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Home My WebLink About08-5727GOLDBECK 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FRI PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN Mortgagor and Record Owner 57 Leeds Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08 -5'701'1 0'imTerh Defendant I CIVIL ACTION: MORTGAGE NOTICE FOREMOSURE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3).. Visit HUD'S website www.hud.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 hhlln://www.Dhfa.orp /consumerslhomeowners/real asnx. 5). Call the Plaintiff (your lender) at 877-362-6631 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 1-866413-2311 or via email at homeretention(a?oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 71832FC. 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1, PO Box 293150, Lewisville, TX 75029. 2. The names and addresses of the Defendant is EARL P. GARMAN, 57 Leeds Road, Newville, PA 17241, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On February 04, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR FREMONT INVESTMENT & LOAN, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1896, Page 3372. The mortgage has been assigned to: LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1 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 May 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 ....................................................................... Interest from 04/01/2008 through 09/30/2008 at 10.8750%...... Per Diem interest rate at $27.39 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .... Late Charges from 05/01/2008 to 09/30/2008....... .............$91,946.99 ...............$5,012.37 .............$4,597.35 .............$1,242.52 Monthly late charge amount at $52.86 Costs of suit and Title Search .............. ....................................................... $900.00 Escrow Advance ..................... ..............................................................$468.03 Monthly Escrow amount $212.66 $104,167.26 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 $104,167.26, together with interest at the rate of $27.39, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By ?? GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, , as the representative of EMC Mortgage Corporation as serving agent 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: 2 LaSalle Ban ational Association, as Trustee for Certificatehol rs of Bear Stearns Asset Backed Securities I LLC, Asset-Backed Certificates, Series 2005-FRi, by EMC Mortgage Corporation as Attorney in Fact 0011581030 EARL P. GARMAN E.,xhibitA • ?I I ALL THAT CERTAIN trod of land situate In Penn ToJmship, Cumberland County, Pennsylvania, hounded and in accordance with Plan of Subdivision for Richard E. Snyder prepared by Thomas Alvin Neff, Regislered Surveyor, as last n+viaad on January 24". 1985, 1 copy of which Is recorded In hereinafter named Recorder's Office In Plan Book 47, Page; 44, and i?roorparsted herein reference, as follows: BEGINNING at a spi s in the original centerline of 33-feet wide L.R. 21075, at comer of land now or formerly of Paul Skim; thence along the sougt4m line of said land nor or rormwly of Paul R. Skiers, South 89 egress 30 minutes East, a distahoa of 545.70 feat to an Won pfd In line of land now or forth Charles A # 8rough; thence along the western tine of said W# row or formarly of Charles , Brough South 11 depress 25 rltkutes East. a distance of 153x.30 Net lo an iron pin at the dividi n line between Lots Nos,1 and 2i as shown on said Plan of S ivision for Richard E. Snyder; along said dividing line between sold Lots Noe. 1 and 2, s9 degrees 30 minutes eat, a distance of 576.80 fast to a spike In the od*@1 cant s of 33-160 wide L.R. 21075; Siang sold original centerline of 33-Nstwl4e L.R 21075, 00 depress 17 minutes seconds East, a distance of 150.01 feet to a spike at place BEGINNING. THE ABOVE descri trad of land contains an area of 1.878 acres exclusive of dedicated right-of-way of said R. 21075, and is sit of Lot No. Vas shown on said Plan of Suulb ivision for Richard E. Snyder recorded in Plan Book 47, Page 44. SO MUCH of the soove-described promises as lies wphkt 25 feel of the original centerlkw of 33- feet wide L.R. 21075 as been dediated as a portion of the right-of:way of said 1.1 .21075 as shown on said Plan Subdivision for Richard E. Snyfler recorded In Plan Book 47, fags 44. THE ABOVE desc trod of lend has thereon erected a dweeing house and other Improvements form known as R. 0. #1 Box 260, now known and numbered as 57 Leeds Road, Newvdle, Pert yivanie 17241. BEING THE SAME P)IEMISES which Vincent Bematie, Jr, Estate, by Its deed to be recorded simullaneously ham"h in Me Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Gar? P, Garman, I i Exhibit o EMC Mortgage Corporation May 1, 2008 I 6 3 ? 