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HomeMy WebLinkAbout08-1727GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 vs. SUSAN L. CROMER STEVEN P. SWARTZ Mortgagors and Real Owners 211 Running Pump Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS Plaintiff Defendants OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE b$ I7a? colI -Tem CIVIL AQTION: MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A 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 TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FHtM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hU://www.vhfa.org/consumers/homeowners/real.as x. 5). Call the Plaintiff (your lender) at 610-378-6367 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(a.goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is SOVEREIGN BANK, 601 Penn Street, Mail Code: 10-6438-MD4 Reading, PA 19601. 2. The names and addresses of the Defendants are SUSAN L. CROMER, 4639 Carlisle Road, Gardners, PA 17324 and STEVEN P. SWARTZ, 4639 Carlisle Road, Gardners, PA 17324, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On December 01, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to SOVEREIGN BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1974, Page 4636. 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 ..................................................................................$153,120.08 Interest from 09/01/2007 through 03/31/2008 at 6.6250% .......................$4,938.07 Per Diem interest rate at $27.66 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$7,656.00 Late Charges from 10/01/2007 to 03/31/2008 .............................................$246.85 Costs of suit and Title Search ......................................................................$900.00 Escrow .......................................................................................................... $885.62 PMI Premium ...............................................................................................$123.38 Fees ..............................................................................................................$151.95 $168,021.95 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $168,021.95, together with interest at the rate of $27.66, 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. l By: Iu GOLD ECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF r. VERIFICATION I, Jose p? lD?itcer???j 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: 3- /2 -og' i L 71 0096200546 SUSAN L. CROMER and STEVEN P. SWARTZ ExhibitA 11/30/2006 THU 9:19 FAX 717249733'4 mood/008 - SCHEDULE C LEGAL DESCRIPTION Commitment Number: 5100-547R File Number. SIMS47R ALL THAT CERTAIN parcel or tract of land lying and being situate in North Newton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a railroad spice in the center line of the public road known as T-328 at corner of Lot No. 21C on a plan of lots dated September 22, 1977, hereinafter Warred to; thence by said Lot No. 21C and tmgh and iron pin sat on the exieti right-of-way ine of said public road. 25.07 feet from the place of beginnft South 71 degreas 35 minutes 48 seconds West, 272.85 feet to an iron pin on line of Lot No. 22 on sheet 8 of 8 of a plan of lots prepared for Leslie V. Lucas and Dolores H. Lucas by Carl 0. Bert, R.S., dated Juno 1974, and recorded in the Me of the Recorder of Deeds for Cwnbedand County, PemsyNania, in Plan Book 25, Pape 121; thence by said Lot No. 22, North 4 degrees 19 mInulas 45 seconds West, 99.55 foot to an existhhg iron pin, then" by the same, North 22 degrees 48 minutes 41 Seconds West, 57.51 feet to an iron pin on Nne of said Lot No. 22 at comer of Lot No. 21A on said plan of lots doled September 22, 1977; thence by said Lot No 21A and through an ng iron pin in the existing right-daway fine of the aforerrrentioned public road known as T-328, North 71 degrees 30 mirwtes 48 seconds Eask 252.87 feet to a railroad spice in On venter One of said public road known as T.328; thence by the center line of said public raid, South 18 degrees 23 mkwtea 10 seconds East, 152.87 feet to an existing rakoad spike; thencee by same. South 22 degrees 35 minutes 58 seconds Fast, 11.05 feet to a railroad spike at the place of BEGINNING. I Certify this to be recorded In Cumberland County PA Recorder of Deeds STEWART TITLE GUARANTY COMPANY BK 1974PG4652 E..x.hibit B ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Date of Notice: December 4, 2007 SUSAN L CROMER 211 RUNNING PUMP RD Loan # 0096200546 NEWVILLE, PA 17241-9685 This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Speciflc information about the nature of the default is provided in the attached paees The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your borne. This Notice explains how the proeram works LA NOTIFICACION EN ADdUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): STEVEN P SWARTZ SUSAN L CROMER PROPERTY ADDRESS: 211 RUNNING PUMP RD NEWVILLE, PA 17241 LOAN ACCT. NO.: 0096200546 r, CURRENT LENDER/SERVICER: Sovereign Bank ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Date of Notice: STEVEN P SWARTZ 211 RUNNING PUMP RD NEWVILLE, PA 17241-9685 December 4, 2007 Loan # 0096200546 The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO FOR 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(S): PROPERTY ADDRESS: LOAN ACCT. NO.: STEVEN P SWARTZ SUSAN L CROMER 211 RUNNING PUMP RD NEWVILLE, PA 17241 0096200546 I? 3 CURRENT LENDER/SERVICER: Sovereign Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE CH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR ONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary. stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling a encies listed at the end of this notice the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to datel NATURE OF THE DEFAULT -The MORTGAGE held by Sovereign Bank (hereinafter we, us, or ours) on your property located at 211 RUNNING PUMP RD, NEWVILLE, PA 17241 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE THE MONTHLY PAYMENTS of 1,283.20. since 10/01/07 to the present. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is 3,957.59. The total amount includes late charges and any other charges that have accrued to this date. If you disagree with the assertion that a default has occurred or the correctness of the calculated amount required to cure the default, contact: SOVEREIGN BANK OVERNIGHT DELIVERY: MORTGAGE COLLECTIONS DEPARTMENT PO BOX 8627 OR 601 PENN STREET READING PA 19603 READING, PA 19601 1-800-753-7366 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 3,957.59, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check certified check or money order made payable to Sovereien Bank and sent to the above address IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage'debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (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 off the mortgage debt.. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to uay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. - If you have not cured the default within cr culu?rcmems Unger me morpta¢e. V unng your default in the manner set your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could a would approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SOVEREIGN BANK Address: PO BOX 8627, READING PA 19603 Phone Number: 1-800-753-7366 Fax Number: 1-800-881-9334 Contact Person: Constance M. Cocroft, Vice President EFFECT OF SE RIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may have the right to 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 THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (SEE ENCLOSURE) You may contact our Mortgage Services Department via E-mail at: MORTSERVQSOVEREIGNBANK COM This bank is a debt collector attempting to collect a debt and any information obtained from you will be used for that purpose. HOUSING AND URBAN DEVELOPMENT ("HUD") NOTIFICATION IMPORTANT NOTICE OF THE HOUSING AND COMMUNITY DEVELOPMENT ACT OF 1987 PLEASE READ THIS NOTICE. HOMEOWNERSHIP COUNSELING MAY BE AVAILABLE TO YOU. s DATE: December 4, 2007 TO: STEVEN P SWARTZ RE: Account No. 0096200546 FROM: Sovereign Bank The Housing and Community Development Act of 1987 requires that Sovereign Bank notify eligible homeowners with delinquent home loans of the availability of homeownership counseling. Because your home loan is DELINQUENT, you may be eligible for homeownership counseling provided by certain non-profit organizations. PLEASE CALL THE HUD TOLL FREE NUMBER AT 1-800-569-4287 FOR MORE INFORMATION. If you have any questions about your home loan you may call or write to-Sovereign Bank at: MORTGAGE COLLECTIONS DEPARTMENT SOVEREIGN BANK PO BOX 8627 READING PA 19603 1-800-753-7366 Constance M. Cocroft Vice President PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES ADAMS COUNTY ARMSTRONG COUNTY Weatherization Office American Red Cross - Hanover Chapter CCCS of Western PA, Inc. 917 Mifflin Street 529 Carlisle Street 217 East Plank Road Huntingdon PA 16652 Hanover, PA 17331 Altoona, PA 16602 , 814-643-2343 717-637-3768 814-944-8100,814-944-5747 FAX 717-637-3294 CCCS of Western PA, Inc. Financial Counseling Services of Franklin ' Credit Counselors of PA 401 Wood Street Suite 906 217 E. Plank Road Altoona PA 16602 31 West 3" Street Pittsburgh, PA 15222 , 814-944-8100 Waynesboro, PA 17268 412-338-9954, 800-737-2933 FAX 814-944-5747 717-762-3285 FAX 412-338-9963 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 717-541-1757 717-541-4670 Indiana Co. Community Action Program 827 Water Street, Box 187 Indiana, PA 15701 724-465-2657 FAX 724-465-5118 Tableland Services, Inc. 535 East Main Street Somerset, PA 15501 814-445-9628, 800-452-0148 FAX 814-443-3690 Adams County Housing Authority 139-143 Carlisle Street Gettysburg, PA 17325 717-334-1518, FAX 717-334-8326 ALLEGHENY COUNTY Pennsylvania Housing Finance Agency 2275 Swallow Hill Road, Bldg. 200 Pittsburgh, PA 