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Home My WebLink About07-4201 GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plaintiff vs. ROBERT D. POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS Mortgagors and Real Owners 345 Peach Glen Road Gardners, PA 17324 Defendants p'7 - ~f~ol Civil l erm OF CUMBERLAND COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE C~VII. ACTI4~~C~~C~~a I~CL(~lU~ 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 maybe 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A LISTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LISTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARR DEFENDERSE ES NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE LISTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI LISTED 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 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 maybe 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 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(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 54329FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is WASHINGTON MUTUAL BANK, 9451 Corbin Avenue, Northridge, CA 91324. 2. The names and addresses of the Defendants are ROBERT D. POTTS, 345 Peach Glen Road, Gardners, PA 17324 and MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS, 345 Peach Glen Road, Gardners, PA 17324, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On July 02, 1990 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to THE GETTSBURG NATIONAL BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 982, Page 1061. The mortgage has been assigned to: WASHINGTON MUTUAL BANK 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 March 02, 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. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$16,975.87 Interest from 02/02/2007 through 07/31/2007 at 7.5000% ..........................$628.20 Per Diem interest rate at $3.49 Reasonable Attorney's Fee .................................................................$2,000.00 Late Charges from 03/02/2007 to 07/31/2007 ...............................................$71.25 Monthly late charge amount at $14.25 Costs of suit and Title Search ...................................................................... $900.00 Fees ................................................................................................................$83.70 Monthly Escrow amount $119.00 $20,659.02 7. 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. 8. 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. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $20,659.02, together with interest at the rate of $3.49, 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: L BECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, ~~(~ ~~~ 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:~,~ .~ i i ~ , ~~ Washington Mutual Bank "~~~ ~~~ ~~ #5007499717 - ROBERT D. POTTS and MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS E.~FiiditA EXFIBIT A LOAN: 600369192 ID: CUSTODIAN ID: 57866.10579 POOL: DEAL• Beak Security JOB: PNC-01-06 LEGAL DESCRIPTION: ALL THAT CERTAIN TRACT OF LAND SITUATE TO DICKENSON TOWNSFNP, CUMBERLAND COUNTY, PENNSYLYANiA BOUNDED AND DESCRIBED AS FOLLOWS BEGINNING AT A POLAR IN THE CENTER OF THE BENDRESVLLE ROAD, MARLLED BY A HEAVY NAIL; THENCE ALONG THE CENTER OF THE SAID BEIDptSVLLE ROAD, NORTH 12;114 DEGREE8 EAST 457.65 FEET, MORE OR LESS, TO LAND NOW OR FORMERLY OF HARRY P. FANUS; THENCE BY SAID FANUS LAND NORTH 64 DEGREES EAST 5 PERCHES TO A CENTER ON THE FANUS LAND; THENCE BY THE FANU8 LAND SOIRH T4 DEGREES EAST 21.1 PERCHES TO A CORNER IN THE FANUS LAND, THENCE BY SAME SOUTH 30314 DEGREES EAST 13.6 PERCHES TO THE CORNER OF LAND NOW OR FORMERLY OF C.F. BEAM, THENCE ALONG THE LINE OF YIIE LAND OF BEAN SOtRH 52 DEGREES WEST 41.7 PERCHES TO A POPLAR TREE; THENCE BY THE LAND OF RANK L BLACK AND WIFE, NORTH 13•K DEGREES WEST 17 PERCHES TO THE NAIL IN THE CENTER OF THE BENDERSYILLE ROAD, THE PLACE OF BEGNONING, CONTAl1~BNG 4 ACRES, MORE OR LESS. ~E,~Fii6it ~ V~ast-ington Mutual Mailstop JAXA2031 P.O. Box 44090 Jacksonville, FL 32231-4090 May 16, 2007 ROBERT D POTTS 345 PEACH GLEN RD GARDNERS PA 17324 EIIII~I~IIINII~IIIIV~IIIN °~° "- ,.oo .o~. ,.ao .,3.3~., 000266 /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 # 5007499717 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 