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Home My WebLink About08-6282GOLDBECK 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 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. LINDA S. KNECHT Mortgagor and Record Owner 1480 Timber Brook Drive Mechanicsburg, PA 17050 Defendant Term CIVIL A&ION: MORTGAGE FORECLOSUr-';',? NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A Ljlcu. L. I IN THE COURT OF COMMON OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES D,E ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.go_v 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 httv://www.nhfa.org/consumers/homeowners/realast)x. 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 -ldbecklaw 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 71754FC. 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 COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendant is LINDA S. KNECHT, 1480 Timber Brook Drive, Mechanicsburg, PA 17050, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On January 30, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1794, Page 2396. The mortgage has been assigned to: COUNTRYWIDE HOME LOANS INC. 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 March 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 ....................................................................................$85,894.75 Interest from 02/01/2008 through 10/20/2008 at 6.3750% .......................$3,945.00 Per Diem interest rate at $15.00 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,294.74 Late Charges from 03/01/2008 to 10/20/2008 .............................................$229.75 Monthly late charge amount at $28.72 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $115.33 $95,264.24 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 terris judgment in mortgage foreclosure in the sum of $95,264.24, together with interest at the rate of $15.00, 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: &G0L4DCCiMM---cc AF ERTY & MCKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION David Perez , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: 1480 Timber Brook Drive Mechanicsburg, PA 17050 - LINDA S. KNECHT ExhibitA Sep 02 2008 4:19PM HP LRSERJET 3330 Prepared by: M. RADNOR COUNTRYWIDE HONE LOANS, INC. BRANCH #217 DATE: 01/30/2003 HAMPDEN CTR 4830 CARLISLE PIKE CASE MECHANICSBURG. PA 17050- DOCID0002382751157088 Or1Fax3No.: (717)730-3824 BORROWER: L114DA S KNECHT PROPERTY ADDRESS; 1480 TIMBER BROOK DRIVE MECHANICSBURG, PA. 17050 LEGAL D1rSCRIP'1'ION 117QMET A p. 22 ALL THAT CERTAIN Unit, being Unit No. 1480 of Timber Chase 11, a Ttiwnhome Condominium located in the Townehp of Hampden, County of Cumberland and Commonwealth of Pennsylvania, which UnR Is designated In the Declaration of Condominium of Timber Chase H, a Townhome Condominium and Declaration Plats and Plans recorded in the Office of the Recorder of Deeds In 1VNec. Book 579, page 35 and right of way in Plan Book 11, page 139 respectively, together with any and all amendments thereto. PARCEL NO. 10-15-1283-011 UG (Knw k.AfMCNEC iT/3) BK 1794PG2412 r02=0a 1:1e:M pM CUMBERLAND COUNTY rwcs2cososos1 - ragas 17 azo EyFidit B ®cm*vw &- HOMELOANS PO Boa 9048 Temecula, CA 92589-9048 Send PaymaMs To: PO Banc 880694 Dallas, TX 75266-0894 Sand Cofraspondelwo b: PO Box 5170, MS SV314B Simi Valley, CA 93065 090602-7 8LCIPAI PRESORT First-Class Mail U.S. Postage and Fees Paid wSo 1054-10 IHIIIIIII?IIIIIINI 7113 8257 1472 7209 9029 Linda S Knecht 1480 TIMBER BROOK DR MECHANICSBURG, PA 17050-9164 101 ®Coun&yw &- HOME LOANS P.O. Box 850694 Dallas, TX 75258-0894 Send Payments to: PO Box 5604 Dalas, TX 75258-0594 06/0212008 Certified Mail: 7113 8257 1472 7209 9029 Return Receipt Requested Regular Mail Linda S Knecht 1480 TIMBER BROOK DR MECHANICSBURG, PA 17050-9164 FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consurner Credit Counselling 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 NOTIFICAC16N EN ADJUNTO ES DE SUMA WPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VNIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N IIMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PR9STAM0 POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Linda S Knecht PROPERTY ADDRESS: 1480 Tinber Brook Drive Mechanicsbura. PA 17050 LOAN ACCT. NO.: 23827511 ORIGINAL LENDER: CURRENT LENDERISERVICER: Countrvwide Home Loans Servicing LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELKNBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS • kfale pr do& pyaCii b Caulkywkle Horn lfern • Wfilerwscomonwilwan • your Mmyadmorlorl/amotrMs Wmorea11M , rtRr (own sere outMWdodo • Dmt r0edl your deck b the • ptr ? kldrKM correspondence • Dad amid Account No.: 23827511 Property Address: 1480 Timber Brook Drive Mechanicsburg, PA 17050 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM Please write yolraccolrnt ember on all rhecb and mrroapmhnce. We may dww you a fee for arny paymerd rearmed or rejected by your inacial insdlction, subject b applicable law. Accent Number: 23827511.9 Leda S Knecht Balartce Due for dta W fated above: $2.520.78 as of 62Yt008. 