15220 412-429-2842, FAX 412-429-2835 Action Housing Inc. 425 61° Avenue, Suite 950 Pittsburgh, PA 15219 412-391-1956,412-281-2102, 800-792-2801, FAX 412-3914512 CCCS of Western PA, Inc. 309 Smithfield Street Pittsburgh, PA 15222 412-471-7584 Urban League of Pittsburgh Bldg. for Equal Opportunity One Smithfield Street Pittsburgh, PA 15222 412-227-4802, FAX 412-261-5207 Mon-Valley Unemployed Committee 120 E. 9°i Avenue Homestead, PA 15120 412-462-9962 Credit Counselors of PA 401 Wood Street, Suite 906 Pittsburgh, PA 15222 412-338-9954,800-737-2933 FAX 412-338-9963 Community Action Southwest 22 West High Street Waynesburg, PA 15370 724-852-2893 Housing Opportunities 133 Seventh Street, PO Box 9 McKeesport, PA 15132 412-664-1906 FAX 412-664-0873 BEAVER COUNTY Action Housing, Inc. 425 6" Avenue, Suite 950 Pittsburgh, PA 15219 412-391-1956 FAX 412-391-4512 Housing Opportunities of Beaver Co, Inc. 650 Corporation Street, Suite 207 Beaver, PA 15009 724-723-7511 Credit Counselors of PA 401 Wood Street, Suite 906 Pittsburgh, PA 15222 412-338-9954,800-737-2933 FAX 412-338-9963 CCCS of Western PA, Inc. 971 3id Street Beaver, PA 15009 724-774-0798 Mon-Valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 412-462-9964,412-462-9962 Housing Opportunities, Inc. 133 7* Street, PO Box 9 McKeesport, PA 15134 412-664-1906 FAX 412-664-0873 BEDFORD COUNTY Bedford-Fulton Housing Services 10241 Lincoln Highway Everett, PA 15537 814-623-9129 FAX 814-623-7187 Keystone Economic Development Corp. 1954 Mary Grace Lane Johnstown, PA 15901 814-535-6556 FAX 814-539-1688 BERKSCOUNTY Budget Counseling Center 247 North Fifth Street Reading, PA 19601 610-375-7866 FAX 610-375-7830 EOC of Schuylkill County 225 N. Centre Street Pottsville, PA 17901 717-622-1995 FAX 717-622-0429 CCCS Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 610-821-4011, 800-220-2733 (814) only FAX 610-821-8932 Community Housing Counselors, Inc. PO Box 244 Kennett Square, PA 19348 610-444-3682 FAX 610-444-8243 BLAIR COUNTY Bedford-Fulton Housing Services RD 1 Box 384 Everett, PA 15537 814-623-9129 FAX 814-623-7187 CCCS of Western PA, Inc. 217 East Plank Road Altoona, PA 16602 814-944-8100,814-944-5747 Keystone Economic Development Corp. 1954 Mary Grace Lane Johnstown, PA 15901 814-535-6556 FAX 814-539-1688 Weatherization Office 917 Mifflin Street Huntingdon, PA 16652 814-643-2343 BRADFORD COUNTY CCCS of Northeastern PA Com. Dev. Corp. of Frankord CCCS of Western PA 1400 Abington Executive Park, Suite 1 4620 Griscom Street Philadelphia PA 19124 YMCA Building, 339 N Washington Street Clarks Summitt, PA 18411 , 215-744-2990 Butler, PA 16001 724-282-7812 570-420-8980,800-922-9537 FAX 215-426-9122 FAX 570-420-8981 Mon-Valley Unemployed Committee CCCS of Northeastern PA Northwest Counseling Services 5001 North Broad Street 120 East 9i° Avenue 31 West Market Street Philadelphia; PA 19141 Homestead, PA 15120 412-462-9962 Wilkes-Barre, PA 18702 570-821-0837 800-922-9537 215-324-7500 FAX 412-462-9964 , FAX 215-324-8753 FAX 570-821-1785 Credit Counselors of PA CCCS of Northeastern PA '^ CCCS of Delaware Valley 1515 Market Street, Suite 1325 401 Wood Street, Suite 906 Pittsburgh PA 15222 9 South 7 Street Stroudsburg PA 18360 Philadelphia, PA 19107 , 412-338-9954, 800-737-2933 , 570-420-8980,800-922-9537 215-563-5665 FAX.215-864-2666 FAX 412-338-9963 FAX 570.420-8981 CAMBRIIA COUNTY CCCS of Northeastern PA CCCS of Delaware Valley 4606 Street Road Bedford-Fulton Housing Services 16318 Atherton Street, suite 100 Trevose, PA 19047 RD 1, Box 384 Everett PA 15537 State College, PA 16801 814-238-3668, FAX 814-238-3669 215-563-5665 , 814-623-9129 CCCS of Lehigh Valley FAX 814-623-7187 The Trehab Center of Northeastern PA 10 Public Avenue 3671 Crescent Court East Indiana County CAP Montrose, PA 18801 Whitehall, PA 18052 610-821-4011 800-220-2733 827 Water Street. Box 187 570-278-3338,800-9824045 , FAX 610-821-8932 Indiana, PA 15701 412-465-2657 FAX 570-278-1889 FAX 412-465-5118 The Trehab Center of Northeastern PA American Credit Counseling Institute 845 Coates Street German Street, PO Box 389 Dushore PA 18614 Coatesville, PA 19320 CCCS of Western PA 219-A College Park Plaza , 570-928-9668, FAX 570-724-5252 888-212-6741 Johnstown, PA 15904 814-539-6335 The Trehab Center of Northeastern PA American Credit Counseling Institute 144 E Dekalb Pike 33 Walnut Street Wellsboro PA 16901 King of Prussia, PA 19406 CCCS of Western PA 217 East Plank Road , 570-724-5252 FAX 570-724-5783 610-971-2210 FAX 610-265-4814 Altoona, PA 16602 814-944-8100 The Trehab Center of Northeastern PA Credit Counseling Center FAX 814-944-5747 185 Elmira Street, PO Box 218 Troy PA 16947 832 Second St, Keystone Econ. Dev. Corp. , 570-297-2101 Richboro, PA 18954 215-396-1880 1954 Mary Grace Lane Johnstown, PA 15901 The Trehab Center of Northeastern PA FAX 215-396-8072 814-535-6556 103 Warren Street, PO Box 709 American Credit Counseling Institute FAX 814-539-1688 Tunkhannock, PA 18657 570-836-6840 FAX 570-836-6840 755 York Road, Suite 103 Tableland Services, Inc. , Warminster, PA 18974 535 East Main Street The Trehab Center of Northeastern PA 215-444-9429 FAX 215-956-6344 Somerset, P 15501 814-445-9628 800-452 0148 931 Main Street , - Honesdale, PA 18431 BUTLER COUNTY FAX 814-443-3690 570-253-8941 FAX 570-253-4817 Action Housing, Inc. CAMERON COUNTY BUCKS COUNTY 425 6° Avenue, Suite 950 Pittsburgh PA 15219 Northern Tier CAP Acorn Housing Corporation , 412-391-1956, 412-281-2102 PO BOX 389,135 West Street Emporium PA 15834 846 North Broad Street Philadelphia, PA 19130 FAX 412-391-4512 , 814-486-1161 215-765-1221, FAX 215-765-1427 Housing Opportunities, Inc. FAX 814-486-0825 Bucks County Housing Group 650 Corporate Street, Suite 207 McKeesport PA 15132 CCCS of Northeastern PA 140 East Richardson Avenue , 412-664-1590 1631 S. Atherton Street, Suite 100 Langhorne, PA 19047 FAX 412-664-0873 State College, PA 16801 814-238-3668 215-750-4310 FAX 215-750-4318 FAX 814-238-3669 HACE Housing Opportunities, Inc 167 Allegheny Avenue, 2' Fl 133 Seventh StrPO Box 9 ? McKeesport PA 15134 CCCS of Western PA Philadelphia, PA 19140 , 412-664-1906 217 East Plank Road Altoona PA 16602 215-426-8025 FAX 215-426-9122 FAX 412-664-0873 , 814-944-8100 FAX 814-9445747 CARBON COUNTY CHESTER COUNTY American CCI EOC of Schuylkill County Acorn Housing Corporation 845 Coates Street 225 )`forth Center Street 846 North Broad Street Coatesville PA 19320 Pottsville, PA 17901 Philadelphia, PA 19130 , 888-212-6741 570-622-1995 215-765-1221 FAX 570-622-0429 FAX 215-765-1427 American CCI CCCS of Lehigh Valley Budget Counseling Center 144 E Dekalb Pike King of Prussia PA 19406 3671 Crescent Court East 247 North Fifth Street , 610-971-2210 Whitehall, PA 18052 Reading, PA 19601 FAX 610-265-4814 610-921-4011, 800-220-2733 610-375-7866 717 and 814 only for 800 FAX 215-375-7830 American CCI FAX 610-821-0137 755 York Road, Suite 103 CCCS of Northeasterri PA HACE 167 W. Allegheny Avenue, 2nd Floor Warminster, PA 18974 215444-9429 1400 Abington Executive Park, Suite 1 Philadelphia, PA 19140 FAX 215-956-6344 Clarks Summitt, PA 18411 215-426-8025 570-587-9163, 800-922-9537 FAX 215-426-9122 CLARION COUNTY FAX 570-587-9134/9135 CCCS of Western Pennsylvania, Inc. CCCS of Northeastern PA Media Fellowship House 302 S Jackson Str t YMCA Building, 339 N Washington Street 31 W Market Street . ee Media, PA 19063 Buder, PA 16001 412-282-7812 Wilkes-Barre, PA 18702 610-565-0846 570-921-0837,800-922-9537 FAX 610-565-8567 CLEARFIELD COUNTY FAX 570-821-1785 Keystone Economic Development Corp. Tabor Community Services, Inc. 1954 Mary Grace Lane CCCS of Northeastern PA 9 South 7d' Street 439 East King Street Johnstown, PA 15901 Lancaster, PA 17602 814-535-6556 Stroudsburg, PA 18360 717-397-5182, 800-788-5062 (H. 0. only) FAX 814-539-1688 570-420-8990,800-922-9537 FAX 717-399-4127 FAX 570-420-8981 American Red Cross of Chester Indiana Co. CAP CCCS of Northeastern PA 1729 Edgemont Avenue 827 Water Street Box 187 1631 S Atherton Street, Suite 100 Chester, PA 19013 , Indiana PA 15701 State College, PA 16801 610-874-1484 , 724-465-2657 814-238-3668 FAX 724-465-5118 FAX 814-238-3669 Northwest Counseling Services CEO of Luzern County 5001 N. Broad Street Philadelphia, PA 19141 CCCS of Western PA, Inc. 217 E Plank Road 163 Amber Lane 215-324-7500 Altoona PA 16602 Wilkes-Barre, PA 18702 FAX 215-324-8753 , 814-944-8100 570-826-0510, 800-822-0359 FAX 814-944-5747 FAX 570-829-1665 - CALL FIRST CCCS of Delaware Valley 570455-4994 Hazleton 1515 Market Street, Suite 1325 CCCS of Northeastern PA FAX 570-455-5631 - CALLFIRST Philadelphia, PA 19107 1631 S Atherton Street Suite 100 570-836-4090 Tunkhannock 215-563-5665 , State College, PA 16801 FAX 215-563-7020 814-238-3668 CENTRE COUNTY FAX 814-238-3669 CCCS of Western PA, Inc. Community Housing Counseling Inc. 217 East Plank Road PO Box 244 CCCS of Western PA Altoona, PA 16602 Kennett Square, PA 19348 219-A College Park Plaza 814-9448100 610-444-3682 ' Johnstown PA 15904 FAX 814-944-5747 FAX 610-4448243 , 814-539-6335 Lycoming-Clinton Co STEP Philadelphia Council for Community Adv. CLINTO N COUNTY 2138 Lincoln Street, PO Box 1328 100 North 17° Street, Suite 600 . Lycoming-Clinton Counties STEP Williamsport, PA 17703 Philadelphia, PA 19103 2138 Lincoln Street PO Box 1328 570-326-0587 215-567-7803 , Williamsport PA 17703 FAX 570-322-2197 FAX 215-%3-9941 , 570-326-0587 CCCS of Northeastern PA CDC of Frankford Group Ministry FAX 570-322-2197 1631 S Atherton Street, Suite 100 4620 Griscom Street CCCS of Northeastern PA State College, PA 16801 Philadelphia, PA 19124 201 Basin Street 814-238-3668 . 