?. 07-2797 10 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 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 Defendant(s; Term No. 07-2797 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: YOST, LORIE L. LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 Your house at 1220 Pine Road, Carlisle, PA 17013 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 $128,207.99 obtained by WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 07-2797 1. The sale will be cancelled if you pay to WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 -V 07-2797 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 866-296-8937 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(i4goldbecklaw.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 WM-1223. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL that certain house and lot of ground situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows; BEGINNING at a point in the center line of Pine Road, also known a Legislative Rout 21008; thence along lands of Luther R Nevius and Telata A. Nevius, his wife, South 11 Degrees 06 minutes 51 seconds East 331.96 feet to a point; thence along lands now or formerly of Vernon Dye, South 56 degrees 14 minutes 57 seconds West 89.79 feet to a stake; thence by other lands of the said Larry L. Warner and Jonietta E. Warner, his wife, North 13 degrees 37 minutes 02 seconds West 325.51 feet to a point in the center line of the aforesaid Pine Road; thence along said center line, North 55 degrees 49 minutes 56 seconds East 105.52 feet to a point, the Place of BEGINNING. CONTAINING 0.685 acres. TAX PARCEL NO: 08-12-0334-082 C? c t?. _...s ,,._y s , ??; Y; ??' ?? `? `£ N GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff vs. LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 Defendant Docket No. 07-2797 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY J*46 1 ;v GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 Attorney for Plaintiff WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 Defendant Docket No. 07-2797 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE n °" Washington Mutual Bank, as Successor-in-Interest In The Court of Common Pleas of To Long Beach Mortgage Company by Operation Cumberland County, Pennsylvania Of Law Writ No. 2007-2797 Civil Term VS Lorie L. Yost R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Joseph Goldbeck. Sheriff s Costs: Docketing $30.00 Poundage 289.91 Law Library .50 Prothonotary 2.00 Levy 15.00 Share of Bills 14.92 Surcharge 20.00 $372.33 l zj b(, l So e R. Thomas Kline, Sheriff B 16AM?LV Real Estate ergeant "?, 51:?' Ctl `0?-7-7 PLZ'Irl 1 2016, a 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 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 07-2797 AFFIDAVIT PURSUANT TO RULE 3129 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, 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: 1220 Pine Road Carlisle, PA 17013 I.Name and address of Owner(s) or Reputed Owner(s): LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: P 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 1220 Pine Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the be of my ersonal knowledge or information and belief. I understand that false statements herein are made subject to the enalti of 18 Pa S. Section 4904 relating to unworn falsification to authorities. DATED: June 18, 2007 GOLDBECK MCCAF E & cKEEVER BY: Joseph A. Goldb ck r., Esq. Attorney for Plainti 07-2797 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 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 9451 Corbin Avenue Northridge, CA 91324 Plaintiff VS. LORIE L. YOST Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 Defendants Term No. 07-2797 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: YOST, L.ORLE L.. LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 Your house at 1220 Pine Road, Carlisle, PA 17013 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 $128,207.99 obtained by WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL, ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 07-2797 1. The sale will be cancelled if you pay to WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-2797 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 maybe 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 866-296-8937 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 homeretentionagoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of WM-1223. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL that certain house and lot of ground situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows; BEGINNING at a point in the center line of Pine Road, also known a Legislative Rout 21008; thence along lands of Luther R Nevius and Telata A. Nevius, his wife, South 11 Degrees 06 minutes 51 seconds East 331.96 feet to a point; thence along lands now or formerly of Vernon Dye, South 56 degrees 14 minutes 57 seconds West 89.79 feet to a stake; thence by other lands of the said Larry L. Warner and Jonietta E. Warner, his wife, North 13 degrees 37 minutes 02 seconds West 325.51 feet to a point in the center line of the aforesaid Pine Road; thence along said center line, North 55 degrees 49 minutes 56 seconds East 105.52 feet to a point, the Place of BEGINNING. CONTAINING 0.685 acres. TAX PARCEL NO: 08-12-0334-082 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-2797 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, Plaintiff (s) From LORIE L. YOST (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 $128,207.99 L.L. $.50 Interest FROM 6/18/07 TO DATE OF SALE AT 8.0000% Atty's Comm % Due Prothy $2.00 Atty Paid $157.56 Other Costs Plaintiff Paid Date: JUNE 21, 2007 Curti Long notary (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 27 On August 7, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA Known and numbered as 1220 Pine Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference n incorporated herein. Date: August 7, 2007 By: jj ?J Real Esta Sergeant '1 ? Z CJ b-7 9"{i F "661