1480 Timber Brook Drive BLCPA1 Countrywide PO BOX 660694 Dallas, TX 75266-0694 il...I.I.I...1.1.11...I IAL„Ji,r I.I...I..II.I...I..I„1,111..r I Pleaw update email nfanmllon on tle wmw side of this coupon, anal Princpa anal Escrow ulna cz Total 023827511900000252078000252078 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a 'face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR Wrn4N THE NFVT 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 desianated consumer credit counselino aaenc'es for the county in which the property is located are set forth at the end of this Notice. It Is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its deciion 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 flied bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1480 Timber Brook Drive Mechanicsburg, PA 17050 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 03/01/2008 05/01/2008 Late Charoes: 03/0112008 Other Late Charaes Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: E-mail use: Pw4ft V= e-md address below will allow us to send you ilbrnalm w you account Acmnr Numbw 23WP 1 L Wa S Kneed E-nW address $1,379.40 $1,377.40 $86.16 $28.72 ($40.60) ($310.30) $2,520.78 How we pod your patrrr - All accepted payment Of I I I; d and WNW A be appal b Ne bnged outsiandrg mesa M due. unMm aberwise opesety pidrered cr roiled by low. ryou submt an cirque in adcMbn b your apreduled mm" amount, we will apply you payment as blows: In b oudri - ngnlily p rils or pdncipd and ftra t, M 1 l, , ddidemJes, A Its dwgee and other araift you an in corrrdbn w1h you ban aW IN) b mduce tlw mftbn e pdndpd balow of yar kw. Plam apecity y you wt an addronel aroma appled b hate payromb, ralwr Nan pbdpd reduction. Poallalel dwdw C=*ywide's poky IS b oat acoept poddeted dada, Wens sp&Mcdy agreed b by a loan munsebr or bcMidan. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (301 DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH 18 $2,520.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (301 DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by takina the folloaina action within THIRTY (30) DAYS of the date of this letter. (Do not use if not apolible) 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 (301 DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. K you cure the default within the THIRTY (301 DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's 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 POSS1113LE SHERIFF'S SALE DATE - it is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be hell would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you watt. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Nome Loans Servicing LP Addresso P. O. Box 660094 Dallas, TX 75266--ff94 Phone Number: 1-800-669-6854 Fax Number: 1-805.577-3432 Contact Person: MS PTX 36 AKention., Loan Counselor 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 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. 7113 8257 1472 7209 9029 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. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an Inspection are to (1) observe the physical condition of your property, (11) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before July 2, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 'A of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period d time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by July 2, 2008 as outlined above will result in the acceleration of your debt. Time Is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-6654. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Ungiestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commissia of Captlel Region 1514 Derry Street Harteburg, PA 17104 717.232.9757 Loveshlp, Inc. Marenatha PHFA 2320 North 5th Street 43 Philadelphia Avenue 211 North Front Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17110 717.232.2207 717.762.3285 717.780.3940 800.342.2397 w -? J 4 4 F`? fiJ ` .> x? {_J € i N N q x;p Ti? S? Eta -tl SHERIFF'S RETURN - REGULAR CASE NO: 2008-06282 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS KNECHT LINDA S VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KNECHT LINDA S the DEFENDANT at 0014:06 HOURS, on the 30th day of October , 2008 at 1480 TIMBER BROOK DRIVE MECHANICSBURG, PA 17050 by handing to LINDA S KNECHT DEFENDANT 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: Docketing Service Affidavit Surcharge i+11'716y `?- 18.00 12.00 .00 10.00 .00 40.00 Sworn and Subscibed to before me this day So Answers: ror e2.0000,- R. Thomas Kline 10/31/2008 GOLDBECK MCCAFFERTY & MCKEEVER By: r eputy Sherif of A. D. 0 In the Court of Common Pleas of Cumberland County COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. LINDA S. KNECHT (Mortgagor(s) and Record Owner(s)) 1480 Timber Brook Drive Mechanicsburg, PA 17050 No. 08-6282 Defendant(s) PRAECIPE FOR JUDGMENT 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 LINDA S. KNECHT by default for want of an Answer. Assess damages as follows: $96,781.06 Debt Interest from 01109/2009 to Date of Sale per diem at $15.00 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW "A4 -2 .2 Ov , , Judgment is entered in favor of COUNTRYWIDE HOM OANS I NC. an against LINDA S. KNECHT by default for want of an Answer and damages assessed in the sum of $96,781.06 as per the above certification. rothonota ry??/ S x,53 qJ r X?l Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. LINDA S. KNECHT (Mortgagors and Record Owner(s)) 1480 Timber Brook Drive Mechanicsburg, PA 17050 Defendant(s) No. 08-6282 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-captione atter n Bred against you. urt - Prothonotary By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 P P 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. That the above named Defendant, LINDA S. KNECHT, is about unknown years of age, that Defendant's last known residence is 1480 Timber Brook Drive Mechanicsburg, PA 17050, 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: l Q (? V(NV!1'1. NN3d AiNnwt 90:C Wd Z ! Nvr A& do 71754FC 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 20, 2008 TO: LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. LINDA S. KNECHT (Mortgagor(s) and Record Owner(s)) 1480 Timber Brook Drive Mechanicsburg, PA 17050 TO: LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-6282 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VINNRWNN d aNnon SO :C Wd Z I Hvr booz MViMt HiOldd 3HI d0 -i GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. LINDA S. KNECHT (Mortgagor(s) and Record owner(s)) 1480 Timber Brook Drive Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-6282 ORDER FOR JUDGMENT Please enter Judgment in favor of COUNTRYWIDE HOME LOANS INC., and against LINDA S. KNECHT 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 $96,781.06. Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are LINDA S. KNECHT, 1480 Timber Brook Drive Mechanicsburg, PA 17050; GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff 9 a .C Wd Z I NVt' 60OZ AWiONOH-l Odd 3U -40 - 14 TO THE PROTHONOTARY: ASSESSMENT OF DAMAGES Kindly assess the damages in this case to be as follows: Principal Balance Interest from 02/01/2008 through 01/08/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 2 X $115.33 $85,894.75 $5,145.00 $4,294.74 $315.91 $900.00 $230.66 $96,781.06 AND NOW, this 1,2 tb day of LL GOL BECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff , 2009 damages are assessed as above. o Prothy Y4 of PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. LINDA S. KNECHT Mortgagor(s) and Record Owner(s) 1480 Timber Brook Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6282 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 01/09/2009 to Date of Sale per diem at $15.00 (Costs to be added) $96,781.06 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff Al l A c ? r- a Ud ? ,., ? a o? sv O N ? '? «p A Sv ,"3 M O? M u,>v, N q , Qo ? A n? 4 i r3 A b o Oil ? t4 cr ? ? Cn y ? OQ ? ? Z t :oil b n >an ? d A O z z x ? o t7 '?