215-7442990 Williamsport PA 17703 FAX 814238-3669 FAX 215-744-2012 , 570-323-6627 CCCS of Northeastern PA CCCS of Delaware Valley FAX 570-323-6626 201 Basis Street Williamsport PA 17703 Marshall Building 1631 S Atherton Street, Suite 100 , 570-323-6627 790 E Market Street, Suite 215 State College, PA 16801 West Chester, PA 19382 814238-3668 ' FAX 570-323-6626 215-563-5665 FAX 814-238-3669 ?' COLUMBIA COUNTY CAC of the Capital Region HACE CCCS of Northeastern PA 1514 Derry Street 167 W. Allegheny Avenue 2nd Floor 1400 Abington Executive Park, Suite 1 Harrisburg, PA 17104 , Philadelphia, PA 19140 Clarks Summitt, PA 18411 717-232-9757 215-426-8025 570-587-9163,800-922-9537 FAX 717-234-2227 FAX 215-426-9122 FAX 570-587-9134/9135 CCCS of Northeastern PA YWCA of Carlisle 301 G Street Community Housing Counselor, Inc. 31 W Market Street, PO Box 1127 Carlisle, PA 17013 PO BOX 224 Kennett Square PA 19348 Wilkes-Barre, PA 18702 717-243-3818 , 610-444-3682 570-821-0837, 800-922-9537 FAX 717-731-9589 FAX 610-444-8243 FAX 570-821-1785 CEO of Luzern County DAUPHIN COUNTY CCCS OF Western PA, Inc. Community Devel Corp of Frankford Group Ministry 163 Amber Lane 2000 Linglestown Road 4620 Griscom Street Wilkes-Barre, PA 18702 Harrisburg, PA 17102 Philadelphia PA 19124 570-826-0510, 800-822-0359 717-541-1757 , 215-7442990 FAX 570-829-1665 - CALL FIRST FAX 717-541-4670 FAX 215-7442012 570-455-4994 Hazleton FAX 570-4S5-5631- CALL FIRST CAC of the Capital Region CCCS of Delaware Valley 570-836-4090 Tunkhannock 1514 Derry Street 290 North Providence Road CRAWFORD COUNTY Harrisburg, PA 17104 717-232-9757 Media, PA 19063 215-563-5665 Booker T. Washington Center FAX 717-2342227 1720 Holland. Street ACCI Erie, PA 16503 Urban League of Metro Harrisburg 144 E. Dekalb Pike 814-453-5744 2107 North 6d' Street King of Prussia PA 19406 FAX 814-453-5749 Harrisburg, PA 17101 , 610-971-2210 John F. Kennedy Center, Inc. 717-234-5925 FAX 717-2349459 Pager 610-973-6219 2021 East 200 Street Erie, PA 16510 DELAWARE COUNTY ELK COUNTY Booker T. Washington Center 814-898-0400 Acorn Housing Corporation 1720 Holland Street FAX 814-898-1243 846 North Broad Street Erie, PA 16503 Greater Erie Comnty Action Committee Philadelphia, PA 19130 215-765-1221 814-453-5744 FAX 814-453-5749 18 West 9d' Street FAX 215-765-1427 Erie, PA 16501 814-459-4581 CCCS of Delaware Valley FAX 814-456-0161 1515 Market Street, Suite 1325 Philadelphia, PA 19107 Shenango Valley Urban League, Inc 215-563-5665 601 Indiana Avenue FAX 215-8642666 Farrell, PA 16121 ERIE COUNTY 412-981-5310 Media Fellowship House Greater Erie Community Action Committee 302 South Jackson Street 18 West 9d' Street CUMBERLAND COUNTY Media, PA 19063 Erie PA 16501 Adams County Housing Authority 610-565-0846 , 814-459-4581 139-143 Carlisle Street FAX 610-565-8567 FAX 814-456-0161 Gettysburg, PA 17325 717-3341518 FAX 717-334-8326 Phila Council fur Community Advancement 100 North I7d' Str t S it 600 John F. Kennedy Center, Inc. ° ee , u e 2021 East 20 Street Financial Counseling Services of Franklin Philadelphia, PA 19103 215-567-7803 Erie, PA 16510 814-898-0400 31 West 3nd Street FAX 215-%3-9941 Fax 814-898-1243 Waynesboro, PA 17268 717-762-3285 American Red Cross of Chester 1729 Edgemont Avenue CCCS of Western PA, Inc. Chester, PA 19013 2000 Linglestown Road 610-8741484 Harrisburg, PA 17102 717-541-1757 ACCI 175 Strafford Avenue, Suite I Urban League of Metropolitan Harrisburg Wayne, PA 19087 N 6d' Street 610-971-2210 Harrisburg, PA 17101 FAX 610-687-7860 717-2345925 FAX 717-2349459 Northwest Counseling Service 5001 North Broad Street Philadelphia, PA 19141 215-3247500, FAX 215-3248753 FAYETTE COUNTY Financial Services Unlimited HUNTINGDON COUNTY Action Housing Inc. 425 6d' A S i 31 West Yd Street Bedford-Fulton Housing Services venue, u te 950 Waynesboro, PA 17268 RD I, Box 384 Pittsburgh, PA 15219 717-762-3285 Everett, PA 15537 412-391-1956,412-281-2102 814-623-9129 FAX 412-391-4512 CCCS of Western PA, Inc. FAX 814-623-7187 912 South George Street Mon Valle Unemployed Committee ' York, PA 17403 Weatherization Office 120 East 9 Avenue 717-846-4176 917 Mifflin Street Homestead, PA 15120 Huntingdon, PA 16652 412-462-9%2 YWCA of Carlisle 814-643-2343 301 G Street Tableland Services, Inc Carlisle, PA 17013 CCCS of Western PA, Inc. 131 North Center Avenue 717-243-3818 217 E. Plank Road Somerset, Pa 15501 FAX 717-243-3948 Altoona, PA 16602 814-445-9628 814-9448100 FAX 814-443-3690 American Red Cross-Hanover Chapter FAX 814-944-5747 529 Carlisle Street CCCS of Western PA, Inc Hanover, PA 17331 INDIANA COUNTY 1 North Gate Square 717-637-3768 CCCS OFWestem PA Inc. 2 Garden Center Drive FAX 717-637-3294 , 1 North Gate Square Greensburg, PA 15601 2 Garden Center Drive 724838-1290 FULTON COUNTY Greensburg, PA 15601 Bedford-Fulton Housing Services 724-838-1290 Community Action Southwest RD 1, Box 384 22 West High Street Everett, PA 15537 Keystone Economic Development Corp. Waynesburg, PA 15370 8144623-9129 1954 Mary Grace Lane 724-852-2893 FAX 814-323-7187 Johnstown, PA 15901 Fayette Co Community Action Agency CCCS of Western PA, Inc. 814-535-6556 FAX 814539-1688 137 North Beeson Avenue 912 South George Street Uniontown, PA 15401 York, PA 17403 Indiana County CAP 724-437-6050, 800-427-INFO 717-846-4176 827 Water Street PO Box 187 FAX 724-437-4418 , Indiana, PA 15701. Financial Counseling Services of Franklin 724-465-2657 CCCS of Western PA 31 West Yd Street FAX 724-465-5118 199 Edison Street Waynesboro, PA 17268 Uniontown, Pa 15401 717-762-3285 CCCS of Western PA 724-439-8939 219-A College Park Plaza Weatherization Office Johnstown PA 15904 FOREST COUNTY 917 Mifflin Street , 814539-6335 Warren-Forest CEOC Huntingdon, PA 16652 204 Liberty Street, PO Box 547 814-64372343 JEFFERSON COUNTY Warren, PA 16365 John F. Kennedy Center Inc. 814-726-2400 GREENE COUNTY , 2021 East 20'h Street FAX 814723-0510 Action Housing, Inc. Erie, PA 16510 425 Oh Avenue; Suite 950 814898-0400 FRANKLIN COUNTY Pittsburgh, PA 15219 FAX 814-898-1243 Adams County Housing Authority 412-391-1956, 412-281-2102 139-143 Carlisle Street FAX 412-391-4512 Indiana County CAP Gettysburg, PA 17325 827 Water Street, Box 187 717-3341518 Community Action Southwest Indiana, PA 15701 FAX 717-334-8326 22 West High Street 724-465-1657 Waynesburg, PA 15370 FAX 724465-5118 CCCS of Western PA 724-852-2893 2000 Linglestown Road FAX 724-627-7713 CCCS of Western PA Inc. Harrisburg, PA 17102 , YMCA Building, 339 North Washington Street 717-541-1757 Mon-Valle Unemployed Committee Butler PA 16001 FAX 717-541-4670 120 East 9' Avenue , 724-282-7812 Homestead, PA 15120 Urban League of Metropolitan Harrisburg 2107 N 6d' Street 412-462-9962 JUNIATA COUNTY Harrisburg PA 17101 FAX 412-462-9964 CCCS of Western PA, Inc. , . 717-2345925 CCCS of Western PA, Inc. 217 E. Plank Road Altoona, PA 16602 FAX 717-2349459 1 North Gate Square 8149448100 2 Garden Center Drive FAX 814-944-5747 CAC of the Capital Region Greensburg, PA 15601 1514 Derry Street 724838-1290 Weatherization Office Harrisburg, PA 17104 917 Mifflin Street 717-232-9757 Huntingdon PA 16652 FAX 717-2342227 , 814-643-2343 i? ii LACKAWANNA COUNTY • LEHIGH COUNTY CCCS of Western PA Inc. CCCS of Northeastern Pennsylvania EOC of Schuylkill County , YMCA Building, 339 N Washington Street 1400 Abington Executive Park, Suite 100 225 North Centre Street Butler, PA 16001 Clarks Summitt, PA 18411 Pottsville, PA 17901 724-282-7812 570 587-9163 or 800 955-9537 570-622-1995 FAX 570 587-9134/9135 FAX 570-622-0429 MIFFLIN COUNTY CCCS of Northeastern Pennsylvania CCCS of Lehigh County CCCS of Western PA, Inc. 217 E. Plank Road 31 W Market Street, PO Box 1127 3671 Crescent Court East Altoona PA 16602 Wilkes-Barre, PA 18702 Whitehall, PA 18052 , 814-944-8100 570 821-0837, 800-922-9537 610-821-4011, 800-220-2733 FAX 814-944-5747 FAX 570-821-1785 FAX 610-821-8932 LANCASTER COUNTY LUZERNE COUNTY CCCS of Northeastern PA 1631 S. Atherton Street Suite 100 Community Housing Counselors, Inc. CCCS of Northeastern PA , State College PA 16801 PO Box 244 31 W. Market Street, PO Box 1127 , 814-238-3668 Kennett Square, PA 19348 Wilkes-Barre, PA 18702 FAX 814-238-3669 215-444-3682 570-821-0837, 800-922-9537 FAX 215-444-3178 FAX 570-821-1785 Weatherization Office CCCS of Western Pennsylvania, Inc. CEO of Luzeme County 917 Mifflin Street Huntingdon PA 16652 912 South George Street 163 Amber Lane , 814-643-2343 York, PA 17403 Wilkes-Barre, PA 18702 717-846-4176 570-826-0510, 800-822-0359 MONROE COUNTY CCCS of Lehigh Valley FAX 570-829-1665 - CALL FIRST 570-455-4994 HAZELTON CCCS of Northeastern PA 31 W. Market Street PO Box 1127 3671 Crescent Court East FAX 570-455-5631 - CALL FIRST , Wilkes-Barre PA 18702 Whitehall, PA 18052 570-836-4090 TUNKHANNOCK , 570-821-0837 800=922-9537 215-821-4011, 800-220-2733 , FAX 570-821-1785 (717) and (814) ONLY CCCS of Northeastern PA FAX 215-821-8932 1400 Abington Executive Park, Suite 1 CCCS of Northeastern PA Clarks Summitt, PA 18411 9 South 7u Street Tabor Community Services, Inc. 570-587-8163, 800-922-9537 Stroudsburg, PA 18360 439 East King Street Lancaster PA 17602 FAX 570-587-9134/9135 570-420-8980, 800-922-9537 , 717-397-5182 or 800-788-5062 EOC of Schuylkill County FAX 570-420-8981 FAX 717-399-4127 225 North Centre Street CCCS of Northeastern PA LAWRENCE COUNTY Pottsville, PA 17901 570-622-1995 1400 Abington Executive Park, Suite 1 CCCS of Western Pennsylvania " FAX 570-622-0429 Clarks Summitt, PA 18411 570-587-9163 800-922-9537 I Federal Plaza, Suite 406 , FAX 570-587-9134/9135 North Mill Street LYCOMING COUNTY New Castle, PA 16101 CCCS ofNortheastern PA CEO of Luzeme County 724-652-8074 31 W. Market Street, PO Box 1127 163 Amber Lane 312 Chestnut Street, Suite 227 Wilkes-Barre, PA 18702 570-821-0837, 800-922-9537 Wilkes-Barre, PA 18702 570-826-0510 800-822-0329 Meadville, PA 16335 814-333-8570 FAX 570-821-1785 , FAX 570-829-1665 - CALL FIRST 570-455-4994 HAZELTON Shenango Valley Urban League, Inc. CCCS of Northeastern PA 1400 Abington Executive Park, Suite 1 FAX 570-455-5631- CALL FIRST 570-836-4090 TUNKHANNOCK 601 Indiana Avenue Clarks Summitt, PA 18411 Farrell, PA 16121 570-587-9163, 800.922-9537 MONTGOMERY COUNTY 724-981-5310 FAX 570-587-9134/9135 Acorn Housing Corporation Housing Opportunities of Beaver County CCCS of Northeastern PA 846 North Broad Street Philadelphia PA 19130 650 Corporation Street, Suite 207 201 Basin Street , 215-765-1221 Beaver, PA 15009 Williamsport, PA 17703 FAX 215-765-1427 724-728-7202 570-323-6627 LEBANON COUNTY FAX 570-323-6626 CCCS of Delaware Valley EOC of Schuylkill County Lycoming-Clinton Counties STEP Norristown Business Center 190 W. Germantown Pike Suite 140 225 North Centre Street 2138 Lincoln Street, PO Box 1328 , Norristown PA 19401 Pottsville, PA 17901 Williamsport, PA 17703 , 215-563-5665 570-6622-1995 570-326-0587 FAX 570-622-0429 FAX 570-322-2197 CCCS of Delaware Valley Tabor Community Services, Inc. MERCER COUNTY 1515 Market Street, Suite 1325 Philadelphia PA 19107 439 East King Street Shenango Valley Urban League, Inc. , 215-563-5665 Lancaster, PA 17602 601 Indiana Avenue FAX 215-864-2666 717-397-5182, 800-788-5062 Farrell, PA 16121 FAX 717-399-4127 724-981-5310 Northwest Counseling Service NORTHUMBERLAND Northwest Counseling Service 5001 N. Broad Street CCCS of Northeastern PA 5001 N Broad Street Philadelphia, PA 19141 31 W Market Street, PO Box 1127 Philadelphia, PA 19141 215-324-7500 Wilkes-Barre, PA 18702 215-324-7500 FAX 215-324-8753 570-821-0837, 800-922-9537 FAX 215-324-8753 FAX 570-821-1785 Community Action Development Comm CCCS of Delaware Valley 113 East Main Street CCCS of Northeastern PA 1515 Market Street, Suite 1325 Norristown, PA 19401 1400 Abington Executive Park, Suite I Philadelphia, PA 19107 610-277-6363 Clarks Summitt, PA 18411 215-563-5665 FAX 610-277-2123 570-587-9163,800-922-9537 FAX 215-864-2666 FAX 570-587-9134/9135 Community Housing Counselors Inc. HACE PO Box 244 CCCS of Northeastern PA 167 W Allegheny, 2ad floor Kennett Square, PA 19348 201 Basin Street Philadelphia, PA 19140 215-444-3682 Williamsport, PA 17703 215-426-8025 FAX 215-444-8243 570-323-6627 FAX 215-426-9122 FAX 570-323-6626 Media Fellowship House Media Fellowship House 302 S. Jackson Street EOC of Schuylkill County 302 S Jackson Street Media, PA 19063 225 North Centre Street Media., PA 19063 610-565-0846 'Pottsville, PA 17901 610-565-0846 FAX 610-565-8567 570-622-1995 FAX 610-565-8567 FAX 570-622-0429 American Credit Counseling Institute PCCA 845 Coates Street PERRY COUNTY 100 N 1741 Street, Suite 500 Coatesville, PA 19320 CCCS of Western PA, Inc. Philadelphia, PA 19103 888-212-6741 2000 Linglestown Road 215-567-7803 Harrisburg, PA 17102 FAX 215-963-9941 Phila. Council For Community Advmnt 717-541-1757 100 North 171° Street Suite 600 FAX 717-541-4670 CCCS of DelawareValiey Philadelphia, PA 19103 One Cherry Hill, Suite 215 215-567-7803 Urban league of Metro Harrisburg Cherry Hill, NJ 08002 FAX 215-963-9941 2107 North a Street 215-563-5665 Harrisburg, PA 17101 American Credit Counseling Institute 717-234-5925 Housing Assoc. of Delaware Valley 144 E Dekalb Pike FAX 717-234-9459 1500 Walnut Street Suite 501 King of Prussia, PA 19406 , Philadelphia, PA 19102 610-971-2210 YWCA of Carlisle 215-545-6010 FAX 610-265-4914 301 G Street FAX 215-790-9132 Carlisle, PA 17013 American Credit Counseling Institute 717-243-3818 Housing Assoc. of Delaware Valley 755 York Road, Suite 103 FAX 717-243-3948 658 North Watts Street Warminster, PA 18974 Philadelphia, PA 19123 215-444-9429 Financial Counseling Services of Franklin 215-978-0224 FAX 215-956-6344 31 West 31d Street FAX 215-765-7614 Waynesboro, PA 17268 MONTOUR COUNTY 717-762-3285 Community Devel. Corp of Frankford CCCS of Northeastern PA Group Ministry 31 W. Market Street, PO Box 1127 ' Weatherization Office 4620 Griscom Street Wilkes-Barre, PA 18702 917 Mifflin Street Philadelphia, PA 19124 570- 821-0837, 800-922-9537 Huntingdon, PA 16652 215-744-2990 FAX 570-821-1785 814-643-2343 FAX 215-7442012 CCCS of Northeastern PA CAC of the Capital Region American Credit Counseling institute 1400 Abington Executive Park, Suite 1 1514 Derry Street 845 Coates Street Clarks Summitt, PA 18411 Harrisburg, PA 17104 Coatesville, PA 19320 570-587-9163,800-922-9537 717-232-9757 888-212-6741 FAX 570-587-9134/9135 FAX 717-2342227 NORTHHAMPTON COUNTY PHILADELPHIA COUNTY American Credit Counseling Institute 144 E Dekalb Pike CCCS of Lehigh Valley Acorn Housing Corporation King of Prussia, PA 19406 3671 Crescent Court East 846 North Broad Street 610-971-2210 Whitehall, PA 18052 Philadelphia, PA 19130 FAX 610-265-4814 610-821-4011 215-765-1221 800-220-2733 (717) and (814) ONLY FAX 215-765-1427 American Credit Counseling Institute FAX 610-821-8932 755 York Road, suite 103 Warminster, PA 18974 215-444-9429 FAX 215-956-6344 PIKE COUNTY SOMMERSET COUNTY 7 Lake Avenue, Box 339 CCCS of Northeastern Pennsylvania Bedford-Fulton Housing Services Montrose, PA 18801 31 W. Market Street PO Box 1127 RD I, Box 384 570-278-3338 800-982-4045 Wilkes-Barre, PA 18702 Everett, PA 15537 , FAX 570-278-1889 570-821-0837,800-922-9537 814-623-9129 FAX 570-821-1785 FAX 814-623-7187 SUSQUEHANNA COUNTY CCCS of Northeastern Pennsylvania CCCS OF Western PA, Inc. CCCS of Northeastern PA 1400 Abington Executive Park, Suite 1 1 North Gate Square Clarks Summitt, PA 18411 2 Garden Center Drive 1400 Abington Executive Park Suite 1 570-587-9163, 800-922-9537 Greensburg, PA 15601 , Clarks Summitt, PA 18411 FAX 570-587-9134/9135 724-838-1290 570-587-9163,800-922-9537 CCCS of Northeastern Pennsylvania Tableland Services Inc. FAX 570-587-9134/9135 9 South P Street 535 East Main Street 31 West Market Street Stroudsburg, PA 18360 Somerset, PA 15501 Wilkes-Barre, PA 18702 570-420-8980,800-922-9537 814-445-9628,800-452-0148 570-821-0837,800-922-9537 FAX 570420-8981 FAX 814443-3690 FAX 570-821-1785 POTTER COUNTY Keystone Economic Dev. Corp. Trebab Center of Northeastern PA Northern Tier CAC 1954 Mary Grace Lane 135 West 0 Street Johnstown, PA 15901 185 Elmira Street Emporium, PA 15834 814-535-6556 PO Box 218 814-486-1161 FAX 814-539-1688 Troy, PA 16947 FAX 814486-0825 570-297-2101 CCCS of Western PA FAX 570-297-2799 SCHUYLKILL COUNTY 219-A College Park Plaza Budgct Counseling Center Johnstown, PA 15904 German Street, PO Box 389 247 North Fifth Street 814-539-6335 Dushore, PA 18614 Reading, PA 19601 570-928-9668 610-375-7866 SULLIVAN COUNTY FAX 570-928-8144 FAX 610-375-7830 CCCS of Northeastern PA 17 Crafton Street CEO of Luzeme County Wellsboro, PA 16901 163 Amber Lane 1400 Abington Executive Park, Suite 1 570-724-5252 Wilkes-Barre, PA 18702 Clarks Summitt, PA 18411 FAX 570-724-5783 570-826-0510,800-822-0359 570-587-9163,800-922-9537 FAX 570-829-1665 - CALL FIRST FAX 570-587-9134/9135 103 Warren Street PO Box 709 570-455-4994 HAZELTON , Tunkhannock, PA 18657 FAX 570-455-5631- CALL FIRST 31 West Market Street 570-836-6840 570-836-4090 TUNKHANNOCK Wilkes-Barre, PA 18702 FAX 570-836-6332 570-821-0837,800-922-9537 E O C of Schuylkill Co FAX 570-821-1785 931 Main Street 225 N Centre Street Honesdale PA 18431 Pottsville, PA 17901 The Trehab Center of Northeastern PA , 570-253-8941 570-622-1995 FAX 570-2534817 FAX 570-622-0429 185 Elmira Street CCCS of Lehigh Valley PO Box 218 Troy, PA 16947 7 Lake Avenue, Box 339 Montrose PA 18801 PO Box A 570-297-2101 , 570-278-3338 800-982-4045 Whitehall, PA 18052 FAX 570-297-2799 , FAX 570-278-1889 610-821-4011 FAX 610-821-8932 17 Crafton Street TIOGA COUNTY Wellsboro, PA 16901 CCCS of Northeastern PA SNYDER COUNTY 570-724-5252 CCCS of Western Pennsylvania, Inc. FAX 570-724-5783 1400 Abington Executive Park Suite 1 2000 Linglestown Road , Clarks Summitt PA 18411 Harrisburg, PA 17102 103 Warren Street, PO Box 709 , 570-587-9134 800-922-9537 717-541-1757 Tunkhannoek, PA 18657 , FAX 570-587-9134/9135 FAX 717-541-4670 570-836-6840 Urban Lea gue of Metro Harrisburg FAX 570-836-6332 31 West Market Street Wilk B PA u 2107 N. 6 Street German Street, PO Box 389 es- arre, 18702 507-821-0837 800-922-9537 Harrisburg, PA 17101 Dushore, PA 18614 , FAX 570-821-1785 717-234-5925 570-928-9668 FAX 717-234-9459 FAX 570-928-8144 Trehab Center of Northeastern PA CAC of the Capital Region 931 Main Street 185 Elmira Street PO Box 218 1514 Deny Street Honesdale, PA 18431 , Troy, PA 16947 Harrisburg, PA 17104 570-253-8941 570-297-2101 717-232-9757, FAX 717-234-2227 FAX 570-253-4817 FAX 570-297-2799 17 Crafton Street Wellsboro PA 16901 WARREN COUNTY 31 West Market Street , 570-724-5252 Booker T. Washington Center Wilkes-Barre, PA 18702 FAX 570-724-5783 1720 Holland Street Erie PA 16503 570-821-0837, 800-922-9537 , FAX 570-821-1785 103 Warren Street, PO Box 709 814-453-5744 FAX 814-453-5749 The Trehab of NE PA Tunkhamrock, PA 18657 570-836-6840 FAX 570-836-6332 Greater Erie CAC 18 West 9'" Street 185 Elmira Street, PO Box 218 Troy, PA 16947 German Street, PO Box 389 Erie, PA 16501 814-459-4581 570-297-2101 7 Dushore, PA 18614 FAX 814-456-0161 FAX 5 0-297-2799 570-928-9668 FAX 570-928-8144 17 Crafton Street Warren-Forrest Counties EOC Wellsboro, PA 16901 931 Main Street 1209 Pennsylvania Avenue, West 570-724-5252 Honesdale, PA 18431 PO Box 547 Warren, PA 16365 FAX 570-724-5783 570-253-8941 FAX 570-253-4817 814-726-2400 103 Warren Street, PO Box 709 FAX 814-723-0510 Tunkhannock, PA 18657 7 Lake Avenue, Box 339 WASHINGTON COUNTY 570-836-6840 FAX 570-836-6332 Montrose, PA 18801 Action Housing, Inc. 570-278-3338, 800-982-4045 FAX 570-278-1889 425 6'" Avenue, Suite 950 German Street, PO Box 389 Pittsburgh, PA 15219 Dushore, PA 18614 UNION COUNTY 412-391-1956,412-281-2102 FAX 412-391-4512 570-928-9668 Lycoming-Clinton County STEP FAX 570-928-8144 2138 Lincoln Street, PO Box 1328 CCCS of Western PA, Inc. 931 Main Street Williamsport, PA 17703 570-326-0587 1 North Gate Square Honesdale, 18431 FAX 570-322-2197 2 Garden Center Drive Greensburg, PA 15601 570-253-8941 1 FAX 570-253-4817 724-838-1290. CCCS of Western Pennsylvania, Inc. WESTMORELAND COUNTY 217 East Plank Road Altoona PA 16602 Housing Opportunities, Inc. Action Housing, Inc. , 814-9448100 133 Seventh Street 425 6* Avenue, Suite 950 FAX 8149445747 McKeesport, PA 15132 412-6641590 Pittsburgh, PA 15219 412-391-1956, 412-281-2102 FAX 412-664-0873 CCCS of Northeastern Pennsylvania Community Action Southwest 31 W. Market Street, PO Box 1127 Credit Counselors of PA 401 Wood Street, Suite 906 22 West High Street Waynesburg PA 15370 Wilkes-Barre, PA 18702 Pittsburgh, PA 15222 , 724-852-2893 570-821-0837,800-922-9537 412-338-9954,800-737-2933 FAX 570-821-1785 FAX 412-338-9963 CCCS of Western PA, Inc. 1400 Abington Executive Park, Suite I Community Action Southwest I North Gate Square 2 Garden Center Drive Clarks Summitt, PA 18411 570-587-9163 800-922-9537 22 West High Street Greensburg, PA 15601 , FAX 570-587-9134/9135 Waynesburg, PA 15370 724-852-2893 724-838-1290 201 Basin Street 53 N. College Street Housing Opportunities, Inc. 133 Seventh Street Williamsport, PA 17703 570-323-6627 Washington, PA 15301 McKeesport, PA 15132 FAX 570-323-6626 724222-8292 41590 FAX 4 FAX 412-664-0873 VENANGO COUNTY Mon-fall 7 Unemployed Committee 120 East 9" Avenue Greater Erie Community Action Committee Homestead PA 15120 Keystone Economic Devel. Corporation I8 West 9° Street , 412-462-9962 1954 Mary Grace Lane Johnstown PA 15901 Erie, PA 16501 814-459-4581 FAX 412-462-9964 , 814-535-6556 FAX 814-456-0161 WAYNE COUNTY FAX 814539-1688 CCCS of Western Pennsylvania Inc CCCS of Northeastern PA Tableland Services Inc. , . 339 N. Washington Street, YMCA Bldg. 1400 Abington Executive Park, Suite I 535 East Main Street Somerset PA 15501 Butler, PA 16001 412-282-7812 Clarks Summitt, PA 18411 , 814-445-9628, 800452-0148 570-587-9163,800-922-9537 FAX 814-443-3690 FAX 570-587-9134/9135 John F. Kennedy Center Inc. , 2021 East 20° Street 9 South 7" Street 199 Edison Street Erie, PA 16510 Stroudsburg, PA 18360 Uniontown, PA 15401 724439-8939 814-898-0400, FAX 814898-1243 570-420-8980, FAX 570.420-8981 F-j Indiana County CAP 827 Water Street, Box 187 Indiana, PA 15701 724-456-2657 FAX 724-456-5118 Mon-Valle Unemployed Committee 120 East 9 Avenue Homestead, PA 15120 412-462-9962 FAX 412-462-9964 Credit Counselors of PA 401 Wood Street, Suite 906 Pittsburgh, PA 15222 412-338-9954,800-737-2933 FAX 412-338-9963 WYOMING COUNTY CEO of Luzeme County 163 Amber Lane Wilkes-Barre, PA 18701 570-826-0510, 800-822-0359 'FAX 570-829-1665 - CALL FIRST 570-455-4994 HAZELTON FAX 570-455-5631- CALL FIRST 570-836-4090 TUNKHANNOCK CCCS of Northeastern PA 1400 Abington Executive Park, Suite 1 Clarks Summitt, PA 18411 570-587-9163,800-922-9537 FAX 570-587-9134/9135 31 West Market Street Wilkes-Barre, PA 18702 570-821-0837,800-922-9537 FAX 570-821-1785 The Trehab Center of NE PA 7 Lake Avenue, Box 339 Montrose, PA 18801 570-278-3338,800-982-4045 FAX 570-278-1889 185 Elmira Street, PO Box 218 Troy, PA 16947 570-297-2101 FAX 570-297-2799 17 CraRon Street Wellsboro, PA 16901 570-724-5252, FAX 570-724-5783 103 Warren Street, PO Box 709 Tunkhannock, PA 18657 570-836-6840 FAX 570-836-6332 German Street, PO Box 389 Dushore, PA 18614 570-928-9668 FAX 570-928-8144 931 Main Street Honesdale, PA 18431 570-253-8941 FAX 570-253-4817 YORK COUNTY American Red Cross-Hanover Chapter 529 Carlisle Street Hanover, PA 17331 717-637-3768 FAX 717-637-3294 Housing Council of York 116 North George Street York, PA 17401 717-854-1541 FAX 717-845-7934 CCCS of Western PA, Inc. 2000 Linglestown Road Harrisburg, PA 17102 717-541-1757 FAX 717-541-4670 CCCS of Western PA, Inc. 912 South George Street York, PA 17403 717-846-4176 Adams County Housing Authority 139-143 Carlisle Street Gettysburg, PA 17325 717-334-1518 FAX 717-334-8326 MCKEAN COUNTY John F. Kennedy Center, Inc. 2021 East 2016 Street Erie, PA 16510 814-898-0400 Fax 814-898-1243 Northern Tier Community Action Corp. PO Box 389 135 W 416 Street Emporium, PA 15834 814-486-1161 Fax 814-486-0825 z 2/15/2008 SOVEREIGN SUBJECT: PO BOX 8627 SUSAN L. CROMER READING, PA 19603 211 RUNNING PUMP RD NEWVILLE, PA 17241 HEMAP Account #: HED001716703 Loan #: 96200546 Your application for a HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE LOAN has been DENIED pursuant to Act 91 of 1983, 35 P.S. Section 1680.401-C et seq. and/or Agency Guidelines 12 PA Code Section 31.201 et seq. for the following reasons: DELETED IN LENDER'S COPY You may be entitled to an appeal hearing If you disagree with our decision. Requests for a hearing must be made in writing and must be submitted to the Agency within 15 days after the postmark date of this letter. Verbal requests are not acceptable. The hearing may be conducted by a telephone conference call; therefore, you must include your telephone number. You also have a right to an in-person hearing at the Agency's office in Harrisburg if you so desire. Requests for hearings must state the reason(s) that a hearing is requested and must be sent first class, registered or certified mail to: Chief Counsel - HEMAP Hearing Request, PHFA/HEMAP, 211 North Front Street, P.O. Box 15628, Harrisburg, PA, 17105-5628. The hearing request may also be faxed to the attention of Chief Counsel - Hearing Request at 717-780-4031. The Agency will attempt to schedule the hearing within thirty (30) days after the request Is received. When sending your appeal, please be sure to print or type your name legibly and include your HEMAP Account Number and phone number where you may be reached during the day. You have a right to be represented by an attorney in connection with youyappeal. If you cannot afford an attorney you may be eligible for Legal Services representation. You can contact a Legal Services representative toll' free at 1-800-322-7572 for a referral to the office for your county. Please be aware that scheduling an appeal hearing does not necessarily stay foreclosure proceedings. DISCLOSURE OF USE OF INFORMATION OBTAINED FROM OUTSIDE SOURCE: 1. Disclosure inapplicable. The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided that the applicant has the capacity to enter into a binding contract); because all or part of the applicant's Income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal Agency that administers compliance with this law concerning this creditor is the Federal Trade Commission, Equal Credit Opportunity, Washington, b.C. Sincerely, THE PENNSYLVANIA HOUSING FINANCE AGENCY Homeowners' Emergency Mortgage Assistance Program nproJecVdhneoccmB?Aapt Rev. September 2004 Harrisburg, PA 17105-5206 Correspondence: 211 North Front Street P.O. Box 15530 Harrisburg, PA 17105-5530 (717) 780-3940 1-800-342-2397 FAX (717) 780-3995 77Y(717) 780.1869 r, K'' Er 1111101 b, m m OFFICIAL US E C Poelage $ .58 Cerftd Fee 2 65 . C3 o (Endor.arrtent Raqutrad) 2.15 ? J r- rU Total Postage -o ° STEVEN P SWARTZ 0 w ww-* 211 RUNNING PUMP RD NEWVILLE PA 17241-9685 Certified Mail ProWdw. . - • A nwft ntcelpt ¦ A unigna idenersr for your6ma iplece ¦ Arend d deNirery kept by the Posted Service for two years . Certified Mar may ONLY be combined wrh FireKYess M04 or Pft* Mai ¦ Cerered Mdi kt rwtavaNeble for any class of inbrtmllondd map. ¦ NO IMRANCE COVERAGE 18 PROVIOW with CatiBe l Mail. F valtmbtes. please cormider Waived or Repbterod Mar. . For an addltlond WA ANn may =requested to Provide prod r dervay. Te A ecut asrv , ps,se oanplele and ailech a Rem Race (PS form 9811 to ere w1cle and add applic" postape to cover tt be. PKI01 11 *!Arm rabun recxtpt s uSPSeRe oattnak u carneedamaan receipts ¦ For an additional fee, ryry may be restricted to the addressee 298 =MM"' ate clerk or mark the marpboe with tt ¦ N a posbnark on the Cerlieed Mar receipt Is desired, pleas present the arl de at the poet otiiee for pocbnerkirtp. "a "drr*rk on ethe Cormed Mr receipt b rtot needed detach and am label with postage and roan. IMPORTANT: Satre this receipt mW presets it when alakin9 M ingetry. PS Form 3900. August 2006 (!dowse) PSN 7530.02.000-9047 CERTIFIED PIAI[-'? REC EIPT o 0 C3 OFFICIAL UTrJE m Co t s .58 , ?- a Fee 65 2 i; r l; ' m . i : . , poeariQrk C3 (E-= 2 15 H- / Roelrktsd whey Fee . t- Toms Pt stw s ti 3 ..u SUSAN L CROMER tnee W i 211 RUNNING PUMP RD C3 r- or PO Ow Ma NEWVILLE PA 17241-9685 r Certified Mail Provides: ¦ A md" MOW ¦ A W*Wo for y& =WON ¦ A neoord of ddway kept by the Postal Service for two years fiyrpw&N Nwa%dww ¦ Certified Moo may ONLY be corobirad with First-Class Mello or Pdm* Mai ¦ CerWied Meg in not avafiable for any class of kdwrm*md mat. ¦ NO OWRANCE COVERAGE 18 PROYMM With Certified MaL Fe valwblee, please corh"der 1 -11 or Registered Mail. ¦ For an additlora( R a may m 1 provide Rookc dolmy. lb Roo (Ps FFarmR381i)mto tM artlde ¦nd, Paddeease Di ¦rw ioc ww th fee. ?rWorse maiipleoe'RMUm Receipt Req¦eeW. lb receive & be w¦hrer k ?ds rekrrh receipt, a USP% posbnark on your Certified Mail receipt 1 ¦ For an additional fee, d*.Wy may be roes Wo to the addressee i addresses's auultarindagot AdNee the dark or mark the nwdi ikce with 0 ¦ dr at the post alficsfor postmerldnpN Is iheRCerWted receipt is not needed, detach and affix Iebal with postage and mat. IMPORTANT: Sate this raoalpt and posed It wlhon makioe as Inquiry. P8 Form 3800. Augmt 20M ptersrss) F8N 7530•02aoo-eat7 C3 ?? C> -7t ir1 (rl r V Ftl 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01727 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOVEREIGN BANK VS _; . CROMER SUSAN L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CROMER SUSAN L but was unable to locate Her in his bailiwick. He therefore returns the the within named DEFENDANT r " 211 RUNNING PUMP ROAD NEWVILLE, PA 17241 HOUSE IS VACANT. CROMER SUSAN L NOT FOUND , as to So answers -7?? ?- R. Thomas Kline Sheriff of Cumberland County 04/11/2008 Sworn and Subscribed to before me this day of Sheriff's Costs: Docketing 18.00 Service 11.00 Affidavit .00 Surcharge 10.00 .00 yJ ??loy 39.00 h ._ A. D. ,. M SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01727 P COMMONTW8ALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SOVEREIGN BANK VS CROMER SUSAN L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SWARTZ STEVEN P but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE ` NOT FOUND as to the within named DEFENDANT 211 RUNNING PUMP ROAD SWARTZ STEVEN P NEWVILLE, PA 17241 HOUSE IS VACANT. Sheriff's Costs: So answers*,------ --7, Docketing 6.00 Service .00 Affidavit .00 R. Thomas -Kline Surcharge 10.00 Sheriff of Cumberland County .00 / 16.00 ? 0,F 04/11/2008 Sworn and Subscribed to before me this day of , A. D. Ail I.s »h .w SHERIFF'S RETURN - REGULAR CASE NO: 2008-01727 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SOVEREIGN BANK VS CROMER SUSAN L ET AL TIM BLACK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SWARTZ STEVEN P the DEFENDANT , at 0010:25 HOURS, on the 10th day of April , 2008 at 4639 CARLISLE ROAD GARDNERS; PA 17324 by handing to KATHY SWARTZ MOTHER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments SERVED AT 4637 CARLISLE ROAD, GARDNERS, PA 17324 Sheriff's Costs: Docketing 6.00 Service 11.00 Affidavit .00 Surcharge 10.00 .00 41,-1 (02 ? ? 27.00 Sworn anq Subscibed to before me this day of So Answers: R. Thomas Kline 04/11/2008 SRL By. /,,,_p/ eputy Sheriff A. D. i SHERIFF'S RETURN - REGULAR CASE NO: 2008-01727 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SOVEREIGN BANK VS CROMER SUSAN L ET AL ; DAVID MCKINNEY Sheriff or Deputy Sheriff of -» r Cumberland County,Pennsylvania, who being duly sworn according to law, says,'the'within COMPLAINT - MORT FORE was served upon CROMER SUSAN L the •. DEFENDANT at 0019:23 HOURS, on the 10th day of April 2008 at 4639 CARLISLE ROAD GARDNERS, PA 17324 by handing to SUSAN CROMER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments .. :- SERVED AT 18 E BIG SPRING AVE, NEWVILLE, PA , Sheriff's Costs: So Answers: .. Docketing 6.00 Service .00 Affidavit 00 Surcharge 10.00 R. Thomas Kline t .00 1'11jOC ? 16.00 04/11/2008 SRL Sworn and Subscibed to By: before me this day Deputy Sheriff ;, . of A.D. '. In the Court of Common Pleas of Cumberland County SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 vs. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 08-1727 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 SUSAN L. CROMER and STEVEN P SWARTZ by default for want of an Answer. Assess damages as follows: Debt Interest from 05/28/08 to Date of Sale Total (Assessment of Damages attached) 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 Ka T1 l iJl? y ? Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW ? 02008 , Judgment is entered in favor of SOVEREIGN BANK and again SUSAN L. CROMER and STEVEN P SWARTZ by default for want of an Answer and damages assessed in the sum of $170,552.08 as per the above certification. PrAonotary $170,552.08 SB-2090 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: May 13, 2008 TO: SUSAN L. CROMER 4639 Carlisle Road Gardners, PA 17324 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 vs. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 TO: SUSAN L. CROMER 4639 Carlisle Road Gardners, PA 17324 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1727 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 kvine Row Carlisle PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libeny 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 SB-2090 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: May 13, 2008 TO: SUSAN L. CROMER 211 Running Pump Road Newville, PA 17241 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 VS. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 TO: SUSAN L. CROMER 211 Running Pump Road Newville, PA 17241 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1727 MWORTANT 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 NC 8 kvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McIKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 SB-2090 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: May 13, 2008 TO: STEVEN P. SWARTZ 211 Running Pump Road Newville, PA 17241 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 VS. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 TO: STEVEN P. SWARTZ 211 Running Pump Road Newville, PA 17241 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1727 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 SB-2090 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: May 13, 2008 TO: STEVEN P. SWARTZ 4639 CarhsIe Road Gardners, PA 17324 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 VS. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 TO: STEVEN P. SWARTZ 4639 Carlisle Road Gardners, PA 17324 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1727 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FARM 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 WTIHOUT 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 SB-2090 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: May 13, 2008 TO: SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 VS. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 TO: SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1727 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 SB-2090 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: May 13, 2008 TO: STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 VS. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 TO: STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-1727 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, SUSAN L. CROMER, is about unknown years of age, that Defendant's last known residence is 18 E. Big Spring Avenue, Newville, PA 17324, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 5A2-1 \? U Pau 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, STEVEN P SWARTZ, is about unknown years of age, that Defendant's last known residence is 4637 Carlisle Road, Gardners, PA 17324, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 vs. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record owner(s)) 211 Running Pump Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-1727 ORDER FOR JUDGMENT Please enter Judgment in favor of SOVEREIGN BANK, and against SUSAN L. CROMER and STEVEN P SWARTZ 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 $170,552.08. 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 and that the name(s) and last known address(es) of the Defendant(s) is/are SUSAN L. CROMER, 18 E. Big Spring Avenue Newville, PA 17324 and STEVEN P SWARTZ, 4637 Carlisle Road Gardners, PA 17324; A a' A 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 $153,120.08 Interest from 09/01/2007 through $7,468.20 05/27/2008 Reasonable Attorney's Fee $7,656.00 Late Charges $246.85 Costs of Suit and Title Search $900.00 Escrow Payments Due 0 X $0.00 $0.00 Escrow $885.62 PMI Premium $123.38 Fees $151.95 $170,552.08 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this o` t34L day of "at , 2008 damages are assessed as above. PAProthy N -> 90 ?1 D i 4? f y (- ? ? D CL7 -71 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagors and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 Defendant(s) No. 08-1727 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. CurtLong Prothono ry By: If you have any questions concerning the above, please contact: 5as/o8 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 vs. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1727 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 05/28/08 to Date of Sale at 6.6250% (Costs to be added) $170,552.08 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff d O y C) 0 -? O d=d aQicndcNn z o3 mad H oa? ?' far 0 W C7 > W' a ? gyp. Gz, c? 42 ? N Ho w U 0 z .5 -? o a? z w o o O cn ?v?N W Qoo u W ? o V b° cz::) 9-5 Q0 -n ((r? O co O V O v O V f i CD Op d ?r ?3 0 ALL THAT CERTAIN parcel or tract of land lying and being situate in North Newton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a railroad spike in the center line of the public road known as T- 328 at corner of Lot No. 21 C on a plan of lots dated September 22, 1977, hereinafter referred to; thence by said Lot No. 21 C and through and iron pin set on the existing right-of-way line of said public road 25.07 feet from the place of beginning, South 71 degrees 36 minutes 48 seconds West, 272.65 feet to an iron pin on line of Lot No. 22 on sheet 6 of 6 of a plan of lots prepared for Leslie V. Lucas and Dolores H. Lucas by Carl D. Bert, R.S. dated June 1974, and recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Plan Book 25, Page 121; thence by said Lot No. 22, North 4 degrees 19 minutes 45 seconds West, 99.55 feet to an existing iron pin, thence by the same North 22 degrees 48 minutes 41 seconds West 67.51 feet to an iron pin on line of said Lot No. 22 at corner of Lot No. 21A on said plan of lots dated September 22, 1977; thence by said Lot No 21A and through and existing iron pin in the existing right-of-way line of the aforementioned public road known as T-328, North 71 degrees 36 minutes 48 seconds East, 252.87 feet to a railroad spike in the center line of said public road known as T-328; thence by the center line of said public road, South 18 degrees 23 minutes 10 seconds East, 152.87 feet to an existing railroad spike; thence by same, South 22 degrees 36 minutes 58 seconds East, 11.05 feet to railroad spike at the place of BEGINNING. TAX PARCEL #: 30-09-0509-017D MUNICIPALITY: NORTH NEWTON TOWNSHIP PROPERTY ADDRESS: 211 RUNNING PUMP ROAD, NEWVILLE, PA 17241 v 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 vs. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-1727 AFFIDAVIT PURSUANT TO RULE 3129 SOVEREIGN BANK, 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: 211 Running Pump Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 2. Name and address of Defendant(s) in the judgment: SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 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 t PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013 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 211 Running Pump Road Newville, PA 17241 (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: Mav 27, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Y {,7 CO .. -may } ?? Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 IN THE COURT OF Reading, PA 19601 COMMON PLEAS Plaintiff vs. of Cumberland County SUSAN L. CROMER CIVIL ACTION - LAW STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) ACTION OF 211 Running Pump Road MORTGAGE FORECLOSURE Newville, PA 17241 Defendant(s) NO. 08-1727 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. Michael T. McKeever Attorney for plaintiff s'^ i a r j-f'# M 08-1727 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-1727 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: CROMER, SUSAN L. SUSAN L. CROMER 4639 Carlisle Road Gardners, PA 17324 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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: IN THE COURT OF COMMON PLEAS 1. The sale will be cancelled if you pay to SOVEREIGN BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 08-1727 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 14 08-1727 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 610-378-6367 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&goldbecklaw com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. A 08-1727 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff SOVEREIGN BANK 601 Perm Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 Defendant(s; Term No. 08-1727 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: CROMER, SUSAN L. SUSAN L. CROMER 211 Running Pump Road Newville, PA 17241 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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 SOVEREIGN BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1 08-1727 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 08-1727 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 610-378-6367 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@goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-1727 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 Defendant(s; Term No. 08-1727 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: SWARTZ, STEVEN R STEVEN P. SWARTZ 4639 Carlisle Road Gardners, PA 17324 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriff s Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to SOVEREIGN BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. y 08-1727 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 riled. 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 08-1727 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 610-378-6367 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 homeretentionggoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. I 08-1727 GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 Defendant(s' , Term No. 08-1727 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: SWARTZ, STEVEN P. STEVEN P. SWARTZ 211 Running Pump Road Newville, PA 17241 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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 SOVEREIGN BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE f 08-1727 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 fmd 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 r 08-1727 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. 0. 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.g_ov 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: hq://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 610-378-6367 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(agoldbecklaw com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. w 08-1727 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 Defendant(s,' of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-1727 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: CROMER, SUSAN L. SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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 SOVEREIGN BANK, 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 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. 08-1727 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 08-1727 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 610-378-6367 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&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 SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. f 08-1727 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 Defendant(s' Term No. 08-1727 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: SWARTZ, STEVEN P. STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriff s Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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 SOVEREIGN BANK, 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' 08-1727 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ON 08-1727 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 610-378-6367 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 a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SB-2090. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1727 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SOVEREIGN BANK, Plaintiff (s) From SUSAN L. CROMER and STEVEN P. SWARTZ (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 $170,552.08 L.L.$ 0.50 Interest FROM 5/28/08 TO Date of Sale at 6.6250% Atty's Comm % Due Prothy $2.00 Atty Paid $217.00 Plaintiff Paid Date: 5/28/08 Other Costs to be added rothon (Seal) REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE By: 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 V. 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 SB-2090 CF: 03/17/2008 SD: 09/03/2008 $170,552.08 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 VS. IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-1727 Defendant(s) 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: p!? 9?QCr . ? SO S? ? ?GSS? . Personal Service by the Sheriffs Office/ ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( } Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( } Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectful y submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff tw 8 1 1 Yl L LL O ~ O /yam O ?- M f ? V- IU 0 Qj o ty a ' 9Z 00 U R N OD 2 c C -0 to c? Q? "` 1 O p ?j-1 A? Q?? ? „yM N O O O U) q _ - a a LL S ts -6 CL 00 K Q W Z Q o c? ^ S W U O ? j m y a ?{{ gg $aza[m = U A U g 8 0000 O CO O 2W rn p U m j m Ir o 2 JQ .- Z(0pg W - Ua 0 Q ?E V is 0 E W ? 4 co Q d ?a ( S ?O$ m toi dS? V}}NQ ?F-x .r. C ? ?m W (n C Za 0. k a ! 0000 m w Zm . o 2'0 a? E S 0 0 0 ' T Q - 2 O _ 0 .. 0. m x ? Z a Tu z? i z n uja t Y! vY lu- dN b $ W W Wa T 00 O y E. Z 0 FE 0- M on r (V ri Ni t6 (O i+ ao F I d d `o e 8 a CL N 0 N ri M LL 0 0 pO? O m 0 m m U Z. 0 U C 3 U O O CV dl N Q CL z W Ill ca Ix w U ..J CO D W 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 08-1727 211 Running Pump Road Newville, PA 17241 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 SOVEREIGN BANK, 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: 211 Running Pump Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 2. Name and address of Defendant(s) in the judgment: SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013 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 211 Running Pump Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: July 30, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 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 3RD day of SEPT A.D., 2008, under and by virtue of a writ Execution issued on the 28TH day of MAY, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 1727, at the suit of SOVEREIGN BANK against SUSAN L CROMER & STEVEN P SWARTZ is duly recorded as Instrument Number 200831968. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this O20?? day of - A.D. 2n2-v- n of Deeds E C? County. CWW PA A1W*y djM 2plo Sovereign Bank In the Court of Common Pleas of VS Cumberland County, Pennsylvania Susan L. Cromer and Steven P. Swartz Writ No. 2008-1727 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2008 at 2114 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Susan L. Cromer, by making known unto Susan Cromer personally, at 18 E. Big Spring Ave., Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copies of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 16, 2008 at 2038 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Steven P. Swartz, by making known unto Steven Swartz personally, at 4639 Carlisle Road, Gardners, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copies of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 17, 2008 at 1622 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 Susan L. Cromer and Steven P. Swartz located at 211 Running Pump Road, Newville, 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: Susan L. Cromer by regular mail to her last known address of 18 E. Big Spring Ave., Newville, PA 17241. This letter was mailed under the date of July 15, 2008 and never returned to the Sheriffs Office. 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: Steven P. Swartz by regular mail to his last known address of 4639 Carlisle Road, Gardners, PA 17324. This letter was mailed under the date of July 15, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 3, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck, on behalf of Fannie Mae. It being the highest bid and best price received for the same, Fannie Mae of International Plaza II, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254-2916, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,070.94. Sheriffs Costs: Docketing $30.00 Poundage 21.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 48.00 Levy 15.00 Surcharge 30.00 Law Journal 383.00 Patriot News 371.30 Share of Bills 17.64 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 1070.94 So Answers: R. Thomas Kline, Sheriff 44 ''99 BY ?Juu , Real Estate rgeant O Q"OL 4 S, gs 47. 