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HomeMy WebLinkAbout08-1387GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF OS-/381 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. HARPREET S. GULERIA Mortgagor and Real Owner 1920 Kent Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. Defendant `iA ACTION: MORTGAGE ?.J?L O8URE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA ?_ DEMANDA. - RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELPFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw com. Call 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 63234FC. 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 Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendant is HARPREET S. GULERIA, 1920 Kent Drive, Camp Hill, PA 17011, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On September 28, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1968, Page 2156.. 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 October 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 ..................................................................................$173,315.03 Interest from 09/01/2007 through 02/14/2008 at 7.1250% .......................$5,649.60 Per Diem interest rate at $33.83 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$8,665.75 Late Charges from 10/01/2007 to 02/14/2008 .............................................$294.60 Monthly late charge amount at $58.92 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $380.28 $188,824.98 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 Sheriffs 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 $188,824.98, together with interest at the rate of $33.83, 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: GOLDBECK McCAFFERTIV & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION OM MILLER 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: OqAtog RI-Z WLMUM-ASSISTANT VIQt PREMEN I 1920 Kent Drive Camp Hill, PA 17011 - HARPREET S. GULERIA ExhibitA a a s Stewart T#le Insurance Commitment Number. 2006080008COL* SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL that certain messuage, tenement and tract of land situate In the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, more fully bounded and described as follows, to wit: BEING Lot No. 32, with a 60 foot frontage on the North side of Kent Drive and a depth between parallel lines 120 feet in Block "B", as shown on Plan No. 4 of Highland Estates Development, drawn by D.P. Raffensperger, Registered Surveyor, revised March 9, 1949, and recorded March 21, 1941 in Plan Book No. 4, page 79, in the Recorder's Office in and for Cumberland County at Carlisle, Pennsylvania. HAVING THEREON erected a single dwelling house known as No. 1920 Kent Drive. UNDER AND SUBJECT to all existing easements, restrictions and conditions of record. Parcel #13-23-0547-167 I Ccrt i fy this to be recorded ICY Curaberland County PA ?-?- Recorder of Deeds ALTA Commitment Schedule C `BIB -19 6.8.1'G 217 (200608o008COL.PFD12006080008CO11118) Eykidit B ECombp-ndo NOME LOANS P.O. Banc 9048 Temecula, CA 92589-9048 SwW Psymw#s To. PO Box 660694 Dallas, TX 75266.0694 Sw,a Correspondence to. PO Box 5170, MS SV314B Simi Valley, CA 93065 4fk 111111111111111111111 7113 8257 1472 5349 3211 Harpreet S Guleda 1920 KENT DR CAMP HILL, PA 17011-5930 071203-MOPAI PRESORT First-Class Mall U.S. Postage and Fees Paid WSO ®Gt11111f1'rMdW HOME LOANS P.O. Box 660694 Danes, 7X 75266-0694 Send Payments to. PO Box 660694 Degas, 7X 75266-0694 December 3, 2007 Certified Mail: 7113 8257 1472 5349 3211 Return Reciept Requested Regular Mail Harpreet S Guleria 1920 KENT DR CAMP HILL, PA 170115930 FORECLOSURE This is an official notice that the mortgage on your home Is In default and the lender Intends to foreclose Specific I adon about the nature of the default is provided In the attached naass. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM f-1EMAP) may be able to help to save your home. This Notice explains how the proaram works To see If HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you whan you meet with he Counselina Agency. This Notice contains important legal Information. H you have arry 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 VMENDO EN SU CASA. SI NO.COMPRENDE EL CONTENDO DE ESTA NOTIFK:Aa6N OBTENGA UNA TRADUCCIbN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL Nt1MERO MENCIONADO ARREA. PUEDE SER ELEG13L.E PARA UN PRtSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(Sr Harpreet S Guleria PROPERTY ADDRESS: 1820 Kent Drive C HYI PA LOAN ACCT. NO.: amp . 17011 150857791 ORIGINAL LENDER: CURRENT LENDERISERViCER: Countrywide Home Loans Servicing 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 • Mace your check payable to Countrywide Hare Loans • Wrta your account number on your dock or money order • Wrte In add[lond amounts you are mdul (r trial le more flan $5000, please send catIlled check) • Dont s<ach your lack to the =LIP on • Dort send cash r aLWAi colreepondenoa ?fe Countrywide PO BOX 6WO94 Dallas, TX 75266-0694 PI"m upolbe i kdoenemn m tle "a•ae aided Mi wupm. Addeoeel Prilcpl /ddacnel Esuvn 7ff Cbuk Tubl 15085779110Q0o[147__ 9? 000479367 Account No.: 150857791 Property Address: 1920 Kent Drive Camp Hill, PA 17011 Current Service: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM Pbase %ft you amount manber an all dledn and convopondanm 9ya may change you a tag bury psymed idumad a roJadad Imyyouranaldal Irettdbn, eubpdb appirads ley. AccountNtxnber:130E677 4 Harpreet S Guleria Balarne Due for charges listed above: $4,793.67 as of 1710312007. 1920 I(ent Drive IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT" % YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT CONSUMER CREDIT COUNSELING AGENCIES - H 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 alter the date of this meeting. The names. M TDnh at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender 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 mature of your default.) H 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 IN out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision 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 filed 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 TENS 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: 1920 Kent Drive Camp Hill, PA 17011 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: 10101/2007 Late Charges: 10/01/2007 Other Late Charaes Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) E-mail use: ProMinnggyour e-mail address belowwillallow us tosendyouirfomredanan youraccourt AcwA Number. ta1M7At Harpred S GUeda E-mail address $4,675.83 $117.84 $0.00 $0.00 ($0.00) $4,793.67 NOW w pod YM PrI N moapbd prgwwda d pb*d ad blend 94 be @WW b tlw