3 2 2 8' Earl P Garman 57 Leeds Rd Newville, PA 17241-9547 &,?EE AfRTION E APT 91 N FOWRI'CY-T CrT?F? This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou wheou meet with the counseling agency The name, address and phone number of Consumer Credit Counselin A encies servin our county are listed at the end of this Notice_If you have any questions you may call the Pennsylvania Housing Finance AQenc toll free at 1-800-342-2397 impaired heanne can ca11717-780-1869) - - y- - (persons with 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 Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S): Earl P Garman PROPERTY ADDRESS: 57 Leeds Rd LOAN ACCOUNT NUMBER: Newville, 15810 OA 17241-9547 0 CURRENT SERVICER EMC Mortgage Corporation Page two 0011581030 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM You may be eligible_for_financial assistance,_which can save our home from_foreclosure and help -in Av payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act f 83 (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 the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. This meeting must occur within the next thirty (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 counseline agencies for the coup to which our pro e are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise this lender immediatejtof 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 Homeowners' Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowners' Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at 57 Leeds Rd Newville, PA 17241-9547 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 02/01/2008: (b) Late charge(s): $3,487.33 (c) Other charge(s): NSF and Advances $ $52 .08 ,031 (d) Less: Credit Balance $520.00 (e) Total amount required as of 04/30/2008: $0.00 $5,038.41 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $5,038.41, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to EMC Mortgage Corporation at Po Box 660530 Dallas, TX 75266-0530. Page three 0011581030 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right 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, EMC Mortgage Corporation also intends to instruct their attorneys to start a 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 they begin 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 are over $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 attorneys' 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 paying the total amount then past due plus any late or other charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such Sheriffs Sale of the mortgaged proprty could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: EMC Mortgage Corporation Address: Po Box 660530 Dallas, TX 75266-0530 Telephone Number: 1-888-609-2379 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 furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You 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 attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT -- To sell the property to obtain money to pay off the mortgage debt, or to borrow money from another lending institution to 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. (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. Page four 0011581030 EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debtor a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, EMC Mortgage Corporation EMC Mortgage Corporation Po Box 660530 Dallas, TX 75266-0530,1-888-609-2379 Appendix B Consumer Credit Counseling Agency Notification To: Name of Mortgagee: Address: In accordance with the Pennslyvania Homeowner's Emergency Mortgage Assistance Program (Act 91 of 1983), we have been approached for mortgage counseling assistance by: Name of Applicant Address Telephone Number Mortgage Loan Number Address of property on which mortgage is in default, If different from above. The counseling agency met with the above named applicant on Date Who have indicated that they are more than sixty (60) days delinquent on their mortgage payments and have received notification to foreclosure from: Name and Address of Mortgage In accordance with the Homeowner's Emergency Mortgage Assistance Program, this is to inform you that: 1. If the delinquency cannot be resolved with in the 30 day forbearance period as provided by the Servicer, the applicant listed above may apply to the Pennsylvania Housing Finance Agency for Homeowner's Emergency Mortgage Assistance. 2. By a copy of this Notice, we are notifying all other mortgagees, if any, which the applicant has indicated as also having a mortgage on the property identified above. 3. It is our understanding that the 30 day forbearance period in which we are now in ends on 4. No legal action to enforce the mortgage may occur during this forbearance period, unless procedural time limits were not met by the homeowner. Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 *Bucks, Chester, Delaware, Montgomery, Philadelphia * Indicates Counties Serviced Americon Financial Counseling Services 1 Abington Plaza, Suite 403 Old York Road and Township Line Jenkintown, PA 19046 (800) 490-3039 *Delaware, Montgomery Action Housing Inc 425 6th Avenue Suite 950 American Financial Counseling Services , Pittsburgh PA 15219 175 Strafford Avenue, Suite One , (412) 281-2102 Wayne, PA 19087 *Allegheny, Beaver, Butler, Fayette, Greene, W hi 800) 490-3039 *Bucks, Chester, Delaware Mongomer as ngton, Westmoreland , y, Philadelphia Adams County Interfaith Housing Authority 40 E High Street American Financial Counseling Services Gettysburg, PA 17325 906 Penn Avenue (717) 334-1518 Wyomissing, PA 19610 *Adams, Cumberland, Franklin, York 78 *Berk0.0680 erks Advocates for Financial Independence 1806 S Broad Street Suite 18 American Red Cross - Hanover Chapter , Philadelphia PA 19145 529 Carlisle Street , (215) 389-2810 Hanover, PA 17331 (Philadelphia (717) 637-3768 Adams, Franklin, York Allegheny County Acorn 5907 Penn Avenue, Suite 300 Pittsburgh, PA 15206 (412) 441-6551 *Allegheny American Credit Counseling Institute 21 S Church Street West Chester, PA 19380 (888) 212-6741 *Chester American Credit Counseling Institute 300 North Pottstown Pike, Suite 210 Exton, PA 19341 (888) 212-6741 *Berks, Bucks, Montgomery American Credit Couseling institute 528 Dekalb Street Norristown, PA 19401 (610) 971-2210 *Montgomery American Credit Counseling Institute 530 W Street Road, Suite 201 Warminster, PA 18974 (215) 444-9429 *Bucks, Montgomery, Philadelphia American Credit Counseling Institute 845 Coates Street Coatesville, PA 19320 (888) 212-6741 *Bucks, Chester, Montgomery, Philadelphia American Credit Counseling Institute 937 North Hanover Street Pottstown, PA 19460 (888) 212-6741 *Berks, Bucks, Montgomery American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 (610) 874-1484 *Chester, Delaware APM 2147 Norht Sixth Street Philadelphia, PA 19122 (215) 235-6788 *Chester, Delaware, Philadelphia Armstrong CO Community Action Agency 124 Armsdale Road, Suite 211 Kittanning, PA 16201 (724) 548-3405 *Armstrong Blair County Community Action Agency 2100 6th Avenue, Suite 102 P.O. Box 1833 Altoona, PA 16602 (814) 946-3651 *Blairl Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 *Crawford, Erie, Warren Bucks County Housing Group 200 West Bridge Street Morrisville, PA 19067 (866) 866-0280 *Bucks Bucks County Housing Group 2324 Second Street Pike, Suite 17 Wrightstown, PA 18940 (866) 866-0280 *Bucks Bucks County Housing Group 349 Durham Road Penndel, PA 19047 (866) 866-0280 *Bucks Bucks County Housing Group 470 Old Dublin Pike Doylestown, PA 18901 (866) 866-0280 *Bucks Bucks County Housing Group 515 West End Blvd Quakertown, PA 18951 (866) 866-0280 *Bucks Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (610) 375-7866 *Berks, Chester, Schuylkill Carroll Park Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 (215) 877-1157 *Chester, Delaware, Philadelphia CCCS of Delaware Valley 1230 New Rodgers Road, Suite F1 Bristol, PA 19007 (215) 563-5665 *Bucks CCCS of Delaware Valley 1515 Market Street, Suite 1325 Philadelphia, PA 19107 (215) 563-5665 *Bucks, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley 1777 Sentry Parkway W, Suite 200 Blue Bell, PA 19422 (215) 563-5665 *Montgomery CCCS of Delaware Valley 280 North Providence Road Media, PA 19063 (215) 563-5665 *Delaware CCCS of Delaware Valley Marshal Building 790 E Market St, Suite 170 West Chester, PA 19382 (215) 563-5665 *Chester, Delaware CCCS of Delaware Valley Catholic Social Services Building 7340 Jackson Street Philadelphia, PA 19136 (215) 563-5665 *Bucks, Philadelphia CCCS of Delaware Valley One Cherry Hill, Suite 215 Cherry Hill, PA 08002 (215) 563-5665 *Philadelphia CCCS of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (610) 821-4011 *Berks, Bucks, Carbon, Lancaster, Lehigh, Northhampton, Schuylkill * Indicates Counties Serviced CCCS of Northeastern PA 1400 Abington Exec. Park, Suite 1 Clarks Summitt, PA 18411 (570) 587-9163 *Carbon, Columbia, Lackawanna Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Tioga, Union, Wayne, Wyoming CCCS of Northeastern PA 201 Basin Street, Suite 6 Williamsport, PA 17701 (570) 323-6627 *Centre, Clinton, Lycoming, Northumberland, Union CCCS of Northeastern PA 202 W Hamilton Avenue State College, PA 16801 (814) 238-3668 *Blair, Centre, Clearfield, Clinton, Huntingdon, Juniata, Mifflin CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 (570) 602-2227 *Bradford, Carbon, Columbia, Lackawanna, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Tioga, Union, Wayne, Wyoming CCCS of Northeastern PA 411 Main Street, Suite 104 Stroudsburg, PA 18360 (570) 420-8980 *Bradford, Carbon, Monroe, Pike, Wayne CCCS of Western PA 1 North Gate Square #2 Garden Center Dr Greensburg, PA 15601 (888) 511-2227 *Fayette, Greene, Indiana, Somerset, Washington, Westmoreland CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (888) 511-2227 'Adams, Cumberland, Dauphin, Franklin, Perry Synder, York CCCS of Western PA 219-A College Park Plaza Johnstown, PA 15904 (888) 511-2227 *Cambria, Clearfield, Indiana, Somerset CCCS of Western PA 312 Chestnut Street, Suite 227 Meadville, PA 16335 (888) 511-2227 *Lawrence CCCS of Western PA 41 East Chestnut Street Washington, PA 15301 (888) 511-2227 *Washington CCCS of Western PA 4402 Peach Street Erie, PA 16509 (888) 511-2227 *Crawford, Erie, Warren CCCS of Western PA 524 Franklin Avenue Aliquippa, PA 15001 (888) 511-2227 *Cameron CCCS of Western PA 917 A Logan Boulevard Altoona, PA 16602 (888) 511-2227 *Armstrong, Bedford, Blair, Cambria, Centre, Clearfield, Huntingdon, Juniata, Mifflin, Union CCCS of Western PA 971 Third Street Beaver, PA 15009 (888) 511-2227 *Beaver CCCS of Western PA Colonial Shopping Center 970 S George Street York, PA 17403 (888) 511-2227 *Franklin, Fulton, Lancaster, York CCCS of Western PA Pullman Commerce Center 112 Hollywood Dr Butler, PA 16001 (888) 511-2227 *Butler, Clarion, Jefferson, Mercer, Venango CCCS of Western PA River Park Commons 2403 Sidney Street Pittsburgh, PA 15203 (888) 511-2227 *Allegheny Chester Community Improvement Project 412 Avenue of the States P.O. Box 541 Chester, PA 19016 (610) 876-8663 *Chester, Delaware, Montgomery, Philadelphia Comm. On Econ Opportunity of Luzeme Co. 