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HomeMy WebLinkAbout08-0578GOLDBECK 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 BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff VS. CONTAD B. HOLZER Mortgagor and Real Owner 901 Bridge Street Drexel Hills, PA 17070 Defendant Tenn N 08- 5`78 C?v? t? wt CIVIL ACTION: MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE FAVOR DEL DEMANDANTE Y REQUERIRA ES POSSIBLE QUE USTED PUEDA PERDER DE ESTA DEMANDA. POR RAZON DE ESA DECISION 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 ABOGADOCER SERVIC OS LEGAL A PERSONAS INFORMACION ACERCA AGENCIAS QUE PUEDAN O 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.go_v for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(d,)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 60196FC. 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 BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, 7105 Corporate Drive, PTX-B-209, Plano, TX 75024. 2. The names and addresses of the Defendant is CONRAD B. HOLZER, 901 Bridge Street, New Cumberland, PA 17070, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On August 31, 1995 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to PROVIDENT MORTGAGE CORP. T/A CONSOLIDATED MORT CORP, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1280, Page 423. The mortgage has been assigned to: BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 by assignment of Mortgage August 08, 2006 and recorded on August 29, 2006 as Book 0729, Page 4917. 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 June 01, 2007 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................... Interest from 05/01/2007 through 12/18/2007 at 8.0000%...... Per Diem interest rate at $16.71 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .. 1/2007 12/18/2007 ............... $76,284.62 .................$3,876.72 Late Charges from 06/0 to ................................ Monthly late charge amount at $31.61 C f d T'tl S h ......$3,814.23 .........$221.26 osts o suit an i e earc ......................................................... ... $900.00 Monthly Escrow amount $152.23 $85,096.83 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in 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 $85,096.83, together with interest at the rate of $16.71, 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: VIER JOSEPH A. GOLDBECK, JR., )RNEY FOR PLAINTIFF VERIFICATION 1cEAisaw% , 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: 69 IT A KM SELMAN, AMSTANT VICE PRESIDM 901 Bridge Street Drexel Hills, PA 17070 - CONRAD B. HOLZER E.ChibitA IS= Db8C VTIOi . Ara. 3x= CXWU= treat of lased situate in i the NOVO Utiaularly New Cmberland. CUMOVIend County, Yensnsyl P bounded and described as follows, to wit, 31=xg na at a point On the sane= aide of midge Street at its intersection with the nottba= siQe at 9th Streeti thence along the sastoxn side of Bridge Street in a northerly direction a distance of twenty and sixty-two hundredths s1Z?31 sty the a points thence aastwardly thzougD the hareix described preelises am the pswiaee imadiatell7, .djaaerst to the north (said adjacent promises bele9 no. to3 Bridge Street) and beyond a distance of one hundred three (103) feet, more Or leas, to the western side of a tm (10) loot aide allayr thence along the weetezn side of said alley in a southerly direetim a distance of twenty md. sixty-two hundredths (20.62) feet to the sorihsrn side o! 9th 8treati thspoe Clang the northern side of 9 ion a distance of am hund (2-00) hfeet«to theaeast?lsiderof Bridge Strr.tt at the poi or dace of zManom. HAVIM TUIPeab1 NIUMsa the southern Mat of a a 1/2 story ?? as No. 901 Sreee Streetftwuiag house and known and , New Mberland,, Pennsylvania. BEIM To SAID Pa8N2328 which bale L. VialI - I and Michele J. Miezman, by their deed to he reoorded simultaneously havewich, in the Office of the Recorder o! Deeds of Cumberland County, granted and conveyed into Caurad D. golear. VAdd Of helas?y?y r!,ft o raawdbstuns of US12M WE AV ,* Ey, hibit B ?C?artiywtde" MOM LOANS P.O. Banc 9048 Temecula, CA 92589-9048 Sand Payments 70: PO BOX 660694 Dallas, TX 75266-0691 Send correspondence to., PO Box 5170, MS SV314B Simi Valley, CA 93065 111111111111111111 2204667940 Conrad B Holzer 901 BRIDGE ST NEW CUMBERLAND, PA 17070-1629 070814-BLQPAI PRESORT First-Class Mall