HomeMy WebLinkAbout08-5380GOLDBECK 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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-CPI
ASSET-BACKED CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
VS.
CHERYL E. RUDD
Mortgagor and Record Owner
9 East South Street
Carlisle, PA 17013
Defendant
CIVIL ACTION: MORTGAGE
FORECLOSURE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
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
No 09 - 5380 Civ? l
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 PROVEERR 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 httn://www.nhfa.orQ/consumers/homeowners/real aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretentionna 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 69995FC.
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 WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN
TRUST 2007-CPI ASSET-BACKED CERTIFICATES, SERIES 2007-CPI, 4650 Regent Blvd, Irving,
TX 75063.
2. The names and addresses of the Defendant is CHERYL E. RUDD, 9 East South Street, Carlisle, PA
17013, who is the mortgagor and record owner of the mortgaged premises hereinafter described.
3. On December 23, 2006 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to H&R BLOCK MORTGAGE CORPORATION, which mortgage is recorded in
the Office of the Recorder of Deeds of Cumberland County as Book 1977, Page 4881. The mortgage has
been assigned to: WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE
LOAN TRUST 2007-CPI ASSET-BACKED CERTIFICATES, SERIES 2007-CPI by assignment of
Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage
obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will
be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage
and assignment(s) are matters of public record and are incorporated by this reference in accordance with
Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to
attach documents to pleadings if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for February 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 ................................ ....$100,306.06
Interest from 01/01/2008 through 08/31/2008 at 10.6000% ..................... $7,105.28
Per Diem interest rate at $29.12
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$5,015.30
Late Charges from 02/01/2008 to 08/31/2008 .............................................$390.46
Monthly late charge amount at $55.78
Costs of suit and Title Search ......................................................................$900.00
Recoverable Balance ....................................................................................$125.00
Monthly Escrow amount $148.99
$113,842.10
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 nersonam" 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 $113,842.10,
together with interest at the rate of $29.12, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordanc with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property.
By:
UUMM CK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
Laura Hescott 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 unworn falsification to authorities.
Date: - 13 CSC
AMERICAN HOME MORTGAGE SERVICING, INC. S/M TO OPTIO NE MORTGAGE CORPORATION
Laura Hescott Assistant Secretary
0022720999 CHERYL E. RUDD
E?chifiitA
LEGAL DESCRIPTION:
LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT CERTAIN PROPERTY SITUATED
IN CITY OF CARLISLE IN THE COUNTY OF CUMBERLAND, AND STATE OF PA AND BEING DESCRIBED IN A
DEED DATED IZVVJD04 AKD RECORDED 01103/2005 IN BOOK 288 PAGE 4836 AMONG THE LAND
RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE. AND REFERENCED AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE
SECOND WARD OF THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED
AND DESCRIBED AS FOLLOWS:
ON THE SOUTH BY EAST SOUTH STREET, ON THE WEST BY LOT NDW OR FORMERLY OF MRS. NANNIE B
BUSHMAN; ON THE NORTH BY LOT NOW OR FORMERLY OF JAMES MCGONIGAL'S HEIRS, ON THE EAST
BY OTHER PROPERTY FORMERLY OF THE ESTATE OF CHARLES C. HOFFER, DECEASED. HIVING A
FRONTAGE ON EAST SOUTH STREET OF 17.63 FEET AND EXTENDING AT EVEN WIDTH TO DEPTH OF 80
FEET AND IMPROVED WITH A TWAT STRORY BRICK DWEW NG HOUSE KNOWN AS NO. B EAST SOUTH
TOGETHER WITH THE USE IN COMMON WITH OWNERS AND OCCUPIERS OF THE PROPERTY ADJOINING
ON THE EAST, OF A THREE FEET WOE PASSAGEWAY SITUATED EQUALLY ON BOTH LOTS AND
EXTENDING NORTW"DLY FROM EAST SOUTH STREET, A DISTANCE OF APPROXIMATELY 30 FEET
PARCEL NO. 03-21-032D-136
CERTIRED TO BE A TRUE AND ?
CORRECT COPY Of THE ORKM
Exhibit (B
ACT 9] NOTICE
DATE OF NOTICE: August 4 2008
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
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.
This is an official notice that the mortgage on our home is in default and the
lender intends to foreclose. Specific information about the nature of the default is provided in
the attached ya es
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP ma be
able to help to save your home This Notice explains how the program works
To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when you meet with the Counseling Agency.