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 *Carbon, Luzeme, Schuylkill, Wyoming Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17094 *Cumberland, Dauphin, Franklin, Perry, Synder Community Action Committee of the Lehigh Valley 1337 East Fifth Street Bethlehem, PA 18015 (610) 691-5620 *Berks, Carbon, Lehigh, Monroe, Northhampton Community Action Development Comm - CADCOM 113 E Main Street Norristown, PA 19401 (610) 277-6363 'Montgomery Community Action Southwest 150 W Beau Street, Suite 304 Washington, PA 15301 (724) 225-9550 *Washington Community Action Southwest 58 E Greene Street Waynesburg, PA 15370 (724) 852-2893 *Allegheny, Fayette, Greene, Washington, Westmoreland Congreso 216 West Somerset Street Philadelphia, PA 19133 (215) 763-8870 *Philadelphia Council of Spanish Speaking Organization 705-09 North Franklin St Philadelphia, PA 19123 (215) 627-3100 *Philadelphia Diversified Community Service Dixon House 1920 South 20th Street Philadelphia, PA 19145 (215) 336-3511 *Bucks, Chester, Delaware, Philadelphia Fair Housing Partnership of Greater Pittsburgh, Inc. 2840 Liberity Ave., Suite 205 Pittsburgh, PA 15222 (412) 391-2535 *Allegheny Fayette Co. Community Acfion Agency Inc 137 North Beeson Avenue Uniontown, PA 15401 (724) 437-6050 *Fayette, Somerset FOB CDC 1201 West Only Avenue Philadelphia, PA 19141 (215) 549-8755 *Bucks, Chester, Delaware, Philadelphia Frankford CDC 4625 Frankford Avenue, 2nd Floor Philadelphia, PA 19124 (215) 743-9201 *Philadelphia Garfield Jubilee Associates 5138 Penn Avenue Pittsburgh, PA 15224 (412) 665-5200 *Allegheny Germandtown Settlement 5538 Wayne Avenue Bldg C Philadelphia, PA 19144 (215) 849-3104 *Bucks, Chester, Delaware, Montgomery, Philadelphia Greater Erie Commun. Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 *Crawford, Erie, Venango, Warren HACE 167 W Allegheny Ave., 2nd Floor Philadelphia, PA 19140 (215) 426-8025 *Bucks, Chester, Delaware, Philadelphia Housing Alliance of York 35 South Duke Street York, PA 17401 (717) 854-1541 *York Housing Assoc. of Delaware Valley 1500 Walnut Street, Suite 601 Philadelphia, PA 19102 (215) 545-6010 *Philadelphia Housing Assoc. of Delawre Valley 658 North Watts Street Philadelphia, PA 19123 (215) 978-0224 *Philadelphia Housing Opportunities of Beaver Co. 320 College Avenue, Unit 1 Beaver, PA 15009 (724) 728-7511 *Beaver, Lawrence Housing Partnership of Chester County 41 West Lancaster Avenue Downingtown, PA 19335 (610) 518-1522 *Chester, Delaware, Montgomery Huntingdon County Housing Servicing Weatherization, Inc. 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2342 'Bedford, Blair, Fulton, Huntingdon, Juniata, Mifflin, Perry Indiana Co. Community Action Prog. 827 Water Street Box 187 Indiana, PA 15701 (724) 465-2657 *Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services Inc. 4225 Chestnut Street Philadelphia, PA 19104 (215) 386-1298 'Philadelphia Keystone Economic Develop. Corp. 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 *Bedford, Blair, Cambria, Clearfield, Indiana, Somerset, Westmoreland * Indicates Counties Serviced Koren Comm. Develop. Services Center 6055 Norht 5th Street Philadelphia, PA 19120 (215) 276-8830 *Philadelphia Lawrence County Social Services, Inc. 241 West Grant Street P.O. Box 189 New Castle, PA 16103 (724) 658-7258 *Lawrence Liberty Resources 714 Market Street, Suite 100 Philadelphia, PA 19106 (215) 634-2000 *Philadelphia Loveship, Inc. 2320 North 5th Street Harrisburg, PA 1711 (717) 232-2207 'Cumberland, Dauphin, Perry Lycom-Clntn Co Comm fo Comm Action 2138 Lincoln Street P.O. Box 3568 Williamsport, PA 17703 (570) 326-0587 'Centre, Clinton, Lycoming, Union New Life Comm. Housing Devel Corp. 712 Hawkins Avenue Braddock, PA 15104 (412) 351-4077 *Allegheny, Washington, Westmoreland Northern Tier Community Action Corp. 135 West 4th Street P.O. Box 389 Emporium, PA 15834 (814) 4861161 *Cameron, Elk, Mckean, Potter Northwest Counseling Service 5001 North Broad Street Philadelphia, PA 19141 (215) 324-7500 *Bucks, Chester, Delaware, Montgomery, Philadelphia Nueva Esperanza 4261 North 5th Street Philadelphia, PA 19140 (215) 324-0746 *Philadelphia Pennsylvania Housing Finance Agency 2275 Swallow Hill Rd., Bldg 200 Pittsburgh, PA 15220 (412) 429-2842 *Allegheny Maranatha PHFA 43 Philadelphia Avenue 211 North Front Street Waynesboro, PA 17268 Harrisburg, PA 17110 (717) 762-3285 (800-) 342-2397 Adams, Cumberland, Franklin, Fulton, Perry *Cumberland, Dauphin Media Fellowship House 302 South Jackson Street Media, PA 19063 (610) 565-0434 *Chester, Delaware Philadelphia Council for Comm. Advmnt. 100 N 17th St, Suite 600 Philadelphia, PA 19103 (215) 567-7803 'Chester, Delaware, Montgomery, Philadelphia Mon Valley Unemployment Committee 1800 West St., 3rd Floor Homestead, PA 15120 (412) 462-9962 *Allegheny, Washington, Westmoreland Mt. Airy, USA 6703 Germantown Ave., Suite 200 Philadelphia, PA 19119 (215) 844-6021 'Philadelphia Nazareth Housing Services 285 Bellevue Road Pittsburgh, PA 15229 (412) 931-3510 *Allegheny Neighborhood Housing Services Inc. 213 N 5th St., Suite 1030 Reading, PA 19601 (610) 372-8433 *Barks Neighborhood Housing Services 710 5th Avenue, Suite 1000 Pittsburgh, PA 15219 (412) 281-9773 *Allegheny Philadelphia Senior Center 509 South Broad Street Philadelphia, PA 19147 (215) 546-5879 *Philadelphia Schuylkill Community Action 225 N. Centre Street Pottsville, PA 17901 (570) 622-1995 *Berks, Carbon, Lebanon, Lehigh, Luzeme, Northumberland, Schuylkill Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (724) 981-5310 'Crawford, Lawrence, Mercer South Philadelphia H.O.M.E.S. 1444 Point Breeze Avenue Philadelphia, PA 19146 (215) 334-4430 *Philadelphia Southwest Community Development Corp. 6368 Paschall Avenue Philadelphia, PA 19142 (215) 729-0800 *Philadelphia St. Martin Center 1701 Parade Street Erie, PA 16503 (814) 452-6113 *Crawford, Erie, Venango, Warren Tableland Services Inc. 535 East Main Street Somerset, PA 15501 (814) 445-9628 *Cambria, Fayette, Somerset, Westmoreland Tabor Community Services 308 E King Street, Suite 1 Lancaster, PA 17602 (717) 397-5182 *Chester, Lancaster, Lebanon The NORCAM Group 4200 Crawford Avenue, Suite 200 Northern Cambria, PA 15714 (814) 948-4444 *Cambria, Clearfield The Trehab