U.S. Pos"s and Foes Paid WSO IG i":k HOME LOA1dli P.O. Sox 660694 Dallas, TX 75266-0694 Send Payments to: PO Sox 660694 Dallas, 7X 75266-0694 August14,2007 Conrad B Holzer 901 BRIDGE ST NEW CUMBERLAND, PA 17070-1629 Account No.: 7122424 Property Address: 901 Bridge Street Drexel Hills, PA 17070 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortgage on your home Is M default and the lender Intends to foreclose. Specific information aboct the nature of the default Is Drovided In the attached gages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM tHEMAPI may be able to help to save your home, This Notice explains how the aoaram works, To see N HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF ...TE OF THIS NOTICE, Take this Notice with you when you meet with the Counselinn Agency. THE This Notice contains Important legal information. N 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. EN SU RADUCCICMm NT CCASA 6 SE NO COMPRENDE EL MC IONTENIDO DE S ESTA NOTIFCACON OBTENGA UNA NT INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL Nt1MERO MECIONADO ARRIBA. PUEDE SER ELEGIBLE PARA LIN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA HOMEOWNER'S NAME(S): Conrad B Holzer PROPERTY ADDRESS: 901 Bridge Street Drexel Hills. PA 17070 LOAN ACCT. NO.: 7122424 ORIGINAL LENDER: CURRENT LENDERISERVICER: Countrywide Home Loans Servicina LP 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 • Make your check payable to Countrywide Hone Loans • Wdte your account number on your check or money order . Write in cry adddonal amounts you ore indudng tr total is more than $5000, please send testified deck) • Dont attach your check to the paymentcocgon • Ddnt krdude correspondence • Dort send cash RN' This communicetkm is from a debt mlWcbr. Please WN Vott account number on all d•do artl WmespondeneQ m may cimge you a fea br ary peymen rGtwo or P*ded by your financial Insttubn, subledto appicable I9N. Account Number. 71224240 ,,,,,,_,,, u UA- Belance Due for charges listed above: $953.54 as of 0811412007. yvI cnage week PWae update+?i cbimemn rn the •vewa clad this muprn. Addtonal Proopel BLWAi Addn i Ewan Countrywide PO BOX 660694 a Dallas, TX 75266-0694 11.3.1,rrl llrlrrrl,rlrrlrlllrrrl chrecs TWI 007122424000000095354000095354 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-five (35) 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 uroTr_erc eCCICTANCF. YOU MUST 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-five (35) days after the date of this meeting. The -..___ f- fhn - v,tv in which the 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-five (35) 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 alter 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 noted 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 tiled bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 901 Bridge Street Drexel Hills, PA 17070 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 0610112007 Late Charaes: 06101/2007 Other Late Charges Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: E-mail use: Providingg yyoue-mail address belas will allow us to send you irformaaon an your a=urt Account Number: 7URN Corad B Fbtnv E-mail address $2,370.90 $63.22 $31.61 ($1,426.41) ($85.78) $953.54 flow we pad yme Pat- M =now prynrnb of pbaipal gad bdwd A be 44M b 1w bryeat odebldYO bwb?arwd dw, adaw dew&w wpm* pealibd cr &M by kw. 1 you a" M amoad Is addiwl b yaw e"tm ma" Will we M MP* ym pgelwrAa n bulge % b rAdo to ewaldr 11 dd 6ftwinlat(11 bb I " and dw Nomllt you an In , Will yoff I= ad #4 fa "m b aubWldlq plod be. y'ar I=. Flue sp * ff ya wait as add•wld email am b bug Pdawda M- Ihn pbt"wldlwbn. fbddabd draft C=fty deals Panay' 1111 Is Od now Padd bd die - W- epwk* speed bby a l=oamdw arbdmidmL YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not aoalicable) HOW TO CURE. THE DEFAULT - You may cure the default within THIRTY+P4E (351 DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $953.54, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-FIVE (351 DAY PERIOD. Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by taking the following action within THIRTY-FIVE (351 DAYS of the date of this letter. (Do not use if not awficable) IF YOU ^vv ? • •- DEFAULT ., NOT C DoE THE - If you do not cure the default within THIRTY-FIVE (351 DAYS of the date of this Notice, the lender Intends to exercise Its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY-FIVE 1351 DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay of( 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 cure the default within the THIRTY-FIVE (35) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. 