The name address and hone number of Consumer Credit Counselin A encies servin
your County are listed at the end of this Notice If you have any guestions you may call the
Pennsvlvama Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869.)
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 any attorney in your area. The local bar association may be able
to help you find a lawyer.
La notifcacion en adjunto es de suma importancia, pues afecta su derecho a continuar
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion
immediatamente Ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programs Ilamado
Homeowners Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
1
Date: August 4, 2008
Homeowners Name: CHERYL E. RUDD
Property Address: 9 East South Street, Carlisle, PA 17013
Loan Account No.: 0022720999
Original Lender: H&R BLOCK MORTGAGE CORPORATION
Current Lender/Servicer: AMERICAN HOME MORTGAGE SERVICES, INC.
HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA 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 designated 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 agencies listed at the end of this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the pro pert y 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 ed_ iateiy 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 fact-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 Mo a e Assistance.
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: 9 East South Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 02/01/2008 thru 8/4/2008
(7 mos. at $1,078.60/month) $7,550.20
(b) Late charges from 02/01/2008 thru 8/4/2008 $311.09
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $7,861.29
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 $7,861.29, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check
certified check or money order made payable and sent to:
AMERICAN HOME MORTGAGE SERVICES, INC.
4650 Regent Blvd
Irving, TX 75063
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 brings 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 pay 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.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale
You may do so by paving the total amount then past due plus any late or other char i;es then due
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriffs Sale as specified in wntin b the lender and b erformin an other requirements
under, the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately four (4 to 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 by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: AMERICAN HOME MORTGAGE SERVICES, INC.
Address: 4650 Regent Blvd
Irving, TX 75063
Phone Number: 561-848-4763
Fax Number:
Contact Person: Donna Kalb
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. 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 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.
Contact Person: Donna Kalb
Phone Number: 561-848-4763
401-
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-05380 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WELLS FARGO BANK N A
VS
RUDD CHERYL E
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
RUDD CHERYL E but was
unable to locate Her in his bailiwick.
COMPLAINT - MORT FORE ,
He therefore returns the
the within named DEFENDANT
9 EAST SOUTH STREET
, RUDD CHERYL E
NOT FOUND , as to
CARLISLE, PA 17013
GIVEN ADDRESS IS VACANT. PER POST OFFICE,
DEFENDANT LIVES AT 621 MILL RACE ROAD CARLISLE, PA 17013.
Sheriff's Costs: So answer
Docketing 18.00
Service 10.00
Not Found 5.00 R. Th as Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
l u f t 4 /0 9 C?,,, 43.00 GOLDBECK MCCAFFERTY MCKEEVER
10/13/2008
Sworn and Subscribed to before
me this day of
A. D.
GOLDBECK McCAFFERTY &
McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-
CPI ASSET-BACKED CERTIFICATES, SERIES
2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
VS.
CHERYL E. RUDD
9 East South Street
Carlisle, PA 17013
Defendant(s)
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
Term
No. 08-5380
r-
By:
GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05380 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK N A
VS
RUDD CHERYL E
GERALD WORTHINGTON Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
RUDD CHERYL E the
DEFENDANT at 1940:00 HOURS, on the 27th day of October 2008
at 621 MILL RACE COURT
CARLISLE, PA 17013 by handing to
CHERYL RUDD
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 5.00
Affidavit .00 A
Surcharge 10.00 R. Thomas Kline
/03o? .00
33.00 10/28/2008
GOLDBECK MCCAFFERTY MCKEEVER
Sworn and Subscibed to By;
before me this day Deputy Sh iff
of A.D.
In the Court of Common Pleas of Cumberland County
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION
ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED
CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
VS.
CHERYL E. RUDD
(Mortgagor(s) and Record Owner(s))
9 East South Street
Carlisle, PA 17013
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 08-5380
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 CHERYL E. RUDD by default for want of an Answer.
Assess damages as follows:
Debt
Interest from 12/24/2008 to
Date of Sale per diem at $29.12
Total
(Assessment of Damages attached)
$117,831.87
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
e;??
Michael T. McKeever
Attorney for Plaintiff
I.D. #56129
AND NOW !J Cc _ J d Je?n fl , Judgment is entered in favor of
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-
BACKED CERTIFICATES, SERIES 2007-CPI and against CHERYL E. RUDD by default for want of an Answer and
damages assessed in the sum of $117,831.87 as per the above certification.
P &-t?thonotary
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-
BACKED CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
No. 08-5380
VS.
CHERYL E. RUDD
(Mortgagors and Record Owner(s))
9 East South Street
Carlisle, PA 17013
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothono
By:
If you have any questions concerning the above, please contact:
Michael T. McKeever
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
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, CHERYL E. RUDD, is about unknown years of
age, that Defendant's last known residence is 621 Mill Race Road Carlisle, PA 17013, 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: /? ? ??
69995FC
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: November 18, 2008
TO:
CHERYL E. RUDD
9 East South Street
Carlisle, PA 17013
In the Court of
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE Common Pleas
MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED of Cumberland County
CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd CIVIL ACTION - LAW
Irving, TX 75063
Plaintiff Action of
vs. Mortgage Foreclosure
CHERYL E. RUDD
(Mortgagor(s) and Record Owner(s)) Term
9 East South Street No. 08-5380
Carlisle, PA 17013
Defendant(s)
TO: CHERYL E. RUDD
9 East South Street
Carlisle, PA 17013
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
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
69995FC
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: November 18, 2008
TO:
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
In the Court of
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE Common Pleas
MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED of Cumberland County
CERTIFICATES, SERIES 2007-CP1
4650 Regent Blvd CIVIL ACTION - LAW
Irving, TX 75063
Plaintiff Action of
vs. Mortgage Foreclosure
CHERYL E. RUDD
(Mortgagor(s) and Record Owner(s)) Term
9 East South Street No. 08-5380
Carlisle, PA 17013
Defendant(s)
TO: CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
ORTANT 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Libaty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
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
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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-CP 1
ASSET-BACKED CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
VS.
CHERYL E. RUDD
(Mortgagor(s) and Record owner(s))
9 East South Street
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 08-5380
ORDER FOR JUDGMENT
Please enter Judgment in favor of WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE
MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED CERTIFICATES, SERIES 2007-CPI, and against
CHERYL E. RUDD 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 $117,831.87.
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 WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST
2007-CPI ASSET-BACKED CERTIFICATES, SERIES 2007-CPI 4650 Regent Blvd Irving, TX 75063 and that
the name(s) and last known address(es) of the Defendant(s) is/are CHERYL E. RUDD, 621 Mill Race Road
Carlisle, PA 17013;
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 $100,306.06
Interest from 01/01/2008 through $10,424.96
12/23/2008
Reasonable Attorney's Fee $5,015.30
Late Charges $613.58
Costs of Suit and Title Search $900.00
Escrow Payments Due 3 X $148.99 $446.97
Recoverable Balance $125.00
$117,831.87
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
AND NOW, this .,kr?k day of IEC . , 2008 damages are assessed as above.
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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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-CP 1
ASSET-BACKED CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
VS.
CHERYL E. RUDD
Mortgagor(s) and Record Owner(s)
9 East South Street
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-5380
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
12/24/2008 to Date of
Sale per diem at
$29.12
(Costs to be added)
$117,831.87
GOLDBECK McCAFFERTY & MCKE R
BY: Michael T. McKeever
Attorney for Plaintiff
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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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-
CPI ASSET-BACKED CERTIFICATES, SERIES
2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
vs.
CHERYL E. RUDD
(Mortgagor(s) and Record Owner(s))
9 East South Street
Carlisle, PA 17013
Defendant(s)
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129
No. 08-5380
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2007-CPI
ASSET-BACKED CERTIFICATES, SERIES 2007-CPI, 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:
9 East South Street
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
IN THE COURT OF COMMON PLEAS
YI
-4
4. Name and address of the last recorded holder of every mortgage of record:
AMERICAN GENERAL FINANCIAL SERVICES, INC.
6 South Hanover Street
Carlisle, PA 17013
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
9 East South Street
Carlisle, PA 17013
(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: December 23, 2008
(kLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
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08-5380
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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-
CP1 ASSET-BACKED CERTIFICATES, SERIES
2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
VS.
CHERYL E. RUDD
Mortgagor(s) and Record Owner(s)
9 East South Street
Carlisle, PA 17013
Defendant(s;
Term
No. 08-5380
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: RUDD, CHERYL E.
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
Your house at 9 East South Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $117,831.87 obtained by WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION
ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED CERTIFICATES, SERIES 2007-CPI
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
08-5380
1. The sale will be cancelled if you pay to WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED CERTIFICATES, SERIES
2007-CP1, 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.
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 may contact the Foreclosure Resource Center: ft://www.philadelphiafed.orpJforeclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
' 08-5380
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.ggv for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentiona-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 69995FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
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W rit,1
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Tw
I1
08-5380
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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-
CP1 ASSET-BACKED CERTIFICATES, SERIES
2007-CP1
4650 Regent Blvd
Irving, TX 75063
Plaintiff
VS.
CHERYL E. RUDD
Mortgagor(s) and Record Owner(s)
9 East South Street
Carlisle, PA 17013
Defendant(s
Term
No. 08-5380
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: RUDD, CHERYL E.
CHERYL E. RUDD
9 East South Street
Carlisle, PA 17013
Your house at 9 East South Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $117,831.87 obtained by WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION
ONE MORTGAGE LOAN TRUST 2007-CP 1 ASSET-BACKED CERTIFICATES, SERIES 2007-CP 1
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
08-5380
1. The sale will be cancelled if you pay to WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED CERTIFICATES, SERIES
2007-CPI, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much
you must pay call: 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.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
08-5380
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:
hllp://www.phfa.org/consumers/homeowners/real.awx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentiona-gLoldbecklaw.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 69995FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
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LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT
CERTAIN PROPERTY SITUATED IN CITY OF CARLISLE IN THE COUNTY OF
CUMBERLAND, AND STAT OF PA AND BEING DESCRIBED IN A DEED DATED
12/06/2004 AND RECORDED 01/03/2005 IN BOOK 266 PAGE 4638 AMONG THE
LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, AND
REFERENCED, AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON
ERECTED SITUATE IN THE SECOND WARD OF THE BOROUGH OF CARLISLE,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS
FOLLOWS:
ON THE SOUTH BY EAST SOUTH STREET; ON THE WEST BY LOT NOW OR
FORMERLY OF MRS. NANNIE B. BUSHMAN; ON THE NORTH BY LOT NOW
OR FORMERLY OF JAMES MCGONIGAL' S HEIRS; ON THE EAST BY OTHER
PROPERTY FORMERLY OF THE ESTATE OF CHARLES C. HOFFER, DECEASED
HAVING A FRONTAGE ON EAST SOUTH STREET OF 17.63 FEET AND
EXTENDING AT EVEN WIDTH TO DEPTH OF 60 FEET AND IMPROVED WITH
A TWO STORY BRICK DWELLING HOUSE KNOWN AS NO. 9 EAST SOUTH
STREET.
TOGETHER WITH THE USE IN COMMON WITH OWNERS AND OCCUPIERS OF
THE PROPERTY ADJOINING ON THE EAST, OF A THREE FEET WIDE
PASSAGEWAY SITUATED EQUALLY ON BOTH LOTS AND EXTENDING
NORTHWARDLY FROM EAST SOUTH STREET, A DISTANCE OF
APPROXIMATELY 30 FEET.
PARCEL NO. 03-21-0320-136
BEING KNOWN AS: 9 East South Street, Carlisle, PA 17013
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-5380 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., As Trustee for OPTION
ONE MORTGAGE LOAN TRUST 2007-CP1 ASSET-BACKED CERTIFICATES, SERIES 2007-
CP 1, Plaintiff (s)
From CHERYL E. RUDD
(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 $177,831.87
L.L. $.50
Interest from 12/24/08 to Date of Sale per diem at $29.12
Atty's Comm % Due Prothy $2.00
Atty Paid $205.00 Other Costs to be added
Plaintiff Paid
Date: 12/30/08
Curtis R. Long, Prothonot y
(Seal) By:
Deputy
REQUESTING PARTY:
Name: MICHAEL T. McKEEVER, ESQUIRE
Address: GOLDBECK, McCAFFERTY & McKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 56129
GOLDBECK McCAFFERTY & McKEEVER 69995FC
BY: Michael T. McKeever CF: 09/09/2008
Attorney I.D.#56129 SD: 06/10/2009
Suite 5000 - Mellon Independence Center $117,831.87
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-
CP1 ASSET-BACKED CERTIFICATES, SERIES
2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
CHERYL E. RUDD
Mortgagor(s) and
Record Owner(s)
9 East South Street
Carlisle, PA 17013
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Term
No. 08-5380
Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of
the Notice of Sheriff Sale was made by:
40 Personal Service by the Sheriffs OfficOwmipebevo a&h (copy of return attached).
( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of
mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail
attached).
( ) Published in accordance with court order (copy of publication attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by
ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section
4904.
Respectfully submitted,
7__ -1?'