-3 0 ? O o "a 0!0 00 O C7 ? O ? y O to A . ... ALL THAT CERTAIN Unit, being Unit No. 1480 of Timber Chase II, a Townhome Condominium located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, which Unit is designated in the Declaration of Condominium of Timber Chase II, a Townhome Condominium and Declaration Plats and Plans recorded in the Office of the Recorder of Deeds in Misc. Book 573, page 35 and right of way in Plan Book 11, page 139 respectively, together with any and all amendments thereto. PARCEL NO. 10-15-1283-011-U6 BEING KNOWN AS: 1480 Timber Brook Drive, Mechanicsburg, PA 17050 r- Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. LINDA S. KNECHT Mortgagor(s) and Record Owner(s) 1480 Timber Brook Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-6282 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Michael T. McKeever Attorney for plaintiff rw a m to ?_ ?,?y C .,,E SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 1480 Timber Brook Drive Mechanicsburg, PA 17050 SOLD as the property of LINDA S. KNECHT TAX PARCEL #10-15-1283-011 U6 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. LINDA S. KNECHT (Mortgagor(s) and Record Owner(s)) 1480 Timber Brook Drive Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-6282 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1480 Timber Brook Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: - 1P COUNTRYWIDE HOME LOANS INC. 4500 Park Granada Calabasas, CA 91302 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 1480 Timber Brook Drive Mechanicsburg, PA 17050 TIMBER CHASE CONDOMINIOM ASSOCIATION Timber Brook Drive Mechanicsburg, PA 17050 (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: January 8, 2009 GO BECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Y j ( b a^+? CIN 08-6282 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. LINDA S. KNECHT Mortgagor(s) and Record Owner(s) 1480 Timber Brook Drive Mechanicsburg, PA 17050 ACTION OF MORTGAGE FORECLOSURE Defendant(s' , Term No. 08-6282 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: KNECHT, LINDA S. LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 Your house at 1480 Timber Brook Drive, Mechanicsburg, PA 17050 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 $96,781.06 obtained by COUNTRYWIDE HOME LOANS INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 08-6282 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: htip://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 8 Irvine Row Carlisle, PA 17013 717-243-9400 i r 08-6282 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.phfa.oriz/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 homeretentionggoldbecklaw.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 7175417C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ??:, ? P a? ?_ ;., -- ?,;. ? ,? '? ?? ? ...? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-6282 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS INC Plaintiff (s) From LINDA S KNECHT 1480 TIMBER BROOK DRIVE, MECHANICSBURG, PA. 17050 (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 $96,781.06 L.L.$0.50 Interest FROM 1/09/2009 TO DATE OF SALE PER DIEM AT $15.00 Atty's Comm % Atty Paid $ 159.00 Plaintiff Paid Date: JANUARY 12, 2009 (Seal) Due Prothy $2.00 Other Costs A?id is R. L roth otary By: Deputy REQUESTING PARTY: Name Michael T. McKeever, Esq. Address: Goldbeck, McCafferty & McKeever Suite 5000-Mellon Independence Center, 701 Market Street, Philadelphia, Pa. 191( Attorney for: Plainitff Telephone: (215) 627-1322 Supreme Court ID No. 56129 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 71754FC CF: 10/22/2008 SD: 06/10/2009 $96,781.06 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. LINDA S. KNECHT Mortgagor(s) and Record Owner(s) 1480 Timber Brook Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-6282 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: 4C1 Personal Service by the Sheriffs OfficeMm1q% effr2 lIItt (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, BY: Michael T. McKeever, Esquire Attorney for Plaintiff 1 , s `aD - CP?o -r^ "Tye .e• QO `L ' , 0 ? r i 0 I L N Q Y () 9 d p? WC4 Uca?' QOp? 15 z Z QF=? I O°Q?r, V LU? ?~ I I 4S J ??` •+ N I O U 1 I zN I? V I =-' ?a .n i I ar ?u m ?r w 7D w ?I ? am ?o 15 n 1 ? ?? W i W a `I ! OaI:-TT i U 60 U, Uv° ?mOO a I 1 ? 1 r 3zz ?oLu I ?W mpW,JO ci IM ,I i , 1 L6 t I m O r N _ Q 11 7 Ul m a c O a C 0 c d ` n 1 ? m c i"3 O O p I a o .- I rQ tz m d7 i ? [n a U !5a pit N C o ° r o Np N r U W ? r= Y M U - 4 rte- Z_ N pl... -s 0. m g 8H C C4 C rS?o o p g N m SAL. rq o? N S3 ? (r a ? A E %YN' ?a ? o ?{ U N v 7aS, ? Z O °n r oG o? g Q y- U v a O ?yQ1 Obi m tl O OR. 54 Aq- t0 N C 15 v ? c U W e= '8 ? v c!i d 7 N tO?,? o cti rs p r Countrywide Home Loans, Inc. Vs Linda S. Knecht In the Court of Common Cumberland County, Pennsylvania Writ No. 2008-6282 Civil Term that on January 30, 2009 at 2035 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: Linda S. Knecht by making known unto her personally, at, 1480 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. -- w, EVER U511 April 4, 2009 at 0939 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 Linda S. Knecht, located at, 1480 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Linda S. Knecht, by regular mail to her last known address of 1480 Timber Brook Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of April 1, 2009 and never returned to the Sheriffs Office. So Answers, r039444e R. Thomas Kline, Shenf#` ."d 0'a'- ---PI "i. / Real Estate Coordinator GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff of Cumberland County CIVIL, ACTION - LAW vs. LH,TDA S. KNECHT Mortgagor(s) and Record Owner(s) 1480 Timber Brook Drive Mechanicsburg, PA 17050 ACTION OF MORTGAGE FORECLOSURE Defendant(s) Term No. 08-6282 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1480 Timber Brook Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: COUNTRYWIDE HOME LOANS - SECOND MORTGAGE DEPARTMENT 400 Countrywide Way MSV-35A Simi Valley, CA 93065 COUNTRYWIDE HOME LOANS INC. 4500 Park Granada Calabasas, CA 91302 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 1480 Timber Brook Drive Mechanicsburg, PA 17050 TIMBER CHASE II CONDOMINIUM ASSOCIATION 1300 Market Street P.O. Box 622 Lemoyne, PA 17043 TIMBER CHASE CONDOMINIOM ASSOCIATION Timber Brook Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 27, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 2EC,9 h tl -o f it 4 !U Countrywide Home Loans, Inc. Vs Linda S. Knecht In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-6282 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 30, 2009 at 2035 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: Linda S. Knecht by making known unto her personally, at, 1480 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 0939 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 Linda S. Knecht, located at, 1480 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the withinnan2d rv 0 defendant, to wit: Linda S. Knecht, by regular mail to her last known address of o - "' Timber Brook Drive, r Mechanicsburg PA 17055. This letter was mailed under th4*te ok?- April 1, 2009 and never returned to the Sheriffs Office. `` ?- y R. Thomas Kline, Sheriff, who being duly sworn according to law, stat ?`r °a hi i d STAYED i to t s wr t s returne . cW Sheriff s Costs: Docketing 30.00 k Poundage 13.66 Posting Bills 15.00 Advertising 15.00 Prothonotary 2.00 Milage 25.20 Levy 15.00 Surcharge 20.00 Law Journal 355.00 Patriot News 190.14 Share of Bills 15.43 696.43 ? G l6 9/" r R. Tho Kline, By . C Real Es ate Coordinator W ,? ab v3Y Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. LINDA S. KNECHT (Mortgagor(s) and Record Owner(s)) 1480 Timber Brook Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6282 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1480 Timber Brook Drive Mechanicsburg, PA 17050 I.Name and address of Owner(s) or Reputed Owner(s): LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: COUNTRYWIDE HOME LOANS INC. 4500 Park Granada Calabasas, CA 91302 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 1480 Timber Brook Drive Mechanicsburg, PA 17050 TIMBER CHASE CONDOMINIOM ASSOCIATION Timber Brook Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: January 8, 2009 GO BECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 08-6282 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. LINDA S. KNECHT Mortgagor(s) and Record Owner(s) 1480 Timber Brook Drive Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-6282 Defendants 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: KNECHT, LINDA S. LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 Your house at 1480 Timber Brook Drive, Mechanicsburg, PA 17050 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 $96,781.06 obtained by COUNTRYWIDE HOME LOANS INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 08-6282 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: htip://www.philadelphiafed.oriz/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 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-6282 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.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@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 71754FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. ALL THAT CERTAIN Unit, being Unit No. 1480 of Timber Chase II, a Townhome Condominium located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, which Unit is designated in the Declaration of Condominium of Timber Chase 11, a Townhome Condominium and Declaration Plats and Plans recorded in the Office of the Recorder of Deeds in Misc. Book 573, page 35 and right of way in Plan Book 11, page 139 respectively, together with any and all amendments thereto. PARCEL NO. 10-15-1283-011-U6 BEING KNOWN AS: 1480 Timber Brook Drive, Mechanicsburg, PA 17050 WRIT OF EXECUTION and/or ATTACHMENT COMMONWP-ALTH OF PENNSYLVANIA) N008-6282 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS INC Plaintiff (s) From LINDA S KNECHT 1480 TIMBER BROOK DRIVE, MECHANICSBURG, PA. 17050 (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 $96,781.06 L.L.$0.50 Interest FROM 1/09/2009 TO DATE OF SALE PER DIEM AT $15.00 Atty's Comm % Due Prothy $2.00 Atty Paid $ 159.00 Other Costs Plaintiff Paid Date: JANUARY 12, 2009 (Seal) 'A tk?4 4 urtis R. Lon rotho otary By: Deputy REQUESTING PARTY: Name Michael T. McKeever, Esq. Goldbeck, McCafferty & McKeever Suite 5000- Mellon Independence Center Address: 701 Market Street, Philadelphia Pa. 19106 Attorney for: Plaintiff Telephone: (215)627-1322 Supreme Court ID No. 56129 Real Estate Sale # 04 On January 15, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 1480 Timber Brook Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: January 15, 2009 By' ?Qe4c?Jc- d?^? Z 18 V S 1 NV 6001 l JAIU3H . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: 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. REAL ZSTATE BALE NO. 4 Writ No. 2008-6282 Civil Countrywide Home Loans, Inc. vs. Linda S. Knecht Atty.: Michael T. McKeever ALL THAT CERTAIN Unit, be- ing Unit No. 1480 of Timber Chase II, a Townhome Condominium lo- cated in the Township of Hampden, County of Cumberland and Com- monwealth of Pennsylvania, which Unit is designated in the Declaration of Condominium of Timber Chase II, a Townhome Condominium and Declaration Plats and Plans recorded in the Office of the Recorder of Deeds in Misc. Book 573, page 35 and right of way in Plan Book 11, page 139 respectively, together with any and all amendments thereto. U6PARCEL NO. 10-15-1283-011- . BEING KNOWN AS: 1480 Timber Brook Drive, Mechanicsburg, PA 17050. a _;i: ( 'I--- isa Marie Coyne, for SWORN TO AND SUBSCRIBED before me this day of May, 2009 '1"A d'dJ2 (fz Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 '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 The Patr1*otwXews 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: 04124/09 Real Estate Sale No. 04 05101109 Writ No. 2008-6282 Civil Term 05/08109 Countrywide Home Loans, Inc. VS Linda S. Knecht ~------ _ Attorney Michael T. Mckeever . , .?" f :' ............ . LEGAL DESCRIPTION t d subscribed before me this 12 day of May, 2009 A.D. Sworn ALL THAT CERTAIN unit, being; unit No. , 1480 of Timber Chase 11, a Townhome Condominium located in the Township of d Hampden, County of Cumberland an Commonwealth of Pennsylvania.. which Unit is Notary Public designated in the Declaration of Condominium of Timber Chase M a Townhome Condominium and Declaration Plats and Plans recorded in the COMMU EALTIJ OF PENNSYLVANIA' Office of the Recorder of Deeds in Misc. Book gelryt?,nzc`: Seal 573, page 35 and right of way in Plan Book 1 I. Sheffffie L Kish iValary public page 139 respectively, together with any and all L Dauphin ttln COU?Y City Of HanisUutCl, P amendments thereto. Commission F-xpires Nov. 26, 2011 PARCELNO , 10-15-1283-011-U6 BEING KNOWN AS: 1480 Timber Brook Member, Pennsylvania Association of Notaries Drive. Mechanicsburg. PA 17050 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Melton Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FILED- '?K`F !)F THIE -,, 2010 APR 23 P 3: 54 L_ -'AUNTY GUC,ti?,::.i-. ri ?u ?.??., PENNSI-VANIA COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 Defendant(s) PRAECIPE TO VACATE JUDQWNT TO THE PROTHONOTARY: No. 08-6282 Kindly vacate the judgment upon payment of your costs only. -M&aV ? MICHAEL T. MCKEEVER, ESQUIRE *8.oo PQ Art-/ C& Sa217a.t$ & ay / 08`1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY GOLDBECK McCAFFERTY & McKEL? VER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 ,HE p- 2010 APR 23 PM 3: 54 PE PvtiS'LMI A COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. LINDA S. KNECHT 1480 Timber Brook Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 08-6282 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. Michael T. McKeever, Esquire Attorney for Plaintiff