ezplain it. You may also want to contact an attorney in your area. The local bar association may be able to help you f nd a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA 1MPORTANCIA, PLIES 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. PA ACT 91 Vlrashington Mutual Mailstop JAXA2031 P.O. Box 44090 Jacksonville, FL 32231-4090 May 16, 2007 #BWNCLNN# #0950079499971798# MARCIA F POTTS 345 PEACH GLEN RD GARDNERS PA 17324 000265 /PC 5007499717 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 # 5007499717 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 PARR 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. PA ACT 97 HOMEOWNER'S NAME(S): Marcia F. Potts PROPERTY ADDRESS: 345 Peach Glen Rd Gardners PA 17324 LOAN ACCT. NUMBER: 5007499717 ORIGINAL LENDER: CURRENT LENDER/SERVICER: 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 HOUSIIVG 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 b` .F.TIN . b` TST .CL1R WITHiN THE NEXT (~ DAYS. IF YOU DO NOT APPLY FOR Eb"ERG)~NCY MORTGAGE ASSISTANCE. YOU MUST BRiN YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALi D "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. ~'ON4 TM .R CR .DIT CO iN4 .I.IN . A .ENCiFS - 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 Plenhone numbtrs of desi;=rPd one Amer credit cnu cel'n¢ agencies for the coun~in which the pZQ~ty is looted a_re 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. APP i ATION FOR MORT ACE ACCISTANCE -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 aze 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.) 000285/C0826 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). - The MORTGAGE debt held by the above lender on your property located at: 345 Peach Glen Rd Gardners PA 17324 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are naw past due: Monthly Installments: 03/0212007 $593.97 04/02/2007 $593.97 05/02/2007 $593.97 Other charges (explainrtemi2s): Uncollected Late Charges $28.50 Uncollected Fees: $8•~ Less Credits $0•~ TOTAL AMOUNT PAST DUE: 51819.31; B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CCi_R_E 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 $1819.31;, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. payment mgt be made either by c?ch c?chier's check certified check_ or mone}~grder made payable and sent to: Washington Mutual Bank Cash Processing P.O. Boa 41275 Jacksonville, FL 32203 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YO ~ DO NOT .IRE TH . D .FA i .T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to s rci4. i a r'~oh a to accPl rat th mort8g8e debt. This means that the entire outtanding 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 it attorneys to start legal action to foreclose upon your mort~_pt4perty. sIF THF. MORT .A .. c FOR - .[>_c .D 1PON 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 Sees will be added to the amount you owe the lender, which may also include other reasonable costs. If ^o.~ c.!re the default witl+_in the THIRTY (~1 DAY p~~,you will not be required to pgy attorney's fees. OTH .R ..NDFR R .M .DISC -The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 RI hT TO LIRE THE DEFA li T PRIOR TO SHERIFF'c SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you maxstill have the ~ht to cure the default and._prevent the sale at a_ny time un to one hour restore your mortgage to the same position as if you had never defaulted. Curing your default in the manner set forth in this notice will FARLIE_cT p[>.c-cIBI E cHERIFF'c cAt F DATE. - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property 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. HOW TO CONTACT THE LEPIDER• Name of Lender: Washington Mutual Bank Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 866-926-8937 Fax Number: 904-281-3914 Contact Person: Collection Department Email Address: www wamuhomeloans.com EFFECTS OF cHERiFF'c SAi E• -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. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTTI'UTION 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. PA ACT 91 ~ C7 t_ ` r ~ ~p ~ ---~ ~,{ p -r Ul ~ -;~ _t 0(NO ~ D r r _} T ~:1 M W =' ~~ ~~ _~,.a r,. r'; "' f. ~,~~ 1 GOLDBECK McCAFFERTY & McKEEVER BY: 70SEPH A. GOLDBECK, 7R. ATTORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE vs. ROBERT D. POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS 345 Peach Glen Road Gardners, PA 17324 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 07-4201 GOLDBECK, McCAFFERTY & McKEEVER By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff ~ ~ ~ ~ o D $ ~ ~- ~ -~, _ ~ ~ ~. ~ ~~ ~. SHERIFF'S RETURN - REGULAR CASE NO: 2007-04201 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS POTTS ROBERT D ET AL TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon POTTS MARCIA FETTERS A/K/A FETTERS MARCIA A the DEFENDANT at 2021:00 HOURS, on the 18th day of July 2007 at 345 PEACH GLEN ROAD GARDNERS, PA 17324 ~.w .-~.-rrT r r-~nmmr+rin nt~mmn by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: .00 .00 10.00 R. Thomas Kline „~ ~~~vjo7C~../ 16:00 Sworn and Subscibed to before me this 07/19/2007 GOLDBECK MCCAFFERTY MCKEEVER De uty Sh iff day of A.D. SHERIFF'S RETURN - NOT FOUND ` CASE NO: 2007-04201 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS POTTS ROBERT D ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT POTTS ROBERT D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 345 PEACH GLEN ROAD GARDNERS, PA 17324 POTTS ROBERT D NOT FOUND as to DEFENDANT IS SUPPOSED TO BE LIVING AT 46 WESTVIEW MANOR YORK, PA 17404. Sheriff's Costs: Docketing 18.00 Service 8.64 Not Found 5.00 Surcharge 10.00 .00 $~Il~lbl ~ 41.64 So answers : ~. ~= R. Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 07/19/2007 Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-04201 P C,pMMONWEALTH OF PENNSYLVANIA: ~ COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS POTTS ROBERT D ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: POTTS ROBERT D but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On August 23rd 2007 this office was in receipt of the attached return from YORK Sheriff's Costs: So a ~~ _ ~.- ;y::...r Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas zne Dep York County 27.85 Sheriff of Cumberland County Postage 1.82 6 6.6 7 v 5/a pld 7 ~,.., 08/23/2007 GOLDBECK MCCAFFERTY MCKEEVER Sworn and subscribe to before me this day of _ , A.D. ,. ' COUNTY OF YORK OFFfCE OF TWE SHERIFF s(R ,I' i % ~L 45 N. GEORGE ST.,YORK, PA 17401 SHERIFF SERVICE '_ ~ - PROCESS RECEIPT and AFFIDAVIT OF RETURN ~ ~~ ~~ 9. 4 ' t. PLAINTIFF1Sl Washington Mutual Bank 2 c~T civil 4. TYPE OF WRrr OR COMPLAINT C E ~- 3. OEFENDANTlS! NOtj,.CL and taint Robert D. Potts et al Ct~tp X ~ t ~ ~ SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO EVIED. ATTACHED, OR RobQxt D. Potts 6. ADDRESS (STREET OR RFO WITH BOX' NUMBER, APT NO., CITY, BORO. TWP., STATE ANO ZIP CODE) AT 46 w~stv~ew Manor Yark, PA 17404 7. INDICATE SERVICE O PERSONAL uPERSON tN CHARGE DEPUTIZE U CERT. MAIL D 7ST CU1SS MAIL U POSTED J OTHER NOW August 1 , 20 I, SHERIFF OF TY, PR, do y deputize the eriff of or COUNTY to execute :this m the rding to law. This deputizatiori being made at the request and risk of the plaintiff. , a lF~'OF TY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT YVILL ASSISt IN EXPEDITING SERVtr~~ .,. 0 F C' O U N •~ Y Oberland Please mail return of service to Ctimberland County Sheriff. Thank you. AUV FEE PAID BY ATTY. NOTE: ONLY APPLICA®LE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sherilt levying upon or attaching any propeAy under within wnt may leave same willwut a watdrrean, in custody of whomever is Iound ~+ possession, atbr notiyiny person of tevy a attachment, without liateilily on the part of such deputy or the sherill to grey plsinllll heroin Mr any Toss. desbuction, or romoval of any property batons sheriRa sale there0t. 9. TYPE NAME snd ADDRESS of ATTORNEY /ORIGINATOR and SIGNATUR~ D S E P H A . G 0 L D B E C K , J R . t °~ ZF~EPHONE NUMBER 11, DATE FILED 701 MARKET ST. PHILA PA 19106 215Jt-j627-1322 7-17-2007 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be oompbted A notice is to be mailed). CUMBERLAND CO SHERIFF 13. t acknowbdpe repipt of Bee writ 14. GATE RECEIVED tS. Expitaliorr<Iiea[nrg pate a<oomota:na:indintedabove.:: YCSO MJ MCGILL 8-3-2007 $-1b-2007 tfr. MOW SERVED: PERSONAL { ) RESIDENCE ( ) POSTED ( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O 1 f+eropy oeAiy and return a, NOT FOUND because I am unaDk to IoeaM the indvidual, oompenY, etc. named above. (See remarlca pe1oM, ) 1 TrFLE OF NrDL q,l LIST ADDRE . RE IF ~~~Ag~ r~ ~ + 19. Da~a Se~ 20. Time f ~ x 1. EMPTS T Miles I oa Time Miles Int. Dale Time Mites IM. Date Time Miles IM. Dab Time Miles Mt. Date Time Miles Int. 22. REMARKS: 23. Advance Coats 21. Service Costs 25. N1F 26. Mileage 27. Postage 28. Sub ToW 29. Poteed 3@. Neay 31. Surdg. 