Center of Northeastern PA 10 Public Avenue P.O. Box 366 Montrose, PA 18801 (570) 278-3338 *Susquehanna * Indicates Counties Serviced The Trehab Center of Northeastern PA 115 SR 92S Tuckhannock,PA 18657 (570) 836-6840 *Wyoming The Trehab Center of of Northeastern PA 1225 Main Street Honesdale, PA 18431 (570) 253-8941 *Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming The Trehab Center of Northeastern PA 144 E East Avenue Wellsboro, PA 16901 (570) 724-5252 *Tioga The Trehab Center of Northeastern PA German Street P.O. Box 389 Dushore, PA 18614 (570) 928-9667 *Sullivan The Trehab Center of Northeastern PA The Enterprise Center 703 S. Elmer Ave., Suite M-6 Sayre, PA 18840 (570) 888-0412 *Bradford United Communties Southeast Philadelphia 2029 South 8th Street Philadelphia, PA 19148 (215) 467-8700 *Philadelphia Urban League of Philadelphia 1818 Market Street Philadelphia, PA 19103 (215) 561-6070 *Bucks, Delaware, Philadelphia Urban League of Pittsburgh Building for Equal Opportunity One Smithfield St. Pttsburgh, PA 15222 (412) 227-4802 *Allegheny Voices for Independence 3711 West 12th Street Erie, PA 16505 (800) 838-9890 *Erie Warren-Forest Counties Economic Opportunity Council 1209 Pennsylvania Ave W. P.O. Box 547 Warren, PA 16365 (814) 726-2400 *Forest, Waren -bfp +Ik ? a (h G1 D C ' i n, fJ? t SHERIFF'S RETURN - NOT SERVED CASE NO: 2008-05727 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOCIA VS GARMAN EARL P R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: GARMAN EARL P unable to locate Him in his bailiwick. COMPLAINT - MORT FORE but was He therefore returns the NOT SERVED , as to the within named DEFENDANT GARMAN EARL P 57 LEEDS ROAD NEWVILLE, PA 17241 SERVICE STOPPED, PER FAX FROM ATTORNEY. . Sheriff's Costs : So answers" Docketing 18.00 Service 10.00 Affidavit .00 R. Thomas Klin ,'. Surcharge 10.00 Sheriff of Cumband County /d?1410 Q? ? 3 8 . 0 0 GOLDBECK MCCAFFERTY MCKEEVER 10/10/2008 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN 57 Leeds Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. c? N c M C) rtt'? %, By: -/ Awue_ GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF $IO.OC PD ATtj cif -r-231 r1a8 e A agn8 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM Term No. 08-5727 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff %V at +C?c>? , r ?? 0 OFFICE OF THE St ERIFF T Jody S Smith Chief Deputy Richard W Stewart Solicitor ,Y) I 1 t 1 r rr r•'1, LUtu Glii1 1 LaSalle Bank National Association Case Number vs. Earl P. Garman 2008-5727 SHERIFF'S RETURN OF SERVICE 06/11/2010 04:13 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2010 at 1613 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Earl P. Garman, by making known unto himself personally, at 57 Leeds Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. Z-2_-?7 A*f?g? DENMI FRY, DEPU SHERIFF COST: $38.80 June 14, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teieosoft. Inc. 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 r L. ?{ 2010JU'L 12 AM H: ilb C UM L: jujN1 ?.1a. LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM No. 08-5727 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P. 2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI for Voluntary Substitution under Pa.R.C.P. 2352 and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the Plaintiff is PO Box 293150 Lewisville, TX 75029. MICHAEL T. MCKEEVER, ESQUIRE c?c 70 P;2 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM No. 08-5727 STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.RC.P. 2352 BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned action is one in mortgage foreclosure regarding the premises as noted in the caption. 2. The subject of the above-captioned action is a first mortgage on said premises recorded at Mortgage Book 1896, Page 3372 in the Office of the Recorder of Deeds for this County. 3. The original Plaintiff is LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI. 4. BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI is the successor in interest to the Plaintiff by Assignment lodged for recording in the Office of the Department of Records and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. Respectfully submitted, MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road, Newville, PA 17241 Defendant(s) CERTIFICATE OF SERVICE CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM Term No. 08-5727 Michael T. McKeever, Esquire, hereby certifies that he did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on June 15, 2010. EARL P. GARMAN 57 Leeds Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Aa.4S_- ::0r*_ 1 # Michael T. McKeever, Esq. 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff VS. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) VERIFICATION CIVIL TERM No. 08-5727 MICHAEL T. McKEEVER, ESQUIRE hereby states that he is the attorney for Plaintiff herein, and that all of the facts set forth in the attached Praecipe for Voluntary Substitution of Plaintiff are true and correct to the best of his knowledge, information and belief. The undersigned understands that statements herein are made subject to the penalties of 18 P.S. section 4904. -XX\Aaa'Q T- yyl?u'i 0" Michael T. McKeever, Esquire IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Attorney for Plaintiff In the Court of Common Pleas of Cumberland County BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) PRAECIPE FOR JUDGMENT CIVIL TERM No. 08-5727 c? _0 c7 "`I -n U)r- 70 c:? tp ^Ci 5-n 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 EARL P. GARMAN by default for want of an Answer. Assess damages as follows: Debt Interest from 09/21/2010 to Date of Sale per diem at $27.40 Total (Assessment of Damages attached) $129,078.69 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 m d Khdva red to the party against whom judgment is to be entered and to his attorney of record, if any, after the defaul c u ed ea st ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237 By: GOLDBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW a3? , A I Judgment is entered in favor of LE BANK NATIONAL ASSOCIATION, AS BANK OF AMERICA, NATIONAL AS-SO IATION SB/M LA LIVE) TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1 and against EARL P. GARMAN by default for want of an Answer and damages assessed in the sum of $129,078.69 as per the above certification. 414.00 Po Al''N e? s?b8?fs Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff CIVIL TERM No. 08-5727 vs. EARL P. GARMAN (Mortgagors and Record Owner(s)) 57 Leeds Road Newville, PA 17241 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. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Prothono By: If you have any questions concerning the above, please con act: 91?3?a Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 71832FC 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: September S, 2010 TO: EARL P. GARMAN GARMAN, EARL P. 57 Leeds Road Newville, PA 17241 BANK OF AMERICA, NATIONAL ASSOCIATION S/B(M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005- FRI PO Box 293150 Lewisville, TX 75029 vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville, PA 17241 TO: EARL P. GARMAN 57 Leeds Road Newville, PA 17241 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure CIVIL TERM Term No. 08-5727 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 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, EARL P. GARMAN, is about unknown years of age, that Defendant's last known residence is 57 Leeds Road Newville, PA 17241, 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: /a 0//d Martin Hynes GOLDBECK McCAFFERTY & WKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, NATIONAL ASSOCIATION SB1M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR I PO Box 293150 Lewisville, TX 75029 vs. EARL P. GARMAN (Mortgagor(s) and Record owner(s)) 57 Leeds Road Newville, PA 17241 Plaintiff Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM No. 08-5727 Please enter Judgment in favor of BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 200 against EARL P. GARMAN for failure to file an Answer in the above action within (20) days (or sixty (60) da i fen nt he United States of America) from the date of service of the Complaint, in the sum of $129,078.69. / By: X/ X_7 %." .. GOLD CK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ?avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is BANK OF AMERICA, NATIONAL ASSOCIATION S/BJM LASALLE B ONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASS SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FRI PO Box 293150 Lewi i ffew, and that the name(s) and last known address(es) of the Defendant(s) is/are EARL P. GARMAN, 57 Leeds o A 0241; By: GOLDB K M C RTY & MCKEEVER Michae cKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Li a Lee Pa. ID 78020 'stina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 homas Puleo Pa. ID 27615 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $91,946.99 Interest from 04/01/2008 through $24,742.20 09/20/2010 Reasonable Attorney's Fee $4,597.35 Late Charges $1,532.94 Costs of Suit and Title Search $900.00 Escrow Payments Due 23 X $212.66 $4,891.18 Escrow Advance $468.03 $1 By: Al Y7-- - GOLDBE MCCAFFERTY & MCKEEVER Michael cKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW, this d314 day of 0 2010 damages are assessed as abov . Pr PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, NATIONAL ASSOCIATION S/B/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR I PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN Mortgagor(s) and Record Owner(s) 57 Leeds Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM No. 08-5727 C-) rn rn ? rrt r=.. N ? CJ?' C:) =C) CD PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: O Amount Due 4 a4. ca 38.00 38.80 1M.50 10.00 8.00 14.00 a.50 PD RrT1! 035F Interest from 09/21/2010 to Date of Sale per diem at $27.40 n (Costs to be added) $ a15. 8C) - PO Am 4.1.00 bVea • 50 LL C-0 64to845 R,o a48(0,7q $129,078.69 By: GOLDBE , MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 istina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff RE W-kd H u) 4 Ln `C W,) • Z z W w ,-. E O to a ? oQww z° N d N W o ° r U r ,.aWvi ?zd?H 7 w d? ?a G 4 a> o ?,° E- ff °?wAH a Ra = 3 a p o . ? `?dYU? a? d Z WR + o Z H UZ? d U ? 00 W °?° H -1 ? WV O U, r1, E-' U o ? W W W W 0 v`i'i Q w oG a a w u N d , ?aHH .c c ?s U 115 H 7 ? ?/U v PA ?o o° o? L7 N ALL THAT CERTAIN tract of land situate in Penn Township, Cumberland County, Pennsylvania, bounded and described in accordance with Plan of Subdivision for Richard E. Snyder prepared by Thomas Alvin Neff, Registered Surveyor, as last revised on January 24th, 1985, a copy of which is recorded in the hereinafter Recorder's Office in Plan Book 47, Page 44, and incorporated herein by reference, as follows: BEGINNING at a spoike in the original centerline of 33-feet wide L.R. 21075, at corner of land now or formerly of Paul R. Siders; thence along the southern line of said land now or formerly of Paul R. Siders, South 89 degrees 30 minutes East, a distance of 545.70 feet to an iron pin in line of land now or formerly of Charles A. Brough; thence along the western line of said land now or formerly of Charles A. Brough, South 11 degrees 25 minutes East, a distance of 153.30 feet to, an iron pin at the dividing line between Lots Nos. 1 and 2 as shown on said Plan of Subdivision for Richard E. Snyder; thence along said dividing line between said Lots Nos. 1 and 2, North 89 degrees 30 minutes West, a distance of 576.80 feet to a spike in the original centerline of 33-feet wide L.R. 21075; thence along said original centerline of 33-feet wide L.R. 21075, North 00 degrees 17 minutes 20 seconds East, a distance of 150.01 feet to a spike at place of BEGINNING. THE ABOVE described tract of land contains an area of 1.876 acres exclusive of the dedicated right-of- way of said L.R. 21075, and is all of Lot No. 1 as shown on said Plan of Subdivision for Richard E. Snyder recorded in Plan Book 47. Page 44. SO MUCH of the above-described premises as lies within 25 feet of the original centerline of 33-feet wide L.R. 21075 has been dedicated as a portion of the right-of-way of said L.R. 21075 as shown on said Plan of Subdivision for Richard E. Snyder recorded in Plan Book 47, Page 44. THE ABOVE described tract of land has thereon erected a dwelling house and other improvements formerly known as R.D. #1 Box 260, now known and numbered as 57 Leeds Road, Newville, Pennsylvania, 17241 TAX PARCEL #31-32-2313-036 `Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, NATIONAL ASSOCIATION SIB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 CIVIL TERM No. 08-5727 BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR I, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 Leeds Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): a cry GO EARL P. GARMAN rn =M M 57 Leeds Road a=te t" -< o tv -::0 C11 Newville, PA 17241 > C 2. Name and address of Defendant(s) in the judgment: ;ten = C)-n ? - C) C a EARL P. GARMAN ' 57 Leeds Road Newville, PA 17241 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 CAPITAL ONE BANK CIO WELTMAN WEINBERG AND REIS 1400 Koppers Building, 436 Seventh Avenue Pittsburgh, PA 15219 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTSIOCCUPANTS 57 Leeds Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: September 20, 2010 j? GOLDBECK McCAFFERTY & McKEEVER BY: Martin Hynes GOLDBECK WCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff VS. EARL P. GARMAN Mortgagor(s) and Record Owner(s) 57 Leeds Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM No. 08-5727 CERTIFICATION AS TO THE SALE OF REAL PROPERTY C= G MCU C/) m r=- m 3> -v „c C. l m ? b Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: GOLDI TY & WKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 08-5727 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BANK OF AMERICA, NATIONAL ASSOCIATION S/B/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN Mortgagor(s) and Record Owner(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM Docket No. 08-5727 rV c= C= cos r-rt -v rv C) -t -r? Urn J CJ 3 .._; C) C) _n o r; rri v 57 Leeds Road Newville, PA 17241r'l CO fri Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GARMAN, EARL P. EARL P. GARMAN 57 Leeds Road Newville, PA 17241 tv Your house at 57 Leeds Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $129,078.69 obtained by BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 08-5727 1. The sale will be cancelled if you pay to BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR1, 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. 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. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 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 08-5727 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-5727 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 http://www.12hfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 877-362-6631 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 71832FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5727 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, NATIONAL ASSOCIATION s/b/m LASALLE BANK NATIONAL ASSOCIATION, as Trustee for Certificateholders of BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI, Plaintiff (s) From EARL P. GARMAN (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 $129,078.69 L.L.$.50 Interest from 9/21/10 to Date of Sale per diem at $27.40 Atty's Comm % Due Prothy $2.00 Atty Paid $213.80 Plaintiff Paid Date: 9/23/10 (Seal) Other Costs avid D. Bue , Prothonotary By: Deputy REQUESTING PARTY: Name: THOMAS PULED, 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. 27615 GOLDBECK McCAFFERTY & McKEEVER 71832FC Suite 5000 t CF: 09/26/2008 Mellon Independence Center r_ ~ ` -PRO SD: 03/02/2011 3 701 Market Street T ' $129,078.69 Philadelphia, PA 19106-1532 Zi3j i F E6 24 Ali ? y' 33 215-627-1322 ND COUNTY Attorney for Plaintiff BANK OF AMERICA, NATIONAL pEN T OF COMMON PLEAS ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR of Cumberland County CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- CIVIL ACTION - LAW BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 ACTION OF MORTGAGE FORECLOSURE Lewisville, TX 75029 Plaintiff CIVIL TERM Term vs. No. 08-5727 EARL P. GARMAN Mortgagor(s) and Record Owner(s) 57 Leeds Road Newville, PA 17241 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) ERIC KEENAN, an employee of Goldbeck McCafferty & McKeever, counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( Personal Service by the Sheriffs Office/cw rotent coin .(copy of return attached). ( 3 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. Respe lly submitted, BY: ERIC KEENAN Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith i f t Ch e Depu y Richard W Stewart Solicitor 9FF1GE OF THE Sr ttF= LaSalle Bank National Association f Case Number EarlvsP.. Garman 2008-5727 SHERIFF'S RETURN OF SERVICE 12/29/2010 05:05 PM - Deputy Robert Bitner, being duly swom according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 57 Leeds Road, Newville, PA 17241, Cumberland County. 12/29/2010 05.05 PM - Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Marsha Garman, wife of defendant, who accepted as "Adult Person in Charge" for Earl P. Garman at 57 Leeds Road, Penn Township, Newville, PA 17241, Cumberland County. SHERIFF COST: $898.94 SO ANSWERS, January 19, 2011 RON R ANDERSON, SHERIFF ;c: CMIMYSLOO Sher-ft. Te lmal, Inc: ------------ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY .00n of ?tf?rA Y,' , QMCE OF THE SK RIFF LaSalle Bank National Association vs. Case Number I Earl P. Garman 2008-5727 SHERIFF'S RETURN OF SERVICE 12129/2010 05:05 PM - Deputy Robert Bitner, being duly swom according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 57 Leeds Road, Newville, PA 17241, Cumberland County. 12/29/2010 05:05 PM - Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Marsha Garman, wife of defendant, who accepted as "Adult Person in Charge" for Earl P. Garman at 57 Leeds Road, Penn Township, Newville, PA 17241, Cumberland County. SHERIFF COST: $898.94 SO ANSWERS, January 19, 2011 RON R ANDERSON, SHERIFF ,c_ C.ourrySui:e Merff. 7e`ecs?zt. irc: o - r; !u L g EJ ,? 5;p u? C.i ? C? e a•, G7 • .,i C'J 0 1. ??? "' ?? ? .+ 1MJf1 41 Ir?? C1 Y t > a m v U ~ m E d fn .$ T?Ec v• _ EE d fl? ?`¢ d U a a=aosao ? a? < ID z O m G _ N E W Z z 3 8 x m ss 2 a a , -- m w w ?m 3E? ¢¢¢tn m z . ???? ? ao: O ? E w CL a, cn w m m O a z X? m g z € y €. I ? n zcn g zw ?2 m3::. r T d o $ U2 j2 W_p•_ C?? w O Z z a m z `o O? u 10 0 d O CL z UUOti!_ a. O = Cc'-) ? J a ????. pca 42 ca cl1 U) w Z V1 ? 3 CL y _ x of < a) m O U UO n DU o N 89 a- -619 g-, a E b z v ~ E z 3? w HT rj wQ m cL a D Q Q cf3 ?X Wd.cy J U$Y N m -d . co m?<w r 3 p Q co 3????0 Za T T a f? N f 7 lri t p 3 ?. O D c d a c o' io m 0 z a d d E V J O a O O 6 cU w m co N O c 7 O C N 8 ? CD z -? U Z ? a h LL d N CO co j d Ur 0. U GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FRI PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN Mortgagor(s) and Record Owner(s) 5 7 Leeds Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM Term No. 08-5727 AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA, NATIONAL, ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR1, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 Leeds Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): EARL P. GARMAN 57 Leeds Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: EARL P. GARMAN 57 Leeds Road Newville, PA 17241 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 CAPITAL ONE BANK C/O WELTMAN WEINBERG AND REIS 1400 Koppers Building, 436 Seventh Avenue Pittsburgh, PA 15219 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 57 Leeds Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: February 10, 2011 GOLDBECK McCAFFERTY & McKEEVER BY: ERIC KEENAN Legal Secretary r KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff • ?- I?f?"-f1IF-?it gP n,Mi"RL,'-',B LS COUN'T`r` 'EP N' S rL VANIA BANK OF AMERICA, NATIONAL ASSOCIATION SB/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FRI PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: of Cumberland County CIVIL TERM No. 08-5727 Kindly vacate the judgment upon payment of your costs only. B .2-0 L LAW GROUP, P.C. Zi ichael McKeever Pa. ID 56129 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Qx? SG. 56 1 4 0? -7IIN(jU a 1035 Q 2-7964S IN THE COURT OF COMMON PLEAS KML LAW GROUP, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF BANK OF AMERICA, NATIONAL ASSOCIATION S/B/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET- BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) CERTIFICATE OF SERVICE CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL TERM Term No. 08-5727 Angela M. Smith, hereby certifies that he/she did serve true and correct copies of Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first 0 class mail, postage pre-paid, on _T_ 2 EARL P. GARMAN 57 Leeds Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY By: KML LA GROUP, P.C. Angela M. Smith, Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone) KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BANK OF AMERICA, NATIONAL ASSOCIATION S/B/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FR1 PO Box 293150 Lewisville, TX 75029 Plaintiff VS. EARL P. GARMAN (Mortgagor(s) and Record owner(s)) 57 Leeds Road Newville, PA 17241 Defendant(s) F DcnL?H?D GOLid C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 08-5727 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A?GOLDBECK McCAFFERTY & McKEEVER chael McKeever Pa. ID 56129 ay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff BANK OF AMERICA, NATIONAL, ASSOCIATION S/B/M LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET-BACKED CERTIFICATES, SERIES 2005-FRI PO Box 293150 Lewisville, TX 75029 Plaintiff vs. EARL P. GARMAN (Mortgagor(s) and Record Owner(s)) 57 Leeds Road Newville. PA 17241 Defendant(s) CERTIFICATE OF SERVICE CIVIL TERM No. 08-5727 Angela M. Smith, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on EARL P. GARMAN 57 Leeds Road Newville. PA 17241 KML LAW GROUP, P.C. F/K/A GOLD ECKMcCAFFERTY&McKEEVER By: /l. J;V'el Angela M. Smith, Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE