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Home My WebLink About07-3727GOLDBECK 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 0-7- 3727 e'LU?C-a?-n ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. STEPHEN D. TUCKER JEAN E. TUCKER Mortgagors and Real Owners 1 Queen Anne Court Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Defendants Term No. CIVIL ACTION: IVIOHTGAGE 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 AV190 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, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 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 800-211-6926 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 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 53364FC. 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 Plaintiff is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 10801 6th Street, Suite 130 Rancho Cucamonga, CA 91730. 2. The names and addresses of the Defendants are STEPHEN D. TUCKER, 1 Queen Anne Court, Camp Hill, PA 17011 and JEAN E. TUCKER, 1 Queen Anne Court, Camp Hill, PA 17011, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. Defendant, THE UNITED STATES OF AMERICA, is named a Defendant pursuant to 28 U.S.C. Section 2410, and Plaintiff requests that a judicial sale be held of the Property. 4. On July 11, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to ARGENT MORTGAGE COMPANY, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1826, Page 1766. The mortgage has been assigned to: WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 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. 5. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 6. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for February 01, 2007 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. 7. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$138,588.12 Interest from 01/01/2007 through 06/30/2007 at 10.9000% .....................$7,594.76 Per Diem interest rate at $41.96 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,929.41 Late Charges from 02/01/2007 to 06/30/2007 .............................................$430.00 Monthly late charge amount at $86.00 Costs of suit and Title Search ......................................................................$900.00 Fees ................................................................................................................$87.00 Recoverable Balance ......................................................................................$17.00 Escrow .........................................................................................................$280.05 Monthly Escrow amount $638.89 $154,266.24 8. 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. 9: Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have 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. 10. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants 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 Defendants 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 Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. 11. THE UNITED STATES OF AMERICA, the above named Defendant, has a lien filed of record, set forth in Exhibit `C' which is attached and made part of this Complaint. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $154,266.24, together with interest at the rate of $41.38, 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: A . G BE K McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, KELLY RADER, 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 8 Pa. S. 4904 relating to unworn falsification to authorities. Date: #0048939706 - STEPHEN D. TUCKER and JEAN E. TUCKER E.rihibitA All that certain lot or tract of land situate in Bast Pemnsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the Northern right-of-way line of Queen Anne Court as the dividing line of Lot No. 16 and Lot No. 17 as shown on a Final Subdivision Plan of Victoria Glen Section 11; thence by aforementioned dividing line North 06 degrees 30 minutes 10 seconds East 162.13 feet to a point on line of land now or formerly of'Ridley Park recorded in Deed Book N, Volume 19, Page 559; thence by aforementioned lands North 79 degrees 53 minutes 56 seconds East 49.00 feet to a point on the dividing line of Lot No. 15 and Lot No. 16; thence by aforementioned dividing line South 09 degrees 19 minutes 57 seconds East 164.59 feet to a point on the northern right-of-way line of Victoria Way; thence by aforementioned right-of-way line by a curve to the left having a radius of 200.00 feet an arc length of 23.53 feet to a point; thence by same by a curve to the right having a radius of 15.00 feet an arc length of 21.46 feet to a point on the northern right-of-way line of Queen Anne Court; thence by aforementioned right-of-way line North 71 degrees 51 minutes 30 seconds West 66.89 feet to a point being the place of Beginning. Being Lot No. 16 as shown.on a Final Subdivision Plan of Victoria Glen Section U, recorded in Plan Book 49, Page 49. Tax ID #: 09-17-1042-187 ?'i C)26PG 1782 Eythibit B ...._ 1II91111111SNI911allydl11 Santa Ana, CA 92711-ION 7182 6389 3060 0995 3162 STEPHEN D TUCKER JEAN E TUCKER 1 QUEEN ANNE CT CAMP HILL, PA 17011 "MORTGAGE SERVICES April 03, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE AVISO: Este documento explica Como los propietarios de casas pueden evitar perder sus hogares debido a demoras de pagos. Para information en espaHol flame a su prestamista. STATEMENTS OF POLICY Loan Number: 0048939706 Property Address: 1 QUEEN ANNE, CAMP HILL PA, 17011 Original Lender: AMC Mortgage Services, Inc. Current Lender/Servicer: AMC Mortgage Services, Inc. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help you most MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-500-342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SII CASA. SI NO COMPRENDE EL CONTENEDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO na W.W -„ Also doing business as Delaware AMC Mortgage Services, Inc., in the states of Texas, Rhode Island, and New Hampshire 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. 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: z 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 z 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 NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set 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 a default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If yon 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 WELL 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. [r'do,4-)2-os April 03, 2007 Loan Number: 0048939706 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. Qf you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it no to date). NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property located at: 1 QUEEN ANNE, CAMP HILL, PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 02101/07 thru 04101/07 Minimum Payments plus late charge or other fees: $5189,94 Minimum Amount to Care Default: $5189.94 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not an if not applicable): NIA 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 55189,94 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payment mum be made either by cash, cashier's check certified check or money order made payable and semi IQ: AMC Mortgage Services P.O. Box 5926 Carol Stream, IL 60197-5926 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) N/A IF YOU DO NOT CURE THE DEFAULT--If you do not care the default within THIRTY (30) DAYS of the date of this Notice, the leader intends to exercise its rights to accelente the mortgage debt, This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged roe IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriffto 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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you care the default within the THIRTY (,M DAY per, you will not be required to pay attorneyy_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 riglu to cure the default andprev° * the sale at any 'me up to one hour before the Sheriffs Sale You may do so paying the minimum amomt then past due, plus any late or other charges then due reasonable attoraeys fees and costs connected with the foreclosure salt and any other costs connected with the Sheriff s Sale as specified in wrW" by the leader and by ,rovoW-)1-o, performing any other requirements under the mortgage. Caring your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: AMC Mortgage Services PO Box 11000 Santa Ana, CA 92711-1000 Phone Number 800-430-5262 Fax Number 714-347-5037 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the Property after the Sheriff s 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 aot (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: x 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. z TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. z 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.) z TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, z 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 If you need additional assistance or counseling you may also find a Housing Counseling Agency in your area by calling Toll-free (800) 5694287 or TDD (800) 877-8339. AMC Mortgage Services Cc: AMC Mortgage Services Attn: Collections Department Lou Number: 0048939706 Mailed by 1st Class Mail and by Certified Mail Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1-800-342-2397 Eyt hibit C jft Liberty Bell Agency, Inc. 701 Market Street, Mellon Independence Center - Suite 5001, Philadelphia, PA 19106 AfP6 (215) 625-3660 ? FAX: (215) 625-3689 Thursday, June 14, 2007 FORECLOSURE REPORT Order #: LBA-28622 THIS SEARCH COVERS THE PERIOD TO: 06/04/2007 PREMISES: 1 Queen Anne Court, Camphill, PA, 17011 PARCEL NUMBER(s): TAX ASSESSMENT(s): 09-17-1042-187 2007 $165,350.00 OWNER OF RECORD: Stephen D Tucker and Jean E Tucker, husband and wife by deed from The Homestead Group Inc. Dated: 8/3/87 and recorded: 8/6/87 in Book 32-V page 866 FEDERAL LIENS: #2006-04513 8/7/06 $24,581.28 -vs- Stephen D. & Jean