bred oda- - babiwnt dw, WM otlwnM epwory PdNW Q baNd by bw. If you Mind w . In WiMm b Pair sdrsdM mo ft m aiad we w1 ** !ar PtOwwtdt n bNrrae W b oddw ft morft pUanab of pb*d and I UNK 04 aaatar daNobrdw W bb dWW and dW wwwb )er an In own" am yar bin ad M b incise to adabrf p I I I I I of yar bm plows W* If yo wad at 5" wd altelnd appNad b On ptptrw I collar M prYtoaaltrdudrn. PodOW die ft Oowtyrddat< pdW b b nd woapl irodbad draft wlra Wsdp* goad b rr ¦ bntr aowaabr ar ladadrbn. HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,793.67, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made o v bt and sent to7 Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (301 DAYS of the date of this Notice, the lender Intends to exercise Its ruts 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 (30) 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 attomey'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 130) DAY period, you witi 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 (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late 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 same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - lt 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 Nome Loans Servicing LP Address: P. Q Sox 660694 Dallas, TX 73266--0694 Phone Number: 1.800-6696634 Fax Number I-W5.377-3432 Contact Person: US P7X-36 Attention; Loan Counselor EFFECT OF SHERIFF'S S AI - 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 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 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 INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE wrm a 7113 6257 1472 5349 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. Your ban 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 January 2, 2008, 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 'A 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 if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if 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 need 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 January 2, 2008 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 1-800-669-6654. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Acom Housing 14 S. 13th Street Harrisburg, PA 17104 717.213,0150 Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Ungleslown Road Harrisburg, PA 17102 888.511.2227 Community Action Commissior of Capital Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PHFA 211 North From Street Harrisburg, PA 17110 717.780.3840 800.342.2397 Loveshlp,Inc. 2320 North 51h Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avarua Waynesboro, PA 17268 717.762.3285 W ov SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01387 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRA VS GULERIA HARPREET S 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 GULERIA HARPREET S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , GULERIA HARPREET S 1920 KENT DRIVE CAMP HILL, PA 17011 PER NEIGHBOR, DEFENDANT MOVED OUT 2-3 MONTHS AGO. WATER WAS SHUT OFF 1/22/08. NO FORWARDING AT POST OFFICE. Sheriff's Costs: Docketing 18.00 Service 14.40 Not Found 5.00 Surcharge 10.00 .00 3?18?ng 47.40 So answers : R. Th as Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 03/13/2008 Sworn and Subscribed to before me this day of A. D. GOLDBECK cCAFFERTY & MCKEEVER MICHAEL T. CKEEVER Attorney I.D.# 6129 Suite 5000 - M llon Independence Center 701 Market Str xi Philadelphia, P 19106-1532 215-627-1322 BY: David B. ein, Esq. Attorney I.D.# 2628 Attomev for PI 'tiff MORTGAGE LECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX C-35 Plano, TX 750$4 vs. HARPREET S GULERIA 1920 Kent Driv e Camp Hill, PA: 17011 THIS COLLECT A WILL BE US: IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-1387 W FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO BT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Substituted Si 1. PA, 17011, h4 2. premises. 3. Fein, Esquire, that I am not it was not vos Plaintiff, by and through its attorney, David B. Fein, Esq., in support of its Motion for represents as follows: Plaintiff is the holder of a first mortgage upon the premises 1920 Kent Drive, Camp Hill, the "mortgaged premises". Defendant, HARPREET S. GULERIA, is the mortgagor and real owner of the mortgaged Pursuant to Cumberland County Local Rule 208.3(ax2) and/or Rule 208.3(a)(9), I, David certify that no judge has ruled on any other matters in this case. I further certify that the Defendant has obtained counsel. Moreover, due to the nature of this motion, to locate or contact the Defendant to request his concurrence. 4. of the Coi 5. S. Guleria, at tl out 2-3 months 6. whereabouts of to serve the C regular mail b The last known address of Defendant, Harpreet S. Guleria, is as set forth in Paragraph 2 The Sheriff has been unable to effect service of the Complaint upon Defendant, Harpreet property, 1920 Kent Drive, Camp Hill, PA, 17011.Per the Sheriff, the Defendant moved ago, according to the neighbor. . The following investigation was conducted in a good faith attempt to ascertain the Defendant, Harpreet S. Guleria. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff iplaint upon Defendant, Harpreet S. Guleria, by posting the premises and certified and he Defendant's last known address. Respectfully submitted, David B. Fein, Esq. ProVest, LLC Affidavit of Good Faith Investigation Client provided File Number: & Attomey Firm: Subject Name: He Property Address: Street: 1920 Kent City: Camp Hill Skip Results: Last Known Street: 1920 Kent City: Camp Hill Death Records: Social Security Employment Creditor Info Department of Mot Vehicle Records: Public Licenses (F Real Estate, etc): Voter Registration Address Search: Comments: No active milih 717-737-3790: answer. 