32. Ta. Conga 33 Cagy Qua $100.00 , OCR ~ ,~Q 34. ioregn Counq Coate 35. Advance Costa 30. Service Costs 37. Notsry Cert. 3e. MileagelPosbgdNot Found 39. Total Costs 10. Coats Due or Refund 41. AFFIRMED and subscribed to leelore me tlda ~ 42. dsy of . 20 _ 43. P ~~ Sgnaluro of ~ Sleerilf 45 .. ROTHY /NOTARY 48. SigreaMrreYark 47. E ~ ,,.~` f ~ V~ 48. CSignarylure~rtForogn 49. DATE S0. 1 ACKlIQ1M,ED6E RECEIPT OF THE SHERIFF'S RETURN SIGNATURE St. fb1TE RECEIVED OF AUTIiORIZEO tSSUMIG AUTHORITY AND TITLE /. YN~NTE - hsuinp Authority 2. PINK - Altomey 3. CANARY - SheriRs Office 4. BLUE - Sharelrs OIFce ~: ` , s In the Court of Common Pleas of Cumberland County WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plaintiff vs. ROBERT D POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS (Mortgagor(s) and Record Owner(s)) 345 Peach Glen Road Gardners, PA 17324 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-4201 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT QWEA TA AIIB CL>~ENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against ROBERT D POTTS and MARCIA FETTERS POTTS a/k/a MARCI.4 A. FETTERS by default for want of an Answer. Assess damages as follows: Debt Interest from 09/13/2007 to Date of Sale Total (Assessment of Damages attached) $21,075.59 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 to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 os h A. oldbeck, Jr. A rney for Plaintiff I.D. #16132 AND NOW ~ ('~__'1'~ ao~pZ ,Judgment is entered in favor of WASHINGTON MUTUAL and against ROBERT D POTTS and MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS by default for want of an Answer and damages assessed in the sum of $21,075.59 as per the above certification. IC . thonotary ~~8 54329FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WII,L BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 28, 20(17 TO: MARCIA FETTERS POTTS a/Wa MARCIA A. FETTERS 345 Peach Glen Road Gardners, PA 17324 WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plaintr; f, j`' vs. ROBERT D POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS (Mortgagor(s) and Record Owner(s)) 345 Peach Glen Road Gardners, PA 17324 Defendant(s) TO: MARCIA FETTERS POTTS a/kia MARCIA A. FETTERS 345 Peach Glen Road Gardners, PA 17324 In the Court of Common Pleas of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-4201 il1-r[PQRTANT N(ITiC:F 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 ENTERID AGAINST YOU WITHOUT A HEARIi~TG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IIvIPORTANT 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 HIltING 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES IldC S Iivice Row Carlisle, PA 17013 717-243-9400 ~~~~ti ~ sn(d6ec~?r GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 54329FC 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: August 28, 2007 TO: ROBERT D POTTS 46 Westview Manor York, PA 17404 WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plaintiff vs. ROBERT D POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS (Mortgagor(s) and Record Owner(s)) 345 Peach Glen Road Gardners, PA 17324 Defendant(s) TO: ROBERT D POTTS 46 Westview Manor York, PA 17404 In the Court of Common Pleas of Cumberland County CTVII, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-4201 iMP(?RTANT NnTiC'F. 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 Il~iPORTANT 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 HIltING 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 L'baty Avawe Cazlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 ?QSe~Ft :.~.~nf~Fec~r GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 54329FC THIS LAW FIRM IS A DEBT COLLECTOR ANb 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: ROBERT D POTTS 345 Peach Glen Road Gardners, PA 17324 WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plainti, ff' vs. ROBERT D POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS (Mortgagor(s) and Record Owner(s)) 345 Peach Glen Road Gardners, PA 17324 Defendant(s) TO: ROBERT D POTTS 345 Peach Glen Road Gardners, PA 17324 DATE OF THIS NOTICE:: August 28, 2007 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-4201 iMP(1RTANT N(1TiC.F. 