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-FIVE u DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth In this notice will restore your mortgage to the some position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans Servicing LP Address: P. O. Box 660694 Dallas, TX 73266--0694 Phone Number: 1-000-669-4578 Fax Number:_ 1^805-377'3432 Contact Person: MS PTX 36 Attention: Loan Counselor 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. It you continue to live in the property alter the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. Yt 2204667940 TO HAVE THE MORTGAGE RESTORED TO THE E POSITION AS IF NO DEFAULT OCCUED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVES RIGHT O CURE OUR DEFAULTDMORE 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. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security Instrument. If you are unable to cure the default on or before September 18, 2007, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 1/2 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even it your home is worth less than what is owed on it. • Deed-in-Lieu: Or, it your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will creed to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to.bring your loan current or to enter into a written agreement by September 18, 2007 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-4578. CONSUMKR CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Atlanta County Irnertanh cccs of wesbsm PA Acorn Housing 14 S. 13th Street Housing Aulltority 2000 Linglestown Rued Harrisburg, PA 17104 40 E High Street Harrisburg, PA 17102 717.213.0150 Gettysburg, PA 17325 888.511.2227 717.334.1518 Communfty Action Commissior Loveship, Inc. 2320 North 5th Street Maranatha 43 Philadelphia Avenue l Region of Harrisburg, PA 17110 W esboro, PA 17268 ?n 15114 4 Street Derry Harrisburg, PA 17104 717.232.2207 717.762.3285 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 (?.._ _"? ":? O t.,? 7' f.• L '? Cw , „ ;'i, ` :7 ti? -? 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00578 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK VS HOLZER CONRAD B MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE HOLZER CONRAD B DEFENDANT the , at 1859:00 HOURS, on the 29th day of January , 2008 at 901 BRIDGE ST NEW CUMBERLAND, PA 17070-1629 by handing to CONRAD B HOLZER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 16.32 .00 10.00 .00 v/ 44.32 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 01/30/2008 GOLDBECK MC KEEVER By: Deputy -Sheriff was served upon of A. D. %4 In the Court of Common Pleas of Cumberland County BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-13-209 Plano, TX 75024 Plaintiff VS. CONRAD B. HOLZER (Mortgagor(s) and Record Owner(s)) 901 Bridge Street Drexel Hills, PA 17070 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-578 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 CONRAD B. HOLZER by default for want of an Answer. Assess damages as follows: Debt Interest from 03/04/2008 to Date of Sale Total (Assessment of Damages attached) $86,918.31 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMO TS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE MPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the p y rkst whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least t n d ys p o the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. I Attorney for I.D. #56129 AND NOW !? a(?? , J> gment is entered in favor of BANK OF NEW YO AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWM S 2003-R4 and against CONRAD B. HOLZER by default for want of an Answer and damages assessed in the sum of 6,918.31 as per e above certification. Protho tary -.?. / Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff vs. CONRAD B. HOLZER (Mortgagors and Record Owner(s)) 901 Bridge Street Drexel Hills, PA 17070 Defendant(s) No. 08-578 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 r h e d against you. urt Long Protho By: If you have any questions concerning the above, please contact: Deputy Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 60196FC 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: February 19, 2008 TO: CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 BANK OF NEW YORK AS TRUSTEE FOR THE In the Court of CERTIFICATEHOLDERS OF CWMBS 2003-R4 Common Pleas 7105 Corporate Drive, PTX-B-209 of Cumberland County Plano, TX 75024 Pl Plaintiff CIVIL ACTION -LAW vs. CONRAD B. HOLZER vs' Action of (Mortgagor(s) and Record Owner(s)) Mortgage Foreclosure 901 Bridge Street Drexel Hills, PA 17070 Term No. 08-578 Defendant(s) TO: CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES O OBJECTIONAS To C THE PERSONALLY SET W 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 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 Joseph A. Goldbeck. Jr 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, y 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, CONRAD B. HOLZER about unknown is years of age, that Defendant's last known residence is 901 Bridge Street, New Cumberland, PA 17070, 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 otherw' e within the provisions of the Soldiers' and Sailors' Ci i R ief Action of Congress of 1940 and its Amendments. 1 Date: GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BANK nF xnnw CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff vs. CONRAD B. HOLZER (Mortgagor(s) and Record owner(s)) 901 Bridge Street Drexel Hills, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 08-578 ORDER FOR JUDGMENT Please enter Judgment in favor of BANK OF NEW YORK AS TRU TE CERTIFICATEHOLDERS OF CWMBS 2003-R4, and against CONRAD B. HO Answer in the above action within (20) days (or sixty (60) days if defendant i the the date of service of the Complaint, in the sum of $86,918.31. Michael T. McKeeve Attorney for Plaintiff I hereby certify that the above names are correct and that the precise es den creditor is BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICA 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 and that the name(s) and 1 ssttL o Defendant(s) is/are CONRAD B. HOLZER, 901 Bridge Street New Cumberlan , P 1 THE 5 failure to file an Mates of America) from ; of the judgment CWMBS 2003-R4 ess(es) of the GOLDBECK McCAFF y & BY: Michael T. McKee er Attorney for Plaintif? ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $76,284.62 Interest from 05/01/2007 through $5,146.68 03/03/2008 Reasonable Attorney's Fee $3,814.23 Late Charges $316.09 Costs of Suit and Title Search $900.00 Escrow Payments Due 3 X $152.23 $456.69 $86,918.31 GOLDBECK MCCAFFERTY & BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this *'k day of 1 bujr- , 2008 damages are assessed as above. 4 Pro Pro y n ?k w ti -It t d ? n? r-' PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW CONRAD B. HOLZER Mortgagor(s) and Record Owner(s) 901 Bridge Street Drexel Hills, PA 17070 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 08-578 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $86,918.31 Interest from 03/04/2008 to Date of Sale at 8.0000% (Costs to be added) GOLDBECK McCAFFERTY & BY: Michael T. McKeever Attorney for Plaintiff w? xx z hM O / a, U U '..? 'd N .r-i ?I V C) Ui a y 0 C U C r/? a 1100 W °O H o Q ? Cpl x ? za °o ??? o= 0 O W H W w U ° U ?? ? W pq U A, ( ) W?c Lv - Cv G ?...+ ^ Y 1/ 1 ? O M ? 0 .0 0 Y ?U a? x? ? w u ? o ~ w 4 0 C) C* C u y N „ o a .n C7 ?\ O M V ? M V N cy- ALL THAT CERTAIN tract of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bridge Street at its intersection with the northern side of 9th Street; thence along the eastern side of Bridge Street in a northerly direction a distance of twenty and sixty-two hundredths (20,62) feet to a point, thence eastwardly through the dividing wall between the herein described premises and the premises immediately adjacent to the north (said adjacent premises being No. 903 Bridge Street) and beyond a distance of one hundred three (103) feet, more or less. to the western side of a ten (10) foot wide alley, thence along the western side of said alley in a southerly direction a distance of twenty and sixty-two hundredths (20.62) feet to the northern side of 9th Street, thence along the northern side of 9th Street in a westerly direction a distance of one hundred (100) feet to the eastern side of Bridge Street at the point or place of BEGINNING. HAVING THEREON ERECTED the southern half