717-737-2709: 717-737-6222: MCCAFFERTY & MCKEEVER S. Guleria a/k/a Harpreed S. Guleria State: PA Date of Birth: None Found State: PA Zip 17011 ProVest File Number: 913305 Dates: As of 3/31/2008 Phone: Zip: 17011 As of 3/31/2008, the Social Security Administration has no death record on file for Harpreet S. Guleria a/k/a Harpreed S. Guleria. Search Completed. Unable to verify current employer. Creditors indicated the last reported address for Harpreet S. Guleria a/k/a Harpreed S. Guleria as 1920 Kent Drive, Camp Hill, PA 17011. The Pennsylvania Department of Motor Vehicles provided no change for Harpreet S. Guleria a/k/a Harpreed S. Guleria from 1920 Kent Drive, Camp Hill, PA 17011. Search performed provided no information. The County Voters Registration Office has no listing for Harpreet S. Guleria a/k/a Harpreed S. Guleria. Has no change for Harpreet S. Guleria a/k/a Harpreed S. Guleria from 1920 Kent Drive, Camp Hill, PA 17011. found. listed to Harpreed and Sonia Guleria at 1920 Kent Drive, Camp Hill, PA 17011, there was no with neighbor, Lester Arnold, stated defendant moved, does not know current address. possible neighbor, K. Berrigan, there was no answer. On 3/31/2008, I, LLC. I have con investgation. Garrett being duly sworn according to the law, deposes and says: I am employed by ProVest, d an investigation into the whereabouts of the above named subject. Above are the results of my Subscritmd wd Wmm to betwe rm, J Ara 0Gx7ALT80digag?ft lrY FWIc Date: 3/3112008 MY'COMMIl1f?WN' -CASE NO: 2008-01387 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRA VS GULERIA S R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn a?cording to law, says, that he made a diligent search and inquiry for ',the within named DEFENDANT GULERIA HARP?,EET S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND as to the within named DEFENDANT , GULERIA HARPREET S 1920 KENT CAMP HILL, PIA 17011 PER NEIGHBOR, DEFENDANT MOVED OUT 2-3 MONTHS AGO. WATER WAS SHUT OFF 1/22/08. NO FORWARDING AT POST OFFICE. Sheriff's Costs: Docketing Service Not Found Surcharge SHERIFF'S RETURN - NOT FOUND So answer 18.00 14.40 5.00 R. Th as Kline 10.00 Sheriff of Cumberland County .00 47.40 GOLDBECK MCCAFFERTY MCKEEVER 03/13/2008 Sworn and Suibscribed to before me this day of .D. GOLDBECK cCAFFERTY & McKEEVER MICHAEL T. CKEEVER Attorney I.D.# 6129 Suite 5000 - M llon Independence Center 701 Market S t Philadelphia, P 19106-1532 215-627-1322 BY: David B. ein, Esq. Attorney I.D.# 2628 Attornev for Plaintiff MORTGAGE LECTRONIC REGISTRATION SYSTEMS, IN., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX C-35 Plano, TX 750 4 vs. HARPREET S GULERIA 1920 Kent Drive Camp Hill, PA 17011 VERIFICATION I, Dz foregoing M and belief. I relating to ut IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-1387 B. Fein, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the for Substituted Service are true and correct to the best of my knowledge, infonnation that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 falsification to authorities. BY: Da B. Fein, Esq. GOLDBECK cCAFFERTY & McKEEVER MICHAEL T. CKEEVER Attorney I.D.# 6129 Suite 5000 - M lion Independence Center 701 Market S t Philadelphia, P 19106-1532 215-627-1322 BY: David B. ein, Esq. Attorney I.D.# 2628 Attornev for PI ' tiff MORTGAGE LECTRONIC REGISTRATION SYSTEMS, ., ACTING SOLELY AS A NOMINEE FOR AMERI 'S WHOLESALE LENDER IN THE COURT OF COMMON PLEAS 7105 Corporat Drive PTX C-35 OF Cumberland COUNTY Plano, TX 750 4" vs. No. 08-1387 HARPREET S GULERIA 1920 Kent Dri e Camp Hill, PA 17011 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) =has as filed a Complaint in Mortgage Foreclosure against Defendant, Harpreet S. Guleria, which been unable to personally serve upon Defendant, Harpreet S. Guleria. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430( CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, Harpreet S. Guleria, by posting the and certified mail and regular mail to the Defendant's last known address. Respectfully submitted, avid B. Fein, Esq. GOLDBECK cCAFFERTY & McKEEVER MICHAEL T. CKEEVER Attorney I.D.# 6129 Suite 5000 - M lion Independence Center 701 Market S t Philadelphia, P 19106-1532 215-627-1322 BY: David B. ein, Esq. Attorney I.D.# 2628 Attorney for P1 ' tiff MORTGAGE LECTRONIC REGISTRATION SYSTEMS, IN "' kCTING SOLELY AS A NOMINEE FO AMERICA'S WHOLESALE LENDER 7105 Corporat Drive PTX C-35 Plano, TX 750 4 VS. HARPREET S. GULERIA 1920 Kent Dri-le Hill, PA 7011 IN THE COURT OF COMMON PLEAS Of Cumberland County No. 08-1387 CERTIFICATE OF SERVICE David . Fein, Esq., does hereby certify that true and correct copies of the foregoing Motion for Substituted Se .ce have been served upon the Defendant, Harpreet S. Guleria, this Oday f ,*O'/ , 2008, by first lass mail, postage prepaid. Harpreet S. Gul a 1920 Kent Driv Camp Hill, PA 7011 BY: David B. Fein, Esq p m;r; r7i 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1387 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P. 2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of COUNTRYWIDE HOME LOANS, INC. for Voluntary Substitution under Pa.R.C.P. 2352 and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the Plaintiff is 7105 Corporate Drive, PTX C-35 Plano, TX 75024 MICHAEL T. MCKEEVER, ESQUIRE 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1387 STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P. 2352 COUNTRYWIDE HOME LOANS, INC., by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned action is one in mortgage foreclosure regarding the premises as noted in the caption. 2. The subject of the above-captioned action is a first mortgage on said premises recorded at Mortgage Book 1968, Page 2156 in the Office of the Recorder of Deeds for this County. 3. The original Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER. 4. COUNTRYWIDE HOME LOANS, INC. is the successor in interest to the Plaintiff by Assignment lodged for recording in the Office of the Department of Records and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. Respectfully submitted, 7?mlcry a I ?h"On MICHAEL T. MCKEEVER, ESQUIRE 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. Plaintiff HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) CERTIFICATE OF SERVICE Term No. 08-1387 Michael T. McKeever, Esquire, hereby certifies that he did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on May 20, 2008. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE *L7 V_U vel Michael T. McKeever, Esq. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER, Plaintiff V. HARPREET S. GULERIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-1387 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SUBSTITUTED SERVICE I ORDER OF COURT AND NOW, this 27`" day of May, 2008, upon consideration of Plaintiffs Motion for Substituted Service under Pa. R.C.P. 430(a), the motion is granted to the extent that Plaintiff is authorized to serve the complaint in mortgage foreclosure upon Defendant, Harpreet S. Guleria, by (a) posting the premises at 1920 Kent Drive, Camp Hill, Cumberland County, Pennsylvania, (b) mailing a copy by certified and regular mail to Defendant's last known address at 1920 Kent Drive, Camp Hill, PA 17011, said service to be deemed complete upon mailing, and (c) publication once in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County, Pennsylvania. ALL FURTHER service of legal papers upon Defendant, including but not limited to motions, petitions, rules, and notice of sheriffs sale, may be made by (a) certified and regular mail to Defendant's aforesaid last known address, said service to be deemed complete upon mailing, and (b) posting of the aforesaid premises. BY THE COURT, - .'r _ :?~`-? ,i`;? j y. i ,?9 ,._ Michael T. McKeever, Esq. ite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 Attorney for Plaintiff ,Xarpreet S. Guleria 1920 Kent Drive Camp Hill, PA 17011 Defendant, pro Se :rc 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 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) Term No. 08-1387 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GOLDBECK, McCAFFERTY & McKEEVER f By Michael T. McKeever, Esq. Attorney for Plaintiff c- w ? CA I- GOLDBECK WCAFFERTY & WKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. HARPREET S. GULERIA Mortgagor(s) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) Term No. 08-1387 CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER ESQUIRE hereby certifies that on he did serve upon Defendant(s) HARPREET S. GULERIA a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated May 27, 2008. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, ;A" ?Ux? IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE C) ° i C ? -n ril t - ' rn 77 i C11 SHERIFF'S RETURN - REGULAR CASE NO: 2008-01387 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRA VS GULERIA HARPREET S RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GULERIA HARPREET S the DEFENDANT , at 0013:22 HOURS, on the 9th day of June 2008 at 1920 KENT DRIVE CAMP HILL, PA 17011 by handing to POSTED PROPERTY AT 1920 KENT DR CAMP HILL, PA 17011 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: So Answers: Docketing 18.00 Service 15.00 Affidavit .00 Surcharge 10.00 T omas K in Posting 6.00 /?ryldy 49.00 06/10/2008 1 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: / before me this day Deputy Sheriff of A. D. M In the Court of Common Pleas of Cumberland County COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 08-1387 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 HARPREET S. GULERIA by default for want of an Answer. Assess damages as follows: Debt Interest from 07/23/2008 to Date of Sale per diem at $33.83 Total (Assessment of Damages attached) $196,399.95 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 AJ1, ` 1?AI?JI?C(? 7 - X x A .Michael T. McKeever Attorney for Plaintiff I.D. #56129 023 AND NOW 11, AS qM 1 0200$ Judgment is entered in favor of COUNTRYWIDE HOME LOAN INC. and against HARPREET S. GULERIA by default for want of an Answer and damages assessed in the sum of $196,399.95 as per the above certification. - !ljzkl A Pro onotary MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER, Plaintiff V. HARPREET S. GULERIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 08-1387 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SUBSTITUTED SERVICE ORDER OF COURT AND NOW, this 27`x' day of May, 2008, upon consideration of Plaintiff's Motion for Substituted Service under Pa. R.C.P. 430(a), the motion is granted to the extent that Plaintiff is authorized to serve the complaint in mortgage foreclosure upon Defendant, Harpreet S. Guleria, by (a) posting the premises at 1920 Kent Drive, Camp Hill, Cumberland County, Pennsylvania, (b) mailing a copy by certified and regular mail to Defendant's last known address at 1920 Kent Drive, Camp Hill, PA 17011, said service to be deemed complete upon mailing, and (c) publication once in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County, Pennsylvania. ALL FURTHER service of legal papers upon Defendant, including but not limited to motions, petitions, rules, and notice of sheriff's sale, may be made by (a) certified and regular mail to Defendant's aforesaid last known address, said service to be deemed complete upon mailing, and (b) posting of the aforesaid premises. BY THE COURT, J. 63234FC 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: July 8, 2008 TO: HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 TO: HARPREET S. GULERIA 1920 Kent Drive Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1387 Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, HARPREET S. GULERIA, is about unknown years of age, that Defendant's last known residence is 1920 Kent Drive Camp Hill, PA 17011, 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: 1 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. HARPREET S. GULERIA (Mortgagor(s) and Record owner(s)) 1920 Kent Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-1387 ORDER FOR JUDGMENT Please enter Judgment in favor of COUNTRYWIDE HOME LOANS, INC., and against HARPREET S. GULERIA 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 $196,399.95. ??V?w I - " I LU JC4 Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are HARPREET S. GULERIA, 1920 Kent Drive Camp Hill, PA 17011; GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $173,315.03 Interest from 09/01/2007 through $11,028.57 07/22/2008 Reasonable Attorney's Fee $8,665.75 Late Charges $589.20 Costs of Suit and Title Search $900.00 Escrow Payments Due 5 X $380.28 $1,901.40 $196,399.95 ?.? 7, UU1 I.I-rlT GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 013rd day of %ju-.14f 2008 damages are assessed as above. Pro frothy C7 ? n sr? ?7 t ? .. Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA (Mortgagors and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) No. 08-1387 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION- LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1387 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 07/23/2008 to Date of Sale per diem at $33.83 (Costs to be added) $196,399.95 GOLDBECK McCAFFERTY & McKEEVER 4_ BY: Michael T. McKeever Attorney for Plaintiff O d O ?v o ??w x Q O U ? H ? U 3 O a? yo ? ?Qd Y p.., w pox ^, H r Qr/Wy]. 01 U x? 0 TL 4? W o ? T 0 H H D L. W Q O d c H ? t o" w? W' U a `k %J, LA 00 o ? c o to ? .I H ? a ?U U ? c?. y O N O? 45 Q C? ?o a 0 O i 3 s p woo r co k C7. C J ALL that certain messuage, tenement and tract of land situate in the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, more fully bounded and described as follows, to wit: BEING Lot No. 32, with a 60 foot frontage on the North side of Kent Drive and a depth between parallel lines 120 feet in Block "B", as shown on Plan No. 4 of Highland Estates Development, drawn by D. P. Raffensperger, Registered Surveyor, revised March 9, 1949, and recorded March 21, 1941 in Plan Book No. 4, page 79, in the Recorder's Office in and for Cumberland County at Carlisle, Pennsylvania. HAVING THEREON erected a single dwelling house known as No. 1920 Kent Drive Camp Hill, PA 17011 UNDER AND SUBJECT to all existing easements, restrictions and conditions of record. Parcel #13-23-0547-167 -1. '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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1387 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS, INC., 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: 1920 Kent Drive Camp Hill, PA 17011 I .Name and address of Owner(s) or Reputed Owner(s): HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 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: 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 1920 Kent Drive Camp Hill, PA 17011 (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 unsworn falsification to authorities. DATED: July 22, 2008 51 . GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff C:P °i r, 7 N s r';, 7 08-1387 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s Term No. 08-1387 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: GULERIA, HARPREET S. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Your house at 1920 Kent Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $196,399.95 obtained by COUNTRYWIDE HOME LOANS, INC. 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 COUNTRYWIDE HOME LOANS, INC., 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. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. 08-1387 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-1387 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.12hfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 cr,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 6323417C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attornev for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-1387 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Uh)w -A -Uuluo Michael T. McKeever Attorney for plaintiff n <_? rt C -TI y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1387 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC., Plaintiff (s) From HARPREET S. GULERIA (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 $196,399.95 L.L.$ 0.50 Interest from 7/23/08 to Date of Sale per diem at $33.83 Atty's Comm % Due Prothy $2.00 Atty Paid $225.40 Other Costs Plaintiff Paid Date: 7/23/08 Prothono (Seal) By: 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 Deputy Telephone: 215-627-1322 Supreme Court ID No. 56129 s i 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 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Defendant PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: No. 08-1387 Kindly vacate the judgment upon payment of your costs only. -110? MICR L T. MCKEEVER, ESQUIRE 4 00 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 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 08-1387 By: GOLDBECK McCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF 00 ?O r?s {s ?•? MM 5rn a O 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 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 08-1387 By: J d'1t? IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GOLDBECK MCCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF R3 .p ?t J ? A N co 4 . . .. 08-1397 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz August 22, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. L' a 'e Coyne, Editor SWORN TO AND SUBSCRIBED before me this 22-day of August, 2008 d Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas Cumberland County Civil Action-Law No. 08-1387 COUNTRYWIDE HOME LOANS, INC., Plaintiff VS. HARPREET S. GULERIA, Mortgagor and Real Owner, Defendant TO: HARPREET S. GULERIA, MORT- GAGOR AND REAL OWNER, DEFENDANT, whose last known address is 1920 Kent Drive, Camp Hill, PA 17011. THIS FIRM IS A DEBT COLLEC- TOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OB- TAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECT- ING THE DEBT. You are hereby notified that Plaintiff, COUNTRYWIDE HOME LOANS, INC., has filed a Mortgage Foreclosure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 08-1387, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located, 1920 Kent Drive, Camp Hill, PA 17011, whereupon your property will be sold by the Sheriff of Cumber- land County. 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 ap- pearance 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 PA- PER 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 RE- DUCED FEE OR NO FEE. LEGAL SERVICES INC. 401 E. Louther St. Ste. 103 Carlisle, PA 17013 (717) 243-9400 or CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 717-249-3166 JOSEPH A. GOLDBECK, JR., ESQUIRE GOLDBECK McCAFFERTY & McKEEVER, P.C. Attorneys for Plaintiff Suite 5000 Mellon Independence Center 701 Market St. Philadelphia, PA 19106-1532 (215) 825-6411 Aug. 22 6 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Peterson, Classified Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): June 6, 2008 COPY OF NOTICE OF PUBLICATION NOTICE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW No. 08-1387 NOTICE OF ACTION IN MORTGAGE FORECLOSURE COUNTRYWIDE HOME LOANS, INC., Plaintiff vs. HARPREET S. GULERIA, Mortgagor and Real Owner, Defendant TO: HARPREET S. GULERIA, MORTGAGOR AND REAL OWNER, DEFENDANT, whose last known address is 1920 Kent Drive, Camp Hill, PA 17011. THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR COENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. ° You are hereby notified that Plaintiff, COUNTRYWIDE HOME LOANS, INC., has filed a Mortgage Foreclosure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 08-1387, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located, 1920 Kent Drive, Camp Hill, PA 17011, whereupon your property will be sold by the Sheriff of Cumberland County. 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. 401 E. Louther St., Ste. 103, Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St., Carlisle, PA 17013 717-249-3166 Joseph A. Goldbeck, Jr., Attorney for Plaintiff Goldbeck McCafferty & McKeever, P.C. Suite 5000, Mellon Independence Center 701 Market St. Philadelphia, PA 19106-1532 215-825-6411 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this 6th day of June, 2008. Notarv Pu lic My commission expires: (4)6f 09 NOURWL SEAL BONM A CANM No" RIbft CAFANU SOROUISK CNIIIIIISI PD COUNTY Mfr Comphdon Expw Jun S. 2009 n v w J/YAAtQ1! VA4%0 AAWHOO MMA yaw It1?i0C1 ¦? 08'0'7-00R £1(1:78 FIT, 115 627 7734 ¦: ¦ ¦ ¦ C_,0i.DI3FCK ¦ z GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 6274322 FAX (215) 627-7734 August 7, 2008 R. Thomas Kline SHERIFF OF CUMBERLAND COUNTY Sheriffs Office I Courthouse Square Carlisle, PA 17013 RE: COUNTRYWIDE HOME LOANS, INC. vs. HARPREET S. GULERIA Term No. 08-1387 Property address: 1920 Kent Drive Camp Hill, PA 17011 Sheriffs Sale Date: Dear Sir/Madam: Cumberland Kindly stay the Sheriffs Sale with reference to the above-captioned matter and return any unused costs. I collected $ 0.00 towards my client's debt. Thank you for your cooperation. Very truly yours, MICHAEL 1'. MCKEEVER MTM/mc **Original writ and sale package returned cc: Andrea Givens to the Prothonotary on 9 / 1 6 / 0 8 COUNTRYWIDE HOME LOANS INC, Acct. 4150857791 **Copy of writ and $1500.00 deposit returned to Attorney McKeever on 9/16/08 ? 