01 i&,-- al ,5 /`p 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff vs. SUSAN L. CROMER STEVEN P SWARTZ (Mortgagor(s) and Record Owner(s)) 211 Running Pump Road Newville, PA 17241 Defendant(s) No. 08-1727 AFFIDAVIT PURSUANT TO RULE 3129 SOVEREIGN BANK, 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: 211 Running Pump Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 2. Name and address of Defendant(s) in the judgment: SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 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 of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013 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 211 Running Pump Road Newville, PA 17241 (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: May 27, 2008 1 n V,n i n -\r UL ,1 A r 9 GOLD\B}E?CK MMccCAAFFERTY & M1ccKK'IEEEVVERR / BY: Michael T. McKeever, Esq. Attorney for Plaintiff r 08-1727 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 Plaintiff VS. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 Term No. 08-1727 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: CROMER, SUSAN L. SUSAN L. CROMER 18 E. Big Spring Avenue Newville, PA 17324 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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 SOVEREIGN BANK, 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. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 44 • 08-1727 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 V 08-1727 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 hqp://www.phfa.org/consumers/homeowners/real.ppx. 5). Call the Plaintiff (your lender) at 610-378-6367 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(agoldbecklaw.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 SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. f- 08-1727 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 SOVEREIGN BANK 601 Penn Street Mail Code: 10-6438-MD4 Reading, PA 19601 VS. SUSAN L. CROMER STEVEN P SWARTZ Mortgagor(s) and Record Owner(s) 211 Running Pump Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-1727 Defendant(s 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: SWARTZ, STEVEN P. STEVEN P SWARTZ 4637 Carlisle Road Gardners, PA 17324 Your house at 211 Running Pump Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $170,552.08 obtained by SOVEREIGN BANK 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 SOVEREIGN BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311. 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. f 08-1727 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 fmd 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 08-1727 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 h=://www.phfa.org/consumers/homeowners/real.gpx. 5). Call the Plaintiff (your lender) at 610-378-6367 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@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 SB-2090. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN parcel or tract of land lying and being situate in North Newton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a railroad spike in the center line of the public road known as T- 328 at corner of Lot No. 21 C on a plan of lots dated September 22, 1977, hereinafter referred to; thence by said Lot No. 21 C and through and iron pin set on the existing right-of-way line of said public road 25.07 feet from the place of beginning, South 71 degrees 36 minutes 48 seconds West, 272.65 feet to an iron pin on line of Lot No. 22 on sheet 6 of 6 of a plan of lots prepared for Leslie V. Lucas and Dolores H. Lucas by Carl D. Bert, R.S. dated June 1974, and recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Plan Book 25, Page 121; thence by said Lot No. 22, North 4 degrees 19 minutes 45 seconds West, 99.55 feet to an existing iron pin, thence by the same North 22 degrees 48 minutes 41 seconds West 67.51 feet to an iron pin on line of said Lot No. 22 at comer of Lot No. 21A on said plan of lots dated September 22, 1977; thence by said Lot No 21 A and through and existing iron pin in the existing right-of-way line of the aforementioned public road known as T-328, North 71 degrees 36 minutes 48 seconds East, 252.87 feet to a railroad spike in the center line of said public road known as T-328; thence by the center line of said public road, South 18 degrees 23 minutes 10 seconds East, 152.87 feet to an existing railroad spike; thence by same, South 22 degrees 36 minutes 58 seconds East, 11.05 feet to railroad spike at the place of BEGINNING. TAX PARCEL #: 30-09-0509-017D MUNICIPALITY: NORTH NEWTON TOWNSHIP PROPERTY ADDRESS: 211 RUNNING PUMP ROAD, NEWVILLE, PA 17241 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-1727 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SOVEREIGN BANK, Plaintiff (s) From SUSAN L. CROMER and STEVEN P. SWARTZ (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 $170,552.08 L.L.$ 0.50 Interest FROM 5/28/08 TO Date of Sale at 6.6250% Atty's Comm % Due Prothy $2.00 Atty Paid $217.00 Other Costs to be added Plaintiff Paid Date: 5/28/08 rothonota (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale #66 On June 03, 2008 the Sheriff levied upon the defendant's interest in the real propy situated in North Newton Township, Cumberland County, PA Known and numbered as 211 Running Pump Rd., Newville more fully described on Exhibit "A" c>- filed with this writ and by this reference. (TI incorporated herein. Date: June 03, 2008 By: r ie Real EsSergeant 0h:8V 0E IN 8001 .a `. 3 lid 33183HS ---fie Patriot-News Co. . 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE the PNow 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the 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: 07/23/08 07/30/08 08/06/08 2008 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial SeN Sherrie L Kbrrer, Notary Public CRY Of Haniaburg; Dauphin County My C nimbWon Expires Nov. 28, 2011 Member, Pennsylvania Assodsflon of Notarlea Real Estate Sale No. 66 Writ No. 2008-1727 Civil Term Sovereign Bank VS Susan L. Cromer and SMven P. Swartz Attorney Joseph Goldbeck LEGAL DESCRIPTION ALL THAT CERTAIN parcel or tract of land lying and being situate in North Newton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a railroad spike in the center line of the public road known as T- 328 at comer of Lot No. 21C on a plan of lots dated September 22, 1977, hereinafter referred to; thence by said Lot No. 21C and through and iron pin set on the existing right-of-way line of said public road 25.07 feet from the place of beginning, South 71 degrees 36 minutes 48 seconds West, 272.65 feet to an iron pin on he of Lot No. 22 on sheet 6 of 6 of a plan of lots prepared for Leslie V. Lucas and Dolores H. Lucas by Carl D. Bert, R.S. dated June 1974, and recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Plan Book 25, Page 121; thence by said Lot No. 22, North 4 degrees 19 minutes 45 seconds West, 99.55 feet to an existing iron pin, thence by the same North 22 degrees 48 minutes 41 seconds West 67.51 feet to an iron pin on line of said Lot No. 22 at comer of Lot No. 21A on said plan of lots dated September 22,1977; thence by said Lot No 21A and through and existing iron pin in the existing right-of-way line of the aforementioned public road known as T-328, North 71 degrees 36 minutes 48 seconds East, 252.87 feet to a railroad spike in the center line of said public road known as T-328; thence by the center line of said public road, South 18 degrees 23 minutes 10 seconds East, 152.87 feet to an existing railroad spike; thence by same, South 22 degrees 36 minutes 58 seconds East, 11.05 feet to railroad spike at the place of BEGINNING. TAX PARCEL #: 30-09-0509-017D MUNICIPALITY: NORTH NEWTON TOWNSHIP PROPERTY ADDRESS: 211 RUNNING PUMP ROAD, NEWVILLE, PA 17241 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: July 18, July 25, and August 1, 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. Marie SWORN TO AND SUBSCRIBED before me this 1 day of August. 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 RZAL RBTATE SALT NO. 66 Writ No. 2008-1727 Civil Sovereign Bank VS. Susan L. Cromer and Steven P. Swartz Atty.: Joseph Goldbeck ALL THAT CERTAIN parcel or tract of land lying and being situate in North Newton Township, Cumber- land County, Pennsylvania, bounded and limited as follows: BEGINNING at a railroad spike in the center line of the public road known as T-328 at corner of Lot No. 21C on a plan of lots dated September 22, 1977, hereinafter referred to; thence by said Lot No. 21C and through and iron pin set on the existing right-of-way line of said public road 25.07 feet from the place of beginning, South 71 degrees 36 minutes 48 seconds West, 272.65 feet to an iron pin on line of Lot No. 22 on sheet 6 of 6 of a plan of lots prepared for Leslie V. Lucas and Do- lores H. Lucas by Carl D. Bert, R.S. dated June 1974, and recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Plan Book 25, Page 121; thence by said Lot No. 22, North 4 degrees 19 minutes 45 seconds West, 99.55 feet to an existing iron pin, thence by the same North 22 degrees 48 minutes 41 seconds West 67.51 feet to an iron pin on line of said Lot No. 22 at corner of Lot No. 21A on said plan of lots dated September 22, 1977; thence by said Lot No 21A and through and existing iron pin in the existing right- of-way line of the aforementioned public road known as T-328, North 71 degrees 36 minutes 48 seconds East, 252.87 feet to a railroad spike in the center line of said public road known as T-328; thence by the cen- ter line of said public road, South 18 degrees 23 minutes 10 seconds East, 152.87 feet to an existing rail- road spike; thence by same, South 22 degrees 36 minutes 58 seconds East, 11.05 feet to railroad spike at the place of BEGINNING. TAX PARCEL #: 30-09-0509- 017D. MUNICIPALITY: NORTH NEWTON TOWNSHIP. PROPERTY ADDRESS: 211 RUN- NING PUMP ROAD, NEWVILLE, PA 17241. Assignment of Bid NO. 08-1727 - CROMER 211 Running Pump Road Newville, PA 17241 I, Michael T. McKeever, Esquire, as attorney for the successful bidder, hereby assign my bid at the Sheriff Sale dated September 03, 2008 to: FANNIE MAE International Plaza II 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 GOLDBECK MCCAFFERTY & MCKEEVER Date: September 9.2008 ,,??MICHAEL T. MCKEEVER