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Home My WebLink About08-3739GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- INTEREST TO LONG BEACH MORTGAGE COMPANY, BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST Mortgagor and Real Owner 1220 Pine Road Carlisle, PA 17013 Defendant Term &Y; No. 3'734 Texts CIVIL ACTION: MORT(aAOE *'r?racre sc;1 IRF 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 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 bt.tv://www.vhfa.org/consumers/homeowners/real. 5). Call the Plaintiff (your lender) at 866-926-8937 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 6733217C. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY, BY OPERATION OF LAW, 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendant is LORIE L. YOST, 1220 Pine Road, Carlisle, PA 17013, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On January 31, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to LONG BEACH MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1896, Page 57. 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 January 01, 2008 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 ..................................................................................$114,010.69 Interest from 12/01/2007 through 01/31/2008 at 10.0000%.......... from 02/01/2008 through 06/30/2008 at 9.87500%.......... Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph. Late Charges from 01/01/2008 to 06/30/2008 ........................ Monthly late charge amount at $61.09 Costs of suit and Title Search ................................ ..................$1,900.18 .................. $4,656.84 ..................$5,700.53 ..................... $366.54 Escrow Advance ..................................................................... Suspense ................................................ Fees ....................................................... NSF Charges .................. .......... $900.00 .......$4,954.53 ........ -$789.93 ...................................................$155 00 Monthly Escrow amount $647.91 ............$25.00 $131,879.38 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $131,879.38, together with interest at the rate of $31.23, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: U f GOLDBECK WCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION -9W,V 6- 71'1w,?td as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: (Q '1 08 n a hington Mutual Bank, as Successor-in- est to Long Beach Mortgage Company, by operation of law J1Y-JIAJC A-)#7V,,V-6ek? 0666779905 LORIE L. YOST E.,Xhibit A ALL taet aerlio home and .tat of ground Omime in Dicbrom Towmd* Carnberiand C1amy, Pkv?e, bounded and d ed am Mome at a pomthi the coaster lieu of p'ise ltosd. ahio 1mo>t+at a Rout 21a1B; daoeo Wm h a& ofLadat RNe+rlw and WOO A. lfrw %hiit wiib. SPA 11 dm CK mom/ 51 mam=dm &0 331.96 hot b e poo fi Smoa aiq bmda am or formalist of Weaas Dy% SwA 36 dens 14 mkWaa 57 seoanitWant19.7!ImIna do* tWWtw OWJ aILWiimer, be wW N atMt 13 doom 37 al', ', 03 m om& Wed 32531 film to a Pohl in do amw lism of thm mid ? dmnaa slows acid eaelar hit, N" 33 tiep= 49 matem 56 meDOM$ Bld 10542 *4 CC 1PA> aw d.6i15 ax+tm. SA11] 1 , I 1 -1 1 jkw* themom amaaI- a aanch mtyle d haws. ptanritatmaiedaataribalaooaeftprat8ttbdilvidomfilm afla M.Nmidlin rr,P8,mtLomNa 3, maotdad 1a dta C>i'Soe oflhe Rceemrdar oCi~keda is and ihr?+c3seengr 1n P1ms Hoot 25, Page 1?. p NO namwqW SWM to as oldaamta at rrsy *0 aXimtft 25 iitat 8000MVgft ftM the mm No efsud Pita Rawl as do swA sw mw as acid plan, ? S<JBJBG?' , ?1?€1kI'116LBS,S b dt dalawipS L 'E'lms mohie bower ps tdM be phased cs *A pew heneln amuv"WA i Of smams VWM wtlit tltltt M Sol ft amid laafds N. 3isYiami his ink pmkd and ?b9ttl,?heatMl?daetis?d3asmsB.1?htliglmwil6,byrdtxwldmlplAt,'?,11RR7?tttdneeamdmdos AqW 24 IM 773, is #A Offim ofdw ltaam nh r ofDO04 dr C3onbatlmmd C o mngr in DW Beak `r. Vadans Eythibit (B Washington Mutual PO Box 44118 Jacksonville, FL 32231-4118 7100 4047 5100 5136 6415 March 17, 2008 LORIE L YOST 1220 PINE RD CARLISLE PA 17013 000540 /PC 0666779905 ® Washington Mutual HOME LOANS WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0666779905 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS 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. SP999 HOMEOWNERS NAME(S): Lorie L. Yost PROPERTY ADDRESS: 1220 Pine Rd Carlisle PA 17013 LOAN ACCT. NUMBER: 0666779905 ORIGINAL LENDER: Lbm CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL 5.414 N E WHICH CAN AVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY TAY OF FOR CI TRF -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 OC[`I1R WITHiN THE NEXT (W DAYC IF YO DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE 1P TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE vntrP urnPj`!a&Q r,EP.,,.T,, EXPLAIN _____.__ BRING YOUR MORTGAUE UP TO DATE CONSUMER CREDIT CO iNC I IN A N e - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addr s ad telephone n um rs of designated consumer redi m cling agencies for the county in which h pro=M is 1 at a are-set forth at the end oft is Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLI ATION FOR M•ORTCAC 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.) 000540/SP999 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE. DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1220 Pine Rd Carlisle PA 17013 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 01/01/2008 $1390.50 02/01/2008 03/01/2008 $1390.50 $1380.28 Other charges (explainritemize): Uncollected Late Charges $000 Uncollected Fees: $98.00 Corporate advances $-356.91 Less Credits $789.93 TOTAL AMOUNT PAST DUE: $3112.44 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO r F. TH DEFA M - 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 $3112.44, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Ea=en c must made either hp each r bier c chak c rtifie? check; or money order made pay &e and sent o• Washington Mutual PO BOX 41275 Jacksonville, FL 32203 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURE THE D FA I T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to z rcisr i a rights to acre! rat h mortggge debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. NE THE MORTI A Ic FORF?' QED TPON 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 with;n h THIRTY ! ^? DAY period- you will not Mq lir ' pgy a torn y's fees. OTHER LENDER R .M .DIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. SP999 RIGHT TO CtIRE THF. DEFA 1 T PRIOR TO cH RIFFN SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have beeun. You may still have the right to rnrp the dpfo„lt -A ,.rp.. - .?,e e.,,e _.....__ ___ - ___ t___ the lender and by performing any other requirements under the mortgage Curing your default in the manner set a" '671 ' forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIRTY SHERiFF'c eAi F DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: Washington Mutual Address: PO Box 44118 Jacksonville, FL 322314118 Phone Number: 1-866-926-8937 Fax Number: 1-904-281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans.com EFF CIS OF cHF.RiFF'c cAi ?• - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. • 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 THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. SP999 C 09 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03739 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK', VS YOST LORIE L MICHAEL BARRICK Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE ? was served upon YOST LORIE L the DEFENDANT ' at 193 :00 HOURS, on the 1st day of July 2008 at 1220 PINE ROAD i CARLISLE, PA 17013 by handing to TODD ROLAND, HUSBAND a true and attested copyY,of COMPLAINT - MORT FORE together with and at the same time dir cting His attention to the contents thereof. Sheriff's Costs: Docketing 1 So Answers: g 181.00 Service 8.00 Affidavit x. 00 Surcharge 10;.00 R. Thomas Kline 1.00 361.00 07/02/2C GOLDBECE Sworn and Subscibed to By: before me this dad' of A.D. Sheriff or Deputy Sheriff of GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY, BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. No. 08-3739 LORIE L. YOST 1220 Pine Road Carlisle, PA 17013 Defendant PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. I tiv?j I. A& a I Michael T. McKeever, Esquire Attorney for Plaintiff 'OF 2009 PR 2 1 A?" i 10