6 w In the Court of Common Pleas of Cumberland County COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-1387 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 HARPREET S. GULERIA by default for want of an Answer. Assess damages as follows: Debt Interest from 10/11/2008 to Date of Sale per diem at $33.83 Total (Assessment of Damages attached) $200,043.67 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 Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW t)P,+_f269 , apgQ , Judgment is entered in favor of COUNTRYWIDE HOME LOANS, INC. and against HARPREET S. GULERIA by default for want of an Answer and damages assessed in the sum of $200,043.67 as per the above certification. AfA Pr ono %ry 63234FC 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: July 8, 2008 TO: HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 TO: HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1387 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, HARPREET S. GULERIA, is about unknown years of age, that Defendant's last known residence is 1920 Kent Drive Camp Hill, PA 17011, 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: pgl(vl g 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. HARPREET S. GULERIA (Mortgagor(s) and Record owner(s)) 1920 Kent Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-1387 ORDER FOR JUDGMENT Please enter Judgment in favor of COUNTRYWIDE HOME LOANS, INC., and against HARPREET S. GULERIA 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 $200,043.67. Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are HARPREET S. GULERIA, 1920 Kent Drive Camp Hill, PA 17011; GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff 1 A ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $173,315.03 Interest from 09/01/2007 through $13,734.97 10/10/2008 Reasonable Attorney's Fee $8,665.75 Late Charges $765.96 Costs of Suit and Title Search $900.00 Escrow Payments Due 7 X $380.28 $2,661.96 $200,043.67 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this le day of 00, { , 2008 damages are assessed as above. 24A??Z Pro othy -='=*' / O c r CA 00 oa -0 5M a . 1 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA (Mortgagors and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) No. 08-1387 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 er r against you. urt Lo Prothonotary By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1387 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 10/11/2008 to Date of Sale per diem at $33.83 (Costs to be added) $200,043.67 i GOLDBtCR McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ? U a 0 cc C =v o 00 x Hza Q O N ? U 9P 0 a w pox d ? U x? 0 ?J1 A 3 o`c (N .a O F U W ?+ W ? 6,2 Q) C " H ? 3 o? WW? U P+ in g 0 m N I4 U., H v ?U y o ?CQ d 'c Q„ ? o a. 0 ? O O Y o v ca - ID p .c, o ?o bd 0 -c t+10 bb 00??°O p O b _ ` a S D 'Z7 t7 ? n G ° ca Ca c, J s yo-.,'. r c3 0 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-1387 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS, INC., 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: 1920 Kent Drive Camp Hill, PA 17011 I.Name and address of Owner(s) or Reputed Owner(s): HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 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: ?? 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 1920 Kent Drive Camp Hill, PA 17011 (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 unsworn falsification to authorities. DATED: October 10, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff a T, CD O r E5 -c Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-1387 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Mic ael T. McKeever Attorney for plaintiff ra 0 ? v CD n r 3i v 08-1387 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) Term No. 08-1387 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: GULERIA, HARPREET S. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Your house at 1920 Kent Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $200,043.67 obtained by COUNTRYWIDE HOME LOANS, INC. 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 COUNTRYWIDE HOME LOANS, INC., 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. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. .r 08-1387 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 i 08-1387 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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&oldbecklaw.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 6323417C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1387 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC., Plaintiff (s) From HARPREET S. GULERIA (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 $200,043.67 L.L. Interest from 10/11/08 to Date of Sale per diem at $33.83 Atty's Comm % Due Prothy $2.00 Atty Paid $6191. yo Plaintiff Paid Date: 10/15/08 (Seal) Other Costs to be added rothonota 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 63234FC BY: Michael T. McKeever CF: 03/03/2008 Attorney I.D.#56129 SD: 03/04/2009 Suite 5000 - Mellon Independence Center 701 Market Street $200,043.67 Philadelphia, PA 19106-1532 215-627-1322 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-1387 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: ( ) Personal Service by the Sheriffs Office/competent adult (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 Attomey 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/ QEs 5060R1 930 ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). (4 t he at) 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, oot BY: Michael T. McKeever, Esquire Attorney for Plaintiff ?L LL $ o 0 O - -- -- N 1 ? y LL C,4 • I,- o Q fnLL ? /x jo.*V Q L) ?pq y !O g 17Q.? ? i O V o = , O ? °?+nrn o o $ u a 'w c> I r U - Q? ? N a L a D m on U z O cli ? g I . ? ? U V a A a J C E LLJ E 'MV E 0 K C' 0.' ty ?a?? j a w ' y W V- o D a m H 3 LV Z U) ? = zo a o ? ? L ? ? I _ O 0$?,j S Y ? Cl ? El ?? C? W Y Q. C LyMd Z O 2 m. 10 a,a c N (o o W h a m Q d , J N Z) = L W t U 7? W C9?C? 00 w UaU g 7 m? 0.m=a a R I AIN a 4 ? z r UJI Z oc a a 11-4 t? Q Y lu J N 0 be pC 0to r c e l6m a E?F W-?JO I ? gzgyyyy ? ? o5 Z40 m r ri M la , t 0 ti pp l a c a C 0 co 0 c 0 1 N O 1 m 4 a um. ti th ILL co 0 N O N A C O U v c c? z .a E U U U- fY Q w LLJ J C7 a Q vv?raiT- MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER, Plaintiff V. HARPREET S. GULERIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 08-1387 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SUBSTITUTED SERVICE ORDER OF COURT AND NOW, this 27`h day of May, 2008, upon consideration of Plaintiff's Motion for Substituted Service under Pa. R.C.P. 430(a), the motion is granted to the extent that Plaintiff is authorized to serve the complaint in mortgage foreclosure upon Defendant, Harpreet S. Guleria, by (a) posting the premises at 1920 Kent Drive, Camp Hill, Cumberland County, Pennsylvania, (b) mailing a copy by certified and regular mail to Defendant's last known address at 1920 Kent Drive, Camp Hill, PA 17011, said service to be deemed complete upon mailing, and (c) publication once in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County, Pennsylvania. ALL FURTHER service of legal papers upon Defendant, including but not limited to motions, petitions, rules, and notice of sheriffs sale, may be made by (a) certified and regular mail to Defendant's aforesaid last known address, said service to be deemed complete upon mailing, and (b) posting of the aforesaid premises. BY THE COURT, J. Form 3877 Domestic USPS Firm Mailing Book Name and Address of Sender: Permit Number Sequence Number JOSEPH A GOLDBECK JR 1406A MELLON INDEPENDENCE CENT 701 MARKET ST STE 5000 Ascent - MAC v7.50.7.51.J PHILADELPHIA, PA 19106 ---------------------------------------------------------------------------------------------------------------------------------- Piece ID Article # Delivery Address SS Fee Postage Value Sender Charges Addreaaea Name Tvne Insur./Register Due Total 000-? 63234HG3-04 71114342363000517639 GULERIA, HARPREET S. C 2.70 0.42 4.1 1920 Kent Drive ERR 1.00 Camp Hill, PA 17011 --------------------------------------------------------------------------------------------------------------------------------- Page Totals: 1 3.70 0.42 4.12 Cumulative Totals: 1 3.70 0.42 4.12 USPS CERTIFICATION Total Number of Pieces Received: Round Stamp: Signature of Receiving Employee Form 3877 (Facsimile) Date of Manifest: 02/10/2009 Page 1 C11 FB ?; .9 * 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff of Cumberland County CIVIL ACTION - LAW VS. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 Term No. 08-1387 COUNTRYWIDE HOME LOANS, INC., 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: 1920 Kent Drive Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS 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: 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 1920 Kent Drive Camp Hill, PA 17011 (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 unswom falsification to authorities. DATED: February 10, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff a ?? f?..? . , ?? fr. ? L. '' '? '-'? . .! ???? ? i L3J L.? ?_? ? i?-? { L? ..r?- ?} C?? V GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor and Record Owner 1920 Kent Drive Camp Hill, PA 17011 Defendant Term No. 08-1387 MOTION TO POSTPONE SHERIFF'S SALE Plaintiff, by and through its attorneys, in support of its Motion to Postpone Sheriffs Sale represents as follows: 1. Plaintiff is the holder of first mortgage upon the premises, 1920 Kent Drive Camp Hill, PA 17011, hereinafter the "mortgaged premises." 2. Defendant is the mortgagor and record owner of the mortgaged premises. 3. A Sheriffs Sale of the mortgaged premises was scheduled for March 4, 2009, and was postponed pursuant to PaR.C.P. 3129.1 until April 1, 2009. 4. The Sale for April 1, 2009 was postponed until May 6, 2009 5. A Sheriff's Sale of the mortgage premises is scheduled for May 6, 2009 and will need to be postponed to June 10, 2009 due to the Fannie Mae Moratorium. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 6. There is no prejudice to any party. WHEREFORE, Plaintiff requests that the Court enter Plaintiffs proposed order, which will postpone the sale until Thursday, June 10, 2009. Respectfully submitted, GOLDBECK MCCAFFERTY & MCKEEVER By: Michael . McKeever, Esquire GOLDBECK McCAFFERTY & McKEEVER Michael McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 Attorney I.D. #56129 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor and Record Owner 1920 Kent Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 08-1387 MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 3129.3(b) allows a judgment creditor to postpone a sheriffs sale up to two times within a one hundred thirty day period without new notice. The postponement must be announced to all assembled bidders. As outlined in the attached motion, the Sheriff s Sale has already been postponed as allowed by Pa.R.C.P. 3129.3(b). Plaintiff seeks Court approval under, inter alia, Pa.R.C.P. 126, to postpone the sale again. This postponement will be announced to all assembled bidders. CONCLUSION For all the reasons discussed above and in the attached Motion, the Court should enter the attached Order postponing the Sheriffs Sale. Respectfully submitted, GOLDf^BECK McCAFFEERTY & McKEEVER By A&K ? VU bQ Michael T. McKeever, Esquire GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor and Record Owner 1920 Kent Drive Camp Hill, PA 17011 Defendant CERTIFICATE OF SERVICE Term No. 08-1387 Michael T. McKeever, Esquire, attorney for Plaintiff, hereby certifies that a copy of Plaintiffs Motion to Postpone Sheriffs Sale was mailed by first class mail, postage prepaid, to Defendant(s) on May 4, 2009. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Respectfully submitted, GOLDBECK MCCAFFERTY & MCKEEVER By: V'1X?t . Michael T. McKeever, Esquire GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor and Record Owner 1920 Kent Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 08-1387 VERIFICATION Michael T. McKeever, Esquire, hereby states that he is the attorney for Plaintiff herein, and that all of the facts set forth within the attached Motion to Postpone Sheriffs Sale are true and correct to the best of his knowledge, information and belief. The undersigned understands that the foregoing statements are made subject to the penalties of 18 P.S. Section 4904. Michael T. 4McKer, Aquire ?I FILED-0!-' ';CE OF TMcF n'''- .';.',gin ARY 2009 MAY -5 FN 12: 0 I ?i?'V1C:.' ??v r t MAY 0 5 2008 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA Mortgagor and Record Owner 1920 Kent Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 08-1387 ORDER AND NOW, this 5 day of N a -1 , 2009 upon consideration of Plaintiffs Motion to Postpone Sheriffs Sale and any response thereto, it is ORDERED and DECREED: That the Motion is granted and the Sheriffs Sale in the above-captioned matter is hereby postponed until Wednesday, June 10, 2009, and month-to-month thereafter, without need for further advertisinG W_.j__, - JOJ -?/T ri, .,..?, ? 1 i h1? 9- ?,a?164UZ Ll r ^ ...q„ Countrywide Home Loans, Inc. In The Court of Common Pleas of VS Cumberland County, Pennsylvania Harpreet S. Guleria Writ No. 2008-1387 Civil Term Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on November 19, 2008 at 1137 hours, she 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: Harprett S. Guleria, pursuant to order of court by posting the premises located at 1920 Kent Drive, Camp Hill, Cumberland County, Pennsylvania with its contents according to law. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2009 at 1737 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 Harpreet S. Guleria located at 1920 Kent Drive, Camp Hill, 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: Harpreet S. Guleria, by regular mail to her last known address of 1920 Kent Drive, Camp Hill, PA 17011. This letter was mailed under the date of January 9, 2009 and returned to the Sheriffs Office on January 13, 2009. 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 10, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of Fannie Mae, of, P.O. Box 650043, Dallas, TX, 75265-0043, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $ 1,004.57. Sheriffs Costs: Docketing $30.00 Poundage 19.68 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 2.00 Mileage 27.00 Levy 15.00 Surcharge 20.00 Post Pone Sale 60.00 Posting 6.00 Goldbeck McCafferty & McKeever BY: Mieh2iel T. McKeever t Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. HARPREET S. GULERIA (Mortgagor(s) and Record Owner(s)) 1920 Kent Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1387 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS, INC., 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: 1920 Kent Drive Camp Hill, PA 17011 I.Name and address of Owner(s) or Reputed Owner(s): HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 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: .f 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 1920 Kent Drive Camp Hill, PA 17011 (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 unsworn falsification to authorities. DATED: October 10, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 08-1387 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 COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. HARPREET S. GULERIA Mortgagor(s) and Record Owner(s) 1920 Kent Drive Camp Hill, PA 17011 ACTION OF MORTGAGE FORECLOSURE Defendant(s' Term No. 08-1387 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: GULERIA, HARPREET S. HARPREET S. GULERIA 1920 Kent Drive Camp Hill, PA 17011 Your house at 1920 Kent Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $200,043.67 obtained by COUNTRYWIDE HOME LOANS, INC. 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 COUNTRYWIDE HOME LOANS, INC., 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. 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. 08-1387 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www. hp fa.org/consumers/homeowners/real gVx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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(2goldbecklaw.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 63234FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OI'' PENNSYLVANIA; NO 08-1387 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC., Plaintiff (s) From HARPREET S. GULERIA (I) 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 $200,043.67 L.L. Interest from 10/11/08 to Date of Sale per diem at $33.83 Atty's Comm % Due Prothy $2.00 Atty Paid $aa1.g0 Other Costs to be added Plaintiff Paid Date: 10/15/08 rothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEI. 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 #29 On November 12, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 1920 Kent Dr., Camp Hill more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 12, 2008 By: Real Estate er ea an g The Patriot-News Co. ,812 Market St. Harrishurg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE Z4 e P atriatwxtw 5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: REAL ESTATE SALE 140.29 wrltNo. 29u111-1307CWH Term 01 /21 /09 Hoft* t ou+e, rnc.. YS 01/28/09 HM~ S.'Gutettla 02/04/09 Attorney 1MchaN McKeever LEGAL DE66101110fi N ......... .... ......... ALL that certain the ge, teaemeot and trad j: of Ind einthe7bwnahiPiofhoeaerAlien, f Sworn to a sub 'ribed before me this 25 dayof Fe96ruary, 2009 A.D. County of Cuml>t md,_ Connamwealth o Ptmsylvania, mat fully bound and descnW f ll s t s ` 1 ?''-. ow as , o w . o BEING [.ot No. 11; wi&s '?Y foot frontage on _ ? ..•,..,?-c 1. l ?j?.t ?'' /? 1 ?.??e the North side of Key Dave and a depth. Notary Public between pars" lines 121 feet in Block "B", as shown os'P1an No. 4 of ftVand Estates Dnitl Pmany drawn,b D ._ P. RaffenTRer, R%istered revised March 9,1949, and COMMONWEALTH OF PENNSYLVANIA recorded Much 21, 1941 m_PW Book No. 4, Notarial Seal page 79, in ft Rawrdes s Office in and for Sherrie L Kisner, Notary Public 0mbertmd Comfy st Carlisle, Ptunsylvania. Cllr Of Harrisburg, Dauphin County HAVING THEREON erc*d a sin* dwelling My ColtN 6sion Expires Nov. 28, 2011 house known' as No. 1921 Rent I)trve Camp Member, Pennsylvania Association of Notaries Hill, PA 17011 UNDER AND SUBJYC!' to all existing eamneW nstricsitms and conditions of recoed. Parcel#13-23-0547-167 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: January 30, February 6, and February 13, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 29 Writ No. 2008-1387 Civil Countrywide Home Loans, Inc. vs. Harpreet S. Guleria Atty.: Michael McKeever ALL that certain messuage, tene- ment and tract of land situate in the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, more fully bounded and described as follows, to wit: BEING Lot No. 32, with a 60 foot frontage on the North side of Kent Drive and a depth between parallel lines 120 feet in Block °B°, as shown on Plan No. 4 of Highland Estates Development, drawn by D. P. Raffen- sperger, Registered Surveyor, revised March 9, 1949, and recorded March 21, 1941 in Plan Book No. 4, page 79, in the Recorder's Office in and for Cumberland Countv at Carlisle, v Marie Covni, Editor SWOR'KTO AND SUBSCRIBED before me this 13 day of February 13, 2009 Notary Pennsylvania. HAVING THEREON erected a single dwelling house known as No. 1920 Kent Drive Camp Hill, PA 17011. UNDER AND SUBJECT to all existing easements, restrictions and conditions of record. Parcel #13-23-0547-167. NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 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 FANNIE MAE is the grantee the same having been sold to said grantee on the 10TH day of JUNE A.D., 2009, under and by virtue of a writ Execution issued on the 15TH day of OCT, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 1387, at the suit of COUNTRYWIDE HOME LOANS INC against HARPREET S GULERIA is duly recorded as Instrument Number 200923833. IN TESTIMONY WHEREOF, I have ereunto set my hand ands 1 of said office this day of ,qa A of Deeds Romrax of 6,;As. CurnbarwW County Cam, PA MY COftwmon EVWs till Fk* Mondoy Of.*. 3010