BY: Michael T. McKeever, Esquire
Attorney for Plaintiff
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In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-5380 Civil Term
Wells Fargo Bank, N.A. as Trustee for Option One Mortgage Loan Trust
1, Asset-Backed Certificates, Series 2007-CPI
Vs
Cheryl E. Rudd
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that
on January 30, 2009 at 2000 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: Cheryl E. Rudd, personally and as Adult in Charge, at, 621 Mill Race Court,
Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that
on April 4, 2009 at 1027 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 Cheryl
E. Rudd, located at, 9 East South Street, Carlisle, Cumberland County, Pennsylvania
according to law.
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: Cheryl E. Rudd, by regular mail to her last known address of 621 Mill Race Court,
Carlisle, PA 17013. This letter was mailed under the date of April 1, 2009 and never
returned to the Sheriffs Office
So Answers,
R. Thomas Kline, Sheriff
BY
Real Estate Coordinator
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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-
CPI ASSET-BACKED CERTIFICATES, SERIES
2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
vs.
CHERYL E. RUDD
Mortgagor(s) and Record Owner(s)
9 East South Street
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 08-5380
AFFIDAVIT PURSUANT TO RULE 3129
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2007-
CPI ASSET-BACKED CERTIFICATES, SERIES 2007-CPI, 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:
9 East South Street
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
AMERICAN GENERAL FINANCIAL SERVICES, INC.
6 South Hanover Street
Carlisle, PA 17013
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
9 East South Street
Carlisle, PA 17013
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unworn falsification to authorities.
DATED: May 27, 2009
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
FILE, ?u
,,,' ! A
2 ?=u9 hd { 2G, A.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which DEUTSCHE BANK NATIONAL TR CO TR is the grantee the same
having been sold to said grantee on the I OTH day of JUNE A.D., 2009, under and by virtue of a writ
Execution issued on the 30TH day of DEC, A.D., 2008, out of the Court of Common. Pleas of said
County as of Civil Term, 2008 Number 5380, at the suit of OPTION ONE MTG LOAN TRUST 2007-
CPI TR against CHERYL E RUDD is duly recorded as Instrument Number 200922887.
IN TESTIMONY WHEREOF, I have ereunto set my hand
a seal of said office this day of
dAj
of Deeds
Fg&'r¢a3' i?? wsrand County, Cw", PA
My Coaw E*kw Ow Fht Mondey of Jan. 2010
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-5380 Civil Term
Wells Fargo Bank, N.A. as Trustee for Option One Mortgage Loan Trust
2007-CPI, Asset-Backed Certificates, Series 2007-CPI
Vs
Cheryl E. Rudd
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that
on January 30, 2009 at 2000 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: Cheryl E. Rudd, personally and as Adult in Charge, at, 621 Mill Face Court,
Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to
her personally the said true and correct copy of the same.
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that
on April 4, 2009 at 1027 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 Cheryl
E. Rudd, located at, 9 East South Street, Carlisle, Cumberland County, Pennsylvania
according to law.
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: Cheryl E. Rudd, by regular mail to her last known address of 621 Mill Race Court,
Carlisle, PA 17013. This letter was mailed under the date of April 1, 2009 and never
returned to the Sheriffs Office
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on June 10, 2009 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Michael McKeever, on behalf of Wells Fargo Bank, N.A., as
Trustee for Option One Mortgage Loan Trust 2007-CP1, Asset-Backed Certificates,
Series 2007-CPlof 4650 Regent Boulevard, Irving, TX 75063, being the buyer in this
execution, paid to Sheriff R. Thomas Kline the sum of $ 972.93
Sheriff s Costs:
Docketing 30.00
Poundage 19.08
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 48.00
Auctioneer 10.00
Law Library .50
Prothonotary 2.00
Milage 9.00
Levy 15.00
Surcharge 20.00
Law Journal 355.00
Patriot News 344.42
Share of Bills 15.43
Distribution of Proceeds 25.00
Sheriff's Deed 49.50
972.93
So Answers,
'' v _eo
R. Thomas Kline, Sheriff
I'D
Real Estate Coordinator
w
i -
CF1 _
1
cam ?a??'?
r
t•
Goldbeck M&affcrty K 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
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-
CP1 ASSET-BACKED CERTIFICATES. SERIES
2007-CPI
4650 Regent Blvd
Irving, TX 75063
Plaintiff
vs.
CHERYL E. RUDD
(Mortgagor(s) and Record Owner(s))
9 East South Street
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE:
AFFIDAVIT PURSUANT TO RULE 3129
No. 08-5380
WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2007-CP 1
ASSET-BACKED CERTIFICATES, SERIES 2007-CPI, 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:
9 East South Street
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and.addr-ess ref the last recorded holder of evcrv morteate of record:
AMERICAN GFNFRAL FINANCIAL SF:RVI(TS. INC.