of 2 %2 story double frame dwelling house and known and numbered as No. 901 Bridge Street, New Cumberland, Pennsylvania. BEING THE SAME PREMISES which Dale L. Wierman and Michale J. Wierman, by their deed to be recorded simultaneously herewith, in the office of the Recorder of Deeds of Cumberland County, grated and conveyed unto Conrad B. Holzer. TAX PARCEL NO: 26-24-0811-245 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-578 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, Plaintiff (s) From CONRAD B. HOLZER (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 $86,918.31 L.L. $.50 Interest FROM 3/4/08 TO DATE OF SALE AT 8.0000% Atty's Comm % Due Prothy $2.00 Atty Paid $163.32 Other Costs Plaintiff Paid Date: MARCH 4, 2008 Curtis . Long, Protho (Seal) By: Deputy REQUESTING PARTY: Name MICHAEL T. MCKEEVER, 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. 56129 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 vs. Plaintiff of Cumberland County CONRAD B. HOLZER CIVIL ACTION -LAW (Mortgagor(s) and Record Owner(s)) 901 Bridge Street ACTION OF MORTGAGE FORECLOSURE Drexel Hills, PA 17070 Defendant(s) No. 08-578 AFFIDAVIT PURSUANT TO RULE 3129 BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 901 Bridge Street Drexel Hills, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 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 P.O. Box 2675 Harrisburg, PA 17105-2675 IN THE COURT OF COMMON PLEAS 4. Name and address of the last recorded holder of every mortgage of record: Y WACHOVIA BANK, NATIONAL ASSOCIATION 301 South College Street Charlotte, NC 28288 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 901 Bridge Street Drexel Hills, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best y per nal knowledge or information and belief. I understand that false statements herein are made subject to the yn ties 71 -4118 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. DATED: February 29, 2008 GOLDBECK McCAI BY: Michael T. McK Attorney for Plaintiff N' C..? ?? ? n ? f'n 1 ..? ? _ _) W'.. ..-?? --+ r? 08-578 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff vs. CONRAD B. HOLZER Mortgagor(s) and Record Owner(s) 901 Bridge Street Drexel Hills, PA 17070 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-578 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: HOLZER, CONRAD B. CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 Your house at 901 Bridge Street, Drexel Hills, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $86,918.31 obtained by BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, 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 IN THE COURT OF COMMON PLEAS 08-578 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-578 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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 homeretentionkmoldbecklaw.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 60196FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. h? C. ca 1 i_ . 77 ALL THAT CERTAIN tract of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bridge Street at its intersection with the northern side of 9th Street; thence along the eastern side of Bridge Street in a northerly direction a distance of twenty and sixty-two hundredths (20,62) feet to a point, thence eastwardly through the dividing wall between the herein described premises and the premises immediately adjacent to the north (said adjacent premises being No. 903 Bridge Street) and beyond a distance of one hundred three (103) feet, more or less. to the western side of a ten (10) foot wide alley, thence along the western side of said alley in a southerly direction a distance of twenty and sixty-two hundredths (20.62) feet to the northern side of 9th Street, thence along the northern side of 9th Street in a westerly direction a distance of one hundred (100) feet to the eastern side of Bridge Street at the point or place of BEGINNING. HAVING THEREON ERECTED the southern half of 2 %2 story double frame dwelling house and known and numbered as No. 901 Bridge Street, New Cumberland, Pennsylvania. BEING THE SAME PREMISES which Dale L. Wierman and Michale J. Wierman, by their deed to be recorded simultaneously herewith, in the office of the Recorder of Deeds of Cumberland County, grated and conveyed unto Conrad B. Holzer. TAX PARCEL NO: 26-24-0811-245 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 60196FC CF: 01/25/2008 SD: 06/11/2008 $86,918.31 BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff VS. CONRAD B. HOLZER Mortgagor(s) and Record Owner(s) 901 Bridge Street Drexel Hills, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-578 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ?j Personal Service by the Sheriffs Office u1L(copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever Attorney for Plaintiff oa 0 OY t.. 6 a Np p 1.1.011ow ••. i O ll ki a a Q 4 aL O w 0000 ?, LLO m ? j)W Q ? c Z o om N ~ ?Z ~ a o o g W z coal LU W T r ? U T O 18111 C R = h m o $N a $ Q U e L a 1811 M C'°° G O 1 T gcgac`? am n. i 3c4i 2 z y F ? WI II Z? w?S=? 04 M ui <O I? Cd C • d S L N N a a 0 O d V? L' Q3 V C3 LL It LU 0 00 V ~ Bank of New York as Trustee for the In the Court of Common Pleas of Certificateholders of CWMBS 2003-R4 Cumberland County, Pennsylvania vs Writ No. 2008-578 Civil Term Conrad B. Holzer (k0?6F&) rt Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April Robe 04, 2008 at 1108 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Conrad B. Holzer by making known unto Conrad B. Holzer personally at 901 Bridge Street, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 04, 2008 at 1108 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and description, in the above entitled action, upon the property of Conrad B. Holzer located at 901 Bridge Street, New Cumberland, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Conrad B. Holzer by regular mail to his last known address of 901 Bridge Street, New Cumberland, PA 17070. This letter was mailed under the date of April 17, 2008 and never returned to the Sheriffs Office. 4;?? 1&591: R. Thomas Kline,' Sheriff B Real Estate ergeant 1 , , GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. CONRAD B. HOLZER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 901 Bridge Street Drexel Hills, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 Term No. 08-578 BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 901 Bridge Street Drexel Hills, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 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 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: WACHOVIA BANK, NATIONAL ASSOCIATION 301 South College Street Charlotte, NC 28288 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 901 Bridge Street Drexel Hills, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: May 1, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff in '? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which SECRETARY OF VETERANS AFFAIRS is the grantee the same having been sold to said grantee on the I I TH day of JUNE A.D., 2008, under and by virtue of a writ Execution issued on the 4TH day of MARCH, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 578, at the suit of BANK OF NEW YORK AS TR FOR CERTIFICATCHOLDERS OF CWMBS 2003-R4 against CONRAD B HOLZER is duly recorded as Instrument Number 200823517. IN TESTIMONY WHEREOF, I have hexeunto set my hand eal of said office this h© ? day of (LiL -, A.D.? ?' V /// - ?l.A /-2t of Deeds Rwm" Duds, Cwts& d Om*. CMde. PA My E*n M» RM MK4q dJw. X10 Bank of New York as Trustee for the In the Court of Common Pleas of Certificateholders of CWMBS 2003-R4 Cumberland County, Pennsylvania vs Writ No. 2008-578 Civil Term Conrad B. Holzer Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 04, 2008 at 1108 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Conrad B. Holzer by making known unto Conrad B. Holzer personally at 901 Bridge Street, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 04, 2008 at 1108 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and description, in the above entitled action, upon the property of Conrad B. Holzer located at 901 Bridge Street, New Cumberland, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Conrad B. Holzer by regular mail to his last known address of 901 Bridge Street, New Cumberland, PA 17070. This letter was mailed under the date of April 17, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 11, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of Secretary of Veterans Affairs. It being the highest bid and best price received for the same, Secretary of Veterans Affairs of 12650 Ingenuity Drive, Orlando, FL 32826 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $982.01. Sheriff s Costs: Docketing $30.00 Poundage 19.26 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 32.64 Levy 15.00 Surcharge 20.00 Law Journal 355.00 Patriot News 339.38 Share of Bills 14.73 Distribution of Proceeds 25.00 Sheriffs Deed 40.50 $ 982.01 / 711y1o;, ?L cl'- Wo U, 'Ai c? ? y ?rS at, d116-20 So Answers: R. Thomas Kline, Sheriff _ BV, A (44 Read Estate ergeant s Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW CONRAD B. HOLZER (Mortgagor(s) and Record Owner(s)) 901 Bridge Street Drexel Hills, PA 17070 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 08-578 AFFIDAVIT PURSUANT TO RULE 3129 BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 901 Bridge Street Drexel Hills, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 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 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: WACHOVIA BANK, NATIONAL ASSOCIATION 301 South College Street Charlotte, NC 28288 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 901 Bridge Street Drexel Hills, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best y pe nal knowledge or information and belief. I understand that false statements herein are made subject to the ties 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: February 29.200$ GOLDBECK MCCAI BY: Michael T. McK Attorney for Plaintiff 08-578' GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street. Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 7105 Corporate Drive, PTX-B-209 Plano, TX 75024 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW VS. CONRAD B. HOLZER Mortgagor(s) and Record Owner(s) 901 Bridge Street Drexel Hills, PA 17070 ACTION OF MORTGAGE FORECLOSURE Defendants; Term No. 08-578 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: MUM CONRAD B. CONRAD B. HOLZER 901 Bridge Street New Cumberland, PA 17070 Your house at 901 Bridge Street, Drexel Hills, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $86,918.31 obtained by BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 08-578 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF T$E SHERIFF'S SALE DOM NOT TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-578 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud_gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionaa goldbecklaw.com. Call 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 60196FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bridge Street at its intersection with the northern side of 9`h Street; thence along the eastern side of Bridge Street in a northerly direction a distance of twenty and sixty-two hundredths (20,62) feet to a point, thence eastwardly through the dividing wall between the herein described premises and the premises immediately adjacent to the north (said adjacent premises being No. 903 Bridge Street) and beyond a distance of one hundred three (103) feet, more or less. to the western side of a ten (10) foot wide alley, thence along the western side of said alley in a southerly direction a distance of twenty and sixty-two hundredths (20.62) feet to the northern side of 9t' Street, thence along the northern side of 9 h Street in a westerly direction a distance of one hundred (100) feet to the eastern side of Bridge Street at the point or place of BEGINNING. HAVING THEREON ERECTED the southern half of 2 1/? story double frame dwelling house and known and numbered as No. 901 Bridge Street, New Cumberland, Pennsylvania. BEING THE SAME PREMISES which Dale L. Wierman and Michale J. Wierman, by their deed to be recorded simultaneously herewith, in the office of the Recorder of Deeds of Cumberland County, grated and conveyed unto Conrad B. Holzer. TAX PARCEL NO: 26-24-0811-245 r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-578 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF CWMBS 2003-R4, Plaintiff (s) From CONRAD B. HOLZER (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 $86,918.31 L.L. $.50 Interest FROM 3/4/08 TO DATE OF SALE AT 8.0000% Atty's Comm % Due Prothy $2.00 Atty Paid $163.32 Other Costs Plaintiff Paid Date: MARCH 4, 2008 69 R. Long, P otary (Seal) By: Deputy REQUESTING PARTY: Name MICHAEL T. MCKEEVER, 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. 56129 Real Estate Sale # 81 On March 13, 2008 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA Known and numbered as 901 Bridge Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 13, 2008 By: ? Real Estat Sergeant 1 ? $ ,d q - WVW BpOt ? 12?3NS 341 31 ??1 ? ?? 149 k*The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Pam* otwxews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/23/08 04/30/08 05/07/08 Sworn toaC40&01P ubscribed before me this 27 day of May, 2008 A.D. N otary P b is COMMONWEALTH OF PENNSYLVANIA Notarial Seal Chyrle L. Sheppard, Notary Public City Of Harrisburg, Dauphin County My Commission Expires May 29, 2010 Member, Pennsylvania Association of Notaries Real Estate Sale #81 Writ No. 2008-578 Civil Term Rank of New York as Trustee for the Certificateholders of CWMBS 2003-R4 VS Conrad B. Holzer Attorney: Joseph Goldeck DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bridge Street at its intersection with the northern side of 9th Street; thence along the eastern side of Bridge Street in a northerly direction a distance of twenty and sixty-two hundredths (20,62) feet to a point, thence eastwardly through the dividing wall between the herein described premises and the premises immediately adjaccat jo the pqA Q* adjacent premises being No. 903 Bridge Street) and beyond a distance of one hundred three (103) feet, more or less. to the western side of a ten (10) foot wide alley, thence along the western side of said alley in a southerly direction a distance of twenty and sixty-two hundredths (20.62) feet to the northern side of 9th Street, thence along the northern side of 9th Street in a westerly direction a distance of one hundred (100) feet to the eastern side of Bridge Street at the point or place of BEGINNING. HAVING THEREON ERECTED the southern half of 2 112 story double frame dwelling house and known and numbered as No. 901 Bridge Street, New Cumberland, Pennsylvania. BEING THE SAME PREMISES which Dale L. Overman and Michale J. Wrerman, by their deed to be recorded simultaneously herewith, in the office of the Recorder of Deeds of Cumberland County, grated and conveyed unto Conrad B. Holzer. TAX PARCEL NO: 26240811-245 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: May 2, May 9, and May 16, 2008 Affiant hither deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 7:? ?- )LI a== L' a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 16 day of May, 2008 K75 N 1 --.4 - - - - - - ?'? - &awe Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 > L MUM *Ala 3W 41 Writ No. 2008-578 Civil Bank of New York as Trustee for the Certificateholders of CWMBS 2003-R4 VS. Conrad B. Holzer Atty.: Joseph Goldeck ALL THAT CERTAIN tract of land w uft in the Bwalgb of Pkw Cum- berland, Cumberland , Penn- sYbusio, more porticuta* bounded and described as fallowa, to w1t BEGINNING at a point cc the eastern side of B ri4p 96nst at its intersection with the northern side of 9th Street; thence along the eastern side of Bridge Street in a northerly direction a distance of twenty and sixty-two hundredths (20,62) feet to a point, thence eastwardly through the dividing wall between the herein described premises and the premises immediately adjacent to the north (said adjacent premises being No. 903 Bridge Street) and beyond a distance of one hundred three (103) feet, more or less. to the western side of a ten (10) foot wide alley, thence along the western side of said alley in a southerly direction a distance of twenty and sixty-two hundredths (20.62) feet to the northern side of 9th Street, thence along the northern side of 9th Street in a westerly direction a distance of one hundred (100) feet to the eastern side of Bridge Street at the point or place of BEGINNING. HAVING THEREON ERECTED the southern half of 2 1/2 story double frame dwelling house and known and numbered as No. 901 Bridge Street, New Cumberland, Pennsylvania. BEING THE SAME PREMISES which Dale L. Wierman and Michale J. Wierman, by their deal to be re- corded simultaneously herewith, in the office of the Recorder of Deeds of Cumberland County, grated and conveyed unto Conrad B. Holzer. TAX PARCEL NO: 26-24-0811- 245. Assignment of Bid NO. 08-578 - HOLZER 901 Bridge Street Drexel Hills, PA 17070 I, Michael T. McKeever, Esquire, as attorney for the successful bidder, hereby assign my bid at the Sheriff Sale dated June 11, 2008 to: SECRETARY OF VETERANS AFFAIRS 12650 Ingenuity Drive Orlando, FL 32826 GOLDBECK MCCAFFERTY & MCKEEVER Date: June 21, 2008 MICHAEL T. MCKEEVER