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 BEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IlVIPORTANT 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 HELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIItING 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 REDUCID FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 McCAFFER EVER B A. Goldbeck, h., Esq. Attorney for Plaintiff Suite 5000 -Melon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 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, ROBERT D POTTS, is about unknown years of age, that Defendant's last known residence is 46 Westview Manor, York, PA 17404, 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 Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: `71i21 ~ / 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, MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS, is about unknown years of age, that Defendant's last known residence is 345 Peach Glen Road, Gardners, PA 17324, 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 Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. oa~e 9~iZlm Vc~op~A~31z!-iPple_~ 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 9451 Corbin Avenue Northridge, CA 91324 vs. ROBERT D POTTS MA~t,CIA FETTEIts POTTS a/k/a MARCIA A. FETTERS (Mortgagor(s) and Record owner(s)) 345 Peach Glen Road Gardners, PA 17324 Defendant(s) IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 07-4201 ORDER FOR JUDGMENT Please enter Judgment in favor of WASHINGTON MUTUAL BANK, and against ROBERT D POTTS and MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $21,075.59. os h A. oldbeck, Jr. A torney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 and that the name(s) and last known address(es) of the Defendant(s) is/are ROBERT D POTTS, 46 Westview Manor York, PA 17404 and MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS, 345 Peach Glen Road Gardners, FA 17324; DBE K McCAFF TY & McKEEVER B :Joseph A. Goldbeck, Jr. Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 02/02/2007 through 09/12/2007 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Seazch Escrow Payments Due 0 X $119.00 Fees Escrow $16,975.87 $778.27 $2,000.00 $99.75 $900.00 $83.70 $238.00 $21,075.59 G LDBE K McCAEFERTY & McKEEVER Joseph A. Goldbeck, Jr. Attorney for Plaintiff AND NOW, this 17* day of ~`T'~. 2007 damages aze assessed as above. S `~i"~ ro rothy _+ y~ ~ , ,_ ~~ ".~ 1 ~' ~ ~ q~ O # O n °O ~ t7 ~ ~ ~ ~ v ~ N ~ ~ ~ i ' R cn '' S ri' ~ ~ ~ - ~:, ~. -. _ - _, ~L l 3 ( ~1 ~'~ ;: ~} .n{ ~ ~~ Rule of Civil Procedure No. 236 -Revised TN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plaintiff vs. ROBERT D POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS (AQw~gngers aid Reeer~l O~er(s)) 345 Peach Glen Road Gardners, PA 17324 Defendant(s) No. 07-4201 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DE$T 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. A~ ~h If you have any questions concerning the above, please contact: 9~/~/0~ Joseph A. Goldbeck, Jr. Goldbeck McC~fferty & McKeever Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 .-- . , ~ 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 9451 Corbin Avenue Northridge, CA 91324 Plaintiff vs. ROBERT D POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS 345 Peach Glen Road Gardners, PA 17324 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Docket No. 07-4201 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 ~~ GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 FAX (215) 627-7734 November 7, 2007 PROTHONOTARY OF CUMBERLAND COUNTY Curt Long Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: Docket Number: 07-4201 Dear Sir or Madam: Kindly file of record the enclosed Praecipe to Vacate Judgment. A time stamped copy does not need to be returned to our office. Goldbeck McCafferty & McKeever Bridget Marie Speck, Legal Assistant Direct Dial: 215-825-6384 Email: BSpeck@goldbecklaw.com Main number: 215-627-1322 Enclosures . -.. GOLDBECK McCAFFERTY ~ McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D. #16132 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attomey for Plaintiff WASHINGTON MUTUAL BANK 9451 Corbin Avenue Northridge, CA 91324 Plaintiff vs. ROBERT D POTTS MARCIA FETTERS POTTS a/k/a MARCIA A. FETTERS 345 Peach Glen Road Gardners, PA 17324 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Docket No. 07-4201 Defendants PRAECIPE TO VACATE JUDC3~SENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE t7Gt ~ ~ ~~ ~'. _ ~ ~ ~ ~ .:. .~` -~