E. US Treasury Department Tucker Pittsburgh Office Room 808, 100 Liberty Avenue 1 Queen Anne Ct. Pittsburgh, Pa. 15222-9974 Camp Hill, Pa. 17011 BANKRUPTCIES: None of record DELINQUENT Delinquent taxes and tax claims, if available, are shown hereafter. Possible additional tax delinquencies may exist, but TAXES: may not be readily available. Certifications need to be obtained to determine whether outstanding tax obligations exist. Taxes appear to be paid thru 2006. MUNICIPAL LIENS: None of record MORTGAGES: 3 of record $89,300.00 Stephen D. Tucker and Jean E. Tucker To: First Federal Savings & Loan Association 234 North Second Street, Harrisburg, Pa. Dated: 12/29/87 and recorded: 12/31/87 in Book 891 page 419 $25,000.00 Stephen D. Tucker and Jean E. Tucker To: Corestates Bank, NA P.O. Box 4008, Lancaster, Pa. 17604 Dated: 11/10/95 and recorded: 11/30/95 in Book 1293 page 829 $143,100.00 Stephen D. Tucker and Jean E. Tucker To: Argent Mortgage Co. LLC One City Boulevard West, Orange, Ca. 92868 Dated: 7/11/03 and recorded: 7/30/03 in Book 1826 page 1766 JUDGMENTS: #2003-04854 9/15/03 $2,626.88 -vs- Stephen D. & Jean E. Bureau of Compliance Tucker Dept. 280946, Harrisburg, Pa. 17128-0946 1 Queen Anne Ct. Camp Hill, Pa. 17011 #2007-02790 5/8/07 $2,743.58 -vs- Stephen D. & Jean E. Bureau of Compliance Tucker Dept 280946 HarTosbura, Pa. 17128-0946 Liberty Bell Agency, Inc. certifies these search results as based upon the examination of evidence recorded in the appropriate public records for those categories searched Upon full payment of the price of this report, liability hereunder, in an amount not exceeding $2000 dollars, is assumed by Liberty Bell Agency, Inc. solely in its capacity as an abstracter for its negligence, mistakes or omissions, and only for the time period searched. This report does not constitute title insurance, nor is it a commitment to issue title insurance. This report shall NOT be used in a real estate or loan settlement or closing, as possible additional public records may need to be searched, and additional requirements may be added to this report Page 1 of 3 ATTACHED TO AND FORMING PART OF SEARCH. #2003-03480 7122/03 $4,501.30 -vs- Steven Richard Tucker Durff Wilmer 4 Darrin Avenue c/o P.O. Box 2013, Mechanicsburg, Pa. 17055 Newburg, Pa. 17240 #2002-02639 5/30/02 $1,797.88 -vs- Stephen D. Tucker Bureau of Compliance 1 Queen Anne Ct. Dept. 280946, Harrisburg, Pa. 17128-0946 Camp Hill, Pa. 17011 MECHANICS CLAIMS: None of record OtherClaims/Llens: None of record SUPPORT LIENS: Overdue support payments become liens on all real property owned by an obligor on the date the payment was due. Certifications may need to be obtained to determine the priority of the lien relative to the lien being forclosed. Pa.R.C.P. 3129 Notice should be sent to the PA Department of Public Welfare and the Cumberland Domestic Relations Office Contact this office if mailing addresses are requested. REMARKS: None Liberty Bell Agency, Inc. certifies these search results as based upon the examination of evidence recorded in the appropriate public records for those categories searched. Upon full payment of the price of this report, liability hereunder, in an amount not exceeding $2000 dollars, is assumed by Liberty Bell Agency, Inc. solely in its capacity as an abstracter for its negligence, mistakes or omissions, and only for the time period searched. This report does not constitute title insurance, nor is it a commitment to issue title insurance. This report shall NOT be used in a real estate or loan settlement or closing, as possible additional public records may need to be searched, and additional requirements may be added to this report Page 2 of 3 C-j ic -0 Fn N r"ti? C bra V " a m Q SHERIFF'S RETURN - REGULAR CASE NO: 2007-03727 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS TUCKER STEPHEN D ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE TUCKER STEPHEN D DEFENDANT the at 1743:00 HOURS, on the 22nd day of June , 2007 at 1 QUEEN ANNE COURT CAMP HILL, PA 17011 JEAN TUCKER WIFE was served upon by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 .00 B b4/07 42.40 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 06/25/2007 GOLDBECK MCCAFFERTY MCKEEVER By: , Deputy Sher' f of A. D. SHERIFF'S RETURN - REGULAR 9 CASE NO: 2007-03727 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS TUCKER STEPHEN D ET AL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE TUCKER JEAN E was served upon the DEFENDANT , at 1743:00 HOURS, on the 22nd day of June , 2007 at 1 QUEEN ANNE COURT CAMP HILL, PA 17011 JEAN TUCKER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 Y?o9?n? 16.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 06/25/2007 GOLDBECK MCCAFFE Y MCKEEVER By: Deputy Sherif of A.D. ,or 4 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff VS. STEPHEN D. TUCKER JEAN E. TUCKER 1 Queen Anne Court Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 07-3727 Defendants PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. MICHAEL T. MCKEEVER, ESQUIRE C -- Z--r c cn c.n