6 South Ilanover Street
Carlisle, PA 17013
5. Name and address of every other person ?N ho has anv 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 knoNN ledge who has am, interest in the property which
may be affected by the sale.
TENANTS%OCCUPANTS
9 Fast South Street
Carlisle. PA 17013
(attach separate sheet if more space is needed)
1 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: December 23, 2008 ??_------
r
_D13 EC'K McCAFFERTY & McKFFVFR
BY: Michael T. McKeever. Fsq.
Attornev for Plaintiff'
08-5 350
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney 1.D.856129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia. PA 19106
215-825-6318
Attorney for Plaintiff'
WELLS FARGO BANK, N.A., AS TRUSTL-F FOR
OPTION ONE, MORTGAGE LOAN TRUST 2007-
CPI ASSET-BACKED CERTIFICATES, SERIES
')007-CI )I
4650 Rcgettt Blvd
Irving, TX 75063
Plaintiff
IN TIIF, COURT OF COMMON PLEAS
Of Cumberland County
CIVIL A("I ION - LAW
ACTION OF MORTGAGE
FORECLOSURE
VS.
CHERYL E. RUDD
Mortgagor(s) and Record Owner(s)
9 East South Street
Carlisle, PA 17013
Def endant(s
Term
No. 08-5380
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: RUDD, CHERYL E.
CHERYL E. RUDD
621 Mill Race Road
Carlisle, PA 17013
Your house at 9 East South Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $117,831.87 obtained by WELLS FARGO BANK, N.A., AS TRUSTEE FOR OPTION
ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED CERTIFICATES., SERIES 2007-CPI
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:
08-_5380
717-?-43-9400
08-5 ; X0
Resources available for_l-lorneowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action Of MOrt,ragc
Foreclosure against you. you still may be able to SAVE YOUR HOME FROI\1
FORECLOSURE.
I ). 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 wcbsite - www.hud. cry' for Help for Homeowners Facing the
Loss of Their Homes. -- -
4). Pennsylvania Housing Finance Agency also offers other loan prof rams that
may assist homeowners in default. Please See the PHFA website
htt?://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-231 1 or via email at homeretentioijj r, ;oNbeckIa_w.coin.
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 Attoniey File Number of 69995FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT
CERTAIN PROPERTY SITUATED IN CITY OF CARLISLE IN THE COUNTY OF
CUMBERLAND, AND STAT OF PA AND BEING DESCRIBED IN A DEED DATED
12/06%2004 AND RECORDED 01/03/2005 IN BOOK 266 PAGE 4638 AMONG THE
LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, AND
REFERENCED, AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON
ERECTED SITUATE IN THE SECOND WARD OF THE BOROUGH OF CARLISLE,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS
FOLLOWS:
ON THE SOUTH BY EAST SOUTH STREET, ON THE WEST BY LOT NOW OR
FORMERLY OF MRS. NANNIE B. BUSHMAN; ON THE NORTH BY LOT NOW
OR FORMERLY OF JAMES MCGONIGAL'S HEIRS, ON THE EAST BY OTHER
PROPERTY FORMERLY OF THE ESTATE OF CHARLES C. HOFFER, DECEASED
HAVING A FRONTAGE ON EAST SOUTH STREET OF 17.63 FEET AND
EXTENDING AT EVEN WIDTH TO DEPTH OF 60 FEET AND IMPROVED WITH
A TWO STORY BRICK DWELLING HOUSE KNOWN AS NO. 9 EAST SOUTH
STREET.
TOGETHER WITH THE USE IN COMMON WITH OWNERS AND OCCUPIERS OF
THE PROPERTY ADJOINING ON THE EAST, OF A THREE FEET WIDE
PASSAGEWAY SITUATED EQUALLY ON BOTH LOTS AND EXTENDING
NORTHWARDLY FROM EAST SOUTH STREET, A DISTANCE OF
APPROXIMATELY 30 FEET.
PARCEL NO. 03-21-0320-136
BEING KNOWN AS: 9 East South Street, Carlisle, PA 17013
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 08-5380 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., As Trustee for OPTION
ONE MORTGAGE LOAN TRUST 2007-CPI ASSET-BACKED CERTIFICATES, SERIES 2007-
CP 1, Plaintiff (s)
From CHERYL E. RUDD
(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 $177,831.87
L.L. $.50
Interest from 12/24/08 to Date of Sale per diem at $29.12
Atty's Comm %, Due Prothy $2.00
Atty Paid $205.00
Plaintiff Paid
Date: 12/30/08
(Seal)
REQUESTING PARTY
Other Costs to be added
Curtis R. Lo , ro honot y
By:
Deputy
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
to Tft i" wtww' I #us valo W My twd
d sW ri nW 0xvA At eadiab, Pa•
cg
Supreme Court ID No. 56129
Real Estate Sale # 08
On January 15, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
the Borough of Carlisle, Cumberland
County, PA Known and numbered as 9 East South Street
Carlisle, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: January 15, 2009
By.
J G -??, t, lip
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L. i1 784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
May 1, May 8, and May 15, 2009
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
v
2141
a Mane Coyne, ditor
SWO TO AND SUBSCRI13ED before me this
a I day of Mqy, 2009
7
r-?- /'? , K ??
Notary
NOTARIAL SEAL
D BJRAH A COLLINS
Notary Public
CARLISLE BOPO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
REAL ESTATE SALE NO. 8
Writ No. 2008-5380 Civil
Wells Fargo Bank, N.A. as Trustee
for Option One Mortgage Loan
Trust 2007-CPI, Asset-Backed
Certificates, Series 2007-CPI
vs.
Cheryl E. Rudd
Atty.: Michael T. McKeever
LAND REFERRED TO in this com-
mitment is described as all that cer-
tain property situated in City of Car-
lisle in the County of Cumberland,
and Stat of PA and being described
in a deed dated 12/06/2004 and
recorded 01/03/2005 in Book 266
Page 4638 among the land records of
the county and state set forth above,
and referenced, as follows:
ALL THAT CERTAIN lot of ground
with the improvements thereon
erected situate in the Second Ward of
the Borough of Carlisle, Cumberland
County, Pennsylvania, bounded and
described as follows:
ON THE SOUTH by east South
Street; on the west by lot now or for-
merly of Mrs. Nannie B. Bushman;
on the north by lot now or formerly
of James McGonigal's heirs; on the
east by other property formerly of the
Estate of Charles C. Hoffer, deceased
having a frontage on East South
Street of 17.63 feet and extending
at even width to depth of 60 feet
and improved with a two story brick
dwelling house known as No. 9 East
South Street.
TOGETHER with the use in com-
mon with owners and occupiers of
the property adjoining on the east, of
a three feet wide passageway situated
equally on both lots and extending
northwardly from East South Street,
a distance of approximately 30 feet.
PARCEL NO. 03-21-0320-136.
BEING KNOWN AS: 9 East South
Street, Carlisle, PA 17013.
The Patriot-News Co.
812'Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8213
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
ttie Patriot-News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
04/24/09
05/01/09
05/08/09
Sworn toland dbscribed before me this 12 day of May, 2009 A.D.
i
Notary Public
COMMONWEALTH OF PENNSYLVANIA
=?totariai S??I
Sherne L Kisnee, Nclary Public
City Of Harrisbury, Dauphin County
My Commission Expires Nov. 26, 2011
Member, Pennsylvania Association of Notaries
Real Estate Sale No. 08
Writ No. 2008-5380 Civil Term
Wells Fargo Bank, N.A. as
Trustee for Option One
Mortgage Loan Trust 2007-
CP1, Asset-Backed Certificates,
Series 2007-CP1
VS
Cheryl E. Rudd
Attorney Michael T. Mckeever
LEGAL DESCRIPTION
LAND REFERRED TO IN THIS
COMMITMENT IS DESCRIBED AS ALL
THAT CERTAIN PROPERTY SITUATED IN
CITY OF CARLISLE IN THE COUNTY OF
CUMBERLAND, AND STAT OF PA AND
BEING DESCRIBED IN A DEED DATED 12/
06/2004 AND RECORDED 01103/2005 IN
BOOK 266 PAGE 4638 AMONG THE LAND
RECORDS OF THE COUNTY AND STATE
SET FORTH ABOVE, AND REFERENCED,
AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND
WITH THE IMPROVEMENTS THEREON
ERECTED SITUATE IN THE SECOND
WARD OF THE BOROUGH OF CARLISLE,
CUMBERLAND COUNTY,
PENNSYLVANIA, BOUNDED AND
DESCRIBED AS FOLLOWS:
ON THE SOUTH BY EAST SOUTH STREET,
ON THE WEST BY LOT NOW OR
FORMERLY OF MRS. NANNIE B.
BUSHMAN; ON THE NORTH BY LOT NOW
OR FORMERLY OF JAMES MCGONIGAL'S
HEIRS; ON THE EAST BY OTHER
PROPERTY FORMERLY OF THE ESTATE
OF CHARLES C. HOFFER, DECEASED
HAVING A FRONTAGE ON EAST SOUTH
STREET OF 17.63 FEET AND EXTENDING
AT EVEN WIDTH TO DEPTH OF 60 FEET
AND IMPROVED WITH A TWO STORY
BRICK DWELLING HOUSE KNOWN AS
NO.9 EAST SOUTH STREET.
TOGETHER WITH THE USE IN COMMON
WITH OWNERS AND OCCUPIERS OF THE
PROPERTY ADJOINING ON THE EAST, OF
A THREE FEET WIDE PASSAGEWAY
SITUATED EQUALLY ON BOTH LOTS AND
EXTENDING NORTHWARDLY FROM EAST
SOUTH STREET, A DISTANCE OF
APPROXIMATELY 30 FEET.
PARCEL NO. 03-21-0320-136
BEING KNOWN AS: 9 East South Street.
Carlisle, PA 17013
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 OPTION ONE MTG LOAN TRUST 2007-CPI TR is the grantee the same
having been sold to said grantee on the I OTH day of JUNE A.D., 2009, under and by virtue of a writ
Execution issued on the 30TH day of DEC, A.D., 2008, out of the Court of Common Pleas of said
County as of Civil Term, 2008 Number 5380, at the suit of OPTION ONE MTG LOAN TRUST 2007-
CPI TR against CHERYL E RUDD is duly recorded as Instrument Number 201011358.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
A.D. vC C
r- Co
-- ?' ? Recorder of Deeds
an* ftdftFA
?- Ny ??q(?t11o?1t?M?.?11
;l
GOLDBECK McCAFFERTY & McKEEVER
Professional Corporation
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
WELLS FARGO BANK, N.A., AS TRUSTEE
FOR OPTION ONE MORTGAGE LOAN
TRUST 2007-CPI ASSET-BACKED
CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd
Irving, TX 75063
vs.
CHERYL E. RUDD
Mortgagor(s) and Record Owner(s)
9 East South Street
Carlisle, PA 17013
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
Term
No. 08-5380
Z5
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the judgment in the above matter satisfied of record.
By:
GOL CK CAFFE Y & MCKEEVER
Michael Mc eever a. 56129
Gary McCafferty Pa. ID 42386./'
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Attorneys for Plaintiff
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Rm
GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
WELLS FARGO BANK, N.A., AS TRUSTEE
FOR OPTION ONE MORTGAGE LOAN
TRUST 2007-CPI ASSET-BACKED
CERTIFICATES, SERIES 2007-CP 1
4650 Regent Blvd
Irving, TX 75063
Plaintiff
vs.
CHERYL E. RUDD
(Mortgagor(s) and
9 East South Street
Carlisle, PA 17013
Record owner(s))
IN THE COURT OF COMMON
PLEAS
of Cumberland County
No. 08-5380;
:tea
?s
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Settled, Discontinued and Ended upon payment of your costs
only.
By:
GOL 'NqCj?,ACCAFFERTY MCKEEVER
Michael Mc
/Gary McCafferty Pa. ID 42386
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay E. Kivitz Pa. ID 26769
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
KML LAW GROUP, P.C.
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
ATTORNEY FOR PLAINTIFF
WELLS FARGO BANK, N.A, AS TRUSTEE
FOR OPTION ONE MORTGAGE LOAN
TRUST 2007-CPI ASSET-BACKED
CERTIFICATES, SERIES 2007-CPI
4650 Regent Blvd
Irving, TX
vs.
CHERYL E. RUDD
Mortgagor(s) and Record Owner(s)
9 East South Street
Carlisle, PA 17013
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
-v 3
Term
m
No. 8-5380=rn °
r'a
°
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Cz> C
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r7l
-C (Ji
PRAECIPE TO AMEND SATISFACTION OF JUDGMENT
TO THE PROTHONOTARY:
The judgment in the above matter having been satisfied on June 10, 2009, kindly mark
the judgment in the above matter satisfied of record.
By:
L L GROUP, P.C.
,AI
i144ichael McKeever Pa. ID 56129
' Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Ann E. Swartz Pa. ID 201926
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff