HomeMy WebLinkAbout08-6310
GOLIMECK 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
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
vs.
ROBERT C. LEWIS JR.
Mortgagors and Record Owners
26 South Enola Drive
Enola, PA 17025
Defendants
CIVIL ACTION: MORTGAGE
FO Finn I perm
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
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. t%- &3W CNl4-rerM'l
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
1)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.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.aVx.
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 73648FC.
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
Plaintiff is WACHOVIA MORTGAGE CORPORATION, PO Box 900001, 1100 Corporate Center
Drive Raleigh, NC 26707-5066.
2. The names and addresses of the Defendants are ROBERT C. LEWIS JR., 26 South Enola Drive, Enola,
PA 17025, who are the mortgagors and record owners of the mortgaged premises hereinafter described.
On August 23, 2007 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR
WACHOVIA MORTGAGE CORPORATION, which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County as Instrument #200734096. The mortgage has been assigned
to: WACHOVIA MORTGAGE CORPORATION 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 July 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 ....................................................................................$86,062.79
Interest from 06/01/2008 through 10/31/2008 at 8.0000% ...................... $2,926.88
Per Diem interest rate at $19.13
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$4,303.14
Late Charges from 07/01/2008 to 10/31/2008 ............................................. $158.84
Monthly late charge amount at $31.77
Costs of suit and Title Search ...................................................................... $900.00
Inspection Fees ................................................................................................$8.75
Escrow ......................................................................................................... $111.12
Monthly Escrow amount $151.64
$94,471.52
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
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $94,471.52,
together with interest at the rate of $19.13, 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:
GOLDBEJ5 M"FFER'Y & McKEEVER
BY: MICR L T. KEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
Michael T. McKeever, Esquire, hereby states that he is
attorney for PLAINTIFF in this matter, that Plaintiff is outside
the jurisdiction of the Court and/or the Verification could not be
obtained within the time allowed for the filing of the pleading
that he is authorized to make this verification pursuant to
Pa.R.C.P 1024(c) and that the statements made in the foregoing
pleading in the Civil Action in Mortgage Foreclosure are based
upon the information supplied by Plaintiff and are true and
correct to the best of his knowledge, information and belief.
Furthermore, it is the undersigned's intention to substitute a
verification from Plaintiff as soon as it is received by counsel.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to
unsworn falsification to authorities.
Bate : 4?,3 0
iii el T. McKeever, Esquire
P I.D. #56129
E.YthibitA
FMIBIT "All
ALL THAT CERTAIN piece or lot of land with the improvements thereon
erected situate in East Pennsboro Township, Cumberland County,
Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the Eastern side of Enola Drive, formerly
known as Brick Church Road, at the line of lands now or formerly of
Lemuel R. Spong; thence Eastward along said last mentioned lands, one
hundred twenty-five (125) feet to a point; thence Northward twenty-
five (25) feet, more or less, to a point on the line running through
the center of the partition wall of the double house erected upon the
lot herein conveyed and the lot adjoining on the North; thence
Westward along said line and along line of property now or formerly
of Paul E. Strickner, one hundred twenty-five (125) feet, more or
less, to a point on the Eastern side of said public road; thence
Southward along said public Road, twenty-five (25) feet, more or less
to a point, the place of BEGINNING.
BEING THE SAME PREMISES which Paul E. Boyer and Catherine L. Boyer,
husband and wife, by Deed bearing date the 3rd day of May, 2007, and
recorded on 15th day of May, 2007 in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, in Record Book 279,
Page 4941, granted and conveyed unto Beneficial Consumer Discount
Company d/b/a Beneficial Mortgage Company of Pennsylvania.
UNDER AND SUBJECT TO restrictions and conditions as now appear of
record.
TAX MAP 09-15-1291-053
E.)Chibit B
Wachovia Mortgage, FS8
Post Office Box 900001 1100 Corporate Center Drive
Raleigh, North Carolina 27675-9000 Raleigh, North Carolina 27607-5066
WACHOVIA
ROBERT C LEWIS JR
26 ENOLA DR S
ENOLA, PA 17025-2704
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
September 3, 2008
This official notice that the mortgage on your home is in default and the lender intends to foreclose
SMific information about the nature of the default is provided in the attached Rages.
The HOMEOWNER S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to he1R to save
your home This Notice explains how the program works.
To see if HEMAP can hem you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet the
Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving your County are
listed at the end of this Notice If you have my auestions,,Y-w Ma call the Pennsylvania Housing Finance
Agency toll five at 1 800-342-2397. (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Mortgagor ROBERT C LEWIS JR
Co-mortgagor
Property Address 26 SOUTH ENOLA DRIVE
ENOLA, PA 17025
Loan Number 000674 3761
Original Lender
Current Lender/Servicer Wachovia Mortgage, FSB
HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE ACT ), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED HOW TO CURE YOUR
MORTGAGE DEFAULT EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender may NOT take action against you for thirty
(30) days after the date of this meeting The names addresses and telephone numbers of des:gpa ted
consumer credit counseling agencies for the county in which the propM 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 a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner s Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner s Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO
NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE
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: 26 SOUTH ENOLA DRIVE, ENOLA, PA 17025 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: Start/End: 07/01/2008 through 09/01/2008 at $787.10 per month.
Total Amount of Delinquent Payments Due $ 2,361.30
Late Charges 63.54
Property inspections and NSF check charges, if any 0.00
Recoverable Corporate Advances 0.00
Other charges accrued, if any 0.00
LESS: Suspense (unapplied funds) - 0.00
LESS: Previously Posted - 0
TOTAL AMOUNT OF DELINQUENCY $ 2,424.84
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not gpplicable): N/A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $
2,424.84, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier s check, certified
check or money order made payable and sent to: Wachovia Mortgage, FSB, Attention: Payment
Processing, 1100 Corporate Center Drive, Raleigh, NC 27607-5066.
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 The means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure upon your mortgage property.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage 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 attorneys fees actually incurred by the lender even if they exceed $50.00.
Any attorney s fees will be added to the amount you owe the lender, which may also include other
reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to
kay attorney s fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF S SALE-If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the rit to
cure the default and Qrevent the sale at any time igp to one hour before the Sheriff s Sale You may do so
by paving 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 mortQag?Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF S SALE DATE-It is estimated that the earliest date that such a Sheriff s
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheriff s 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:
Wachovia Mortgage, FSB
Attention: Servicing Operations
1100 Corporate Center Drive
Raleigh, NC 27607-5066
Phone: (800) 688-9224
Fax: 866/260-3962
Contact: Steve Kennedy
EFFECT OF SHERIFF S SALE-You should realize that a Sheriff s 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 Sheriff s
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE -You may or may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney s fees and cost are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
Sent by Regular Mail, Certificate of Mailing (PS Form 3877), and Certified Mail
Sincerely,
s&m zmae4
Steve Kennedy
Servicing Operations
Wachovia Mortgage, FSB
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GOLDBECK McCAFFERTY & McKEEVER
Professional Corporation
By: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6303
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
VS.
ROBERT C. LEWIS JR.
Mortgagor(s) and Record Owner(s)
26 South Enola Drive
Enola, PA 17025
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
Term
No. 08-6310
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification to Plaintiff's Complaint filed on October 24,
2008 in the above captioned matter.
GOLDBECK McCAFFERTY & McKEEVER
BY:
Michael T. McKeever
Attorney for Plaintiff
J
GOLDBECK McCAFFERTY & McKEEVER
Professional Corporation
By: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6303
ATTORNEY FOR PLAINTIFF
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
vs.
ROBERT C. LEWIS JR.
Mortgagor(s) and Record Owner(s)
26 South Enola Drive
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
Term
No. 08-6310
CERTIFICATION OF SERVICE
I certify that a true and correct copy of Plaintiffs Praecipe to Substitute Verification to
Plaintiffs Complaint was served on Defendant(s) via first class mail on December 5, 2008 as
follows:
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
GOLDBECK McCAFFERTY & McKEEVER
Ml hael T. McKeever
Attorney for Plaintiff
VERIFICATION
I, 6 weI' 01 ki ? ?'?f'f n , as the representative of the Plaintiff corporation
within named do hereby verify that I am authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the
best of my knowledge, information and belief. I understand that false statements therein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities.
Date: 27 2Gp8
CHOVIA ORTGAGE CORPORATION
#73648FC - ROBERT C. LEWIS JR.
26 South Enola Drive Enola, PA 17025
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06310 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WACHOVIA MORTGAGE CORPORATION
VS
LEWIS ROBERT C JR
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
LEWIS ROBERT C JR the
DEFENDANT , at 0019:00 HOURS, on the 29th day of October , 2008
at 26 SOUTH ENOLA DRIVE
ENOLA, PA 17025
SHARON LEWIS
by handing to
ADULT SISTER OF 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 18.00
Service 15.00
Affidavit .00
Surcharge 10.00
00
43.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
.i?? ?Qe? le?z-
R. Thomas Kline
10/30/2008
GOLDBECK MCCAFFERTY MCYrAE VER
By:
eputy Sherif
A. D.
In the Court of Common Pleas of Cumberland County
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
vs.
ROBERT C. LEWIS JR.
(Mortgagor(s) and Record Owner(s))
26 South Enola Drive
Enola, PA 17025
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 08-6310
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 ROBERT C. LEWIS JR. by default for want of an Answer.
Assess damages as follows:
Debt
Interest from 01/17/2009 to
Date of Sale per diem at $19.13
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM
I certify that written notice of the intention to file this praecipe was mailed or delivered to the
is to be entered and to his attorney of record, if any, after the default occurred and at least ten
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 /
Michael T. I
Attorney for
I.D. #56129
$96,494.76
'ALLEGED TO
ist wWm judgment
to We date of the
AND NOW , 071 _ o74w1' , Judgment is entered in favor of
WACHOVIA MORTGA CORPORATION and against ROBERT C. LEW JR. by default for want of an Answer and
damages assessed in the sum of $96,494.76 as per the above certification.
Pr onotary
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Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
No. 08-6310
vs.
ROBERT C. LEWIS JR.
(Mortgagors and Record Owner(s))
26 South Enola Drive
Enola, PA 17025
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothon ry
By:
If you have any questions concerning the above, please contact:
Michael T. McKeever
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
73648FC
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: December 1, 2008
TO:
ROBERT C. LEWIS JR-
26 South Enola Drive
Enola, PA 17025
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
vs.
R BER'I?C.
(Mortgagor(s) and Record Owner(s))
26 South Enola Drive
Enola, PA 17025
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Term
No. 08-6310
Defendant(s)
TO: ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
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
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
Carlisk, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Michael T. McKeever
GOLDBECK MCCAFFIERTY & MCKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
Plaintiff
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, ROBERT C. LEWIS JR., is about unknown
years of age, that Defendant's last known residence is 26 Sou En a Drive Enola, PA 17025, and
is engaged in the unknown business located at unknown
2. That Defendant is not in the Military Na 1 S rvice of the United States or its
Allies, or otherwise within the provisions of the of ers' d Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
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, ROBERT C. LEWISA),, is about unknown
years of age, that Defendant's last known residence is 26 South Enola riv Enola, PA 17025, and
is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Nav Se ice of the United States or its
Allies, or otherwise within the provisions of the Soldie/ a/Sa' s' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
vs.
ROBERT C. LEWIS JR.
(Mortgagor(s) and Record owner(s))
26 South Enola Drive
Enola, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-6310
ORDER FOR JUDGMENT
Please enter Judgment in favor of WACHOVIA MORTGAGE CORPORA C
C. LEWIS JR. for failure to file an Answer in the above action within (20) days (or i
the United States of America) from the date of service of the Complaint, in the su #(/f s
Michael T. Mc
Attorney for PI
?, and inst ROBERT
(60) ays if defendant is
6 4.76.
I hereby certify that the above names are correct and that the recise residence ad
creditor is WACHOVIA MORTGAGE CORPORATION PO Box 0001 1100 Corporat
NC 26707-5066 and that the name(s) and last known address(es) A the Defendant(s) is?
JR., 26 South Enola Drive Enola, PA 17025;
GOLDBECK I
BY: Michael T
Attorney for X
the judgment
ve Raleigh,
T C. LEWIS
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $86,062.79
Interest from 06/01/2008 through $4,399.89
01/16/2009
Reasonable Attorney's Fee $4,303.14
Late Charges $254.15
Costs of Suit and Title Search $900.00
Escrow Payments Due 3 X $151.64 $454.92
Inspection Fees $8.75
Escrow $111.12
$96,494.76
GOLDBECK McCAF Y &
BY: Michael T. Mc ever
Attor/are f
AND NOW, this f day of 2009 damn es sed as above.
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE. FORECLOSURE)
P.R.C.P 3180-3183
Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
vs.
ROBERT C. LEWIS JR.
Mortgagor(s) and Record Owner(s)
26 South Enola Drive
Enola, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-6310
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
01/17/2009 to Date of
Sale per diem at
$19.13
(Costs to be added)
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ALL THAT CERTAIN piece or lot of land with the improvements thereon erected situate
in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described
as follows, to wit:
BEGINNING at a point on the Eastern side of Enola Drive, formerly known as Brick
Church Road, at the line of lands now or formerly of Lemuel R. Spong; thence Eastward
along said last mentioned lands, one hundred twenty-five (125) feet to a point; thence
Northward twenty-five (25) feet, more or less, to a point on the line running thorough the
center of the partition wall of the double house erected upon the lot herein conveyed and
the lot adjoining on the North; thence Westward along said line and along line of
property now or formerly of Paul E. Strickener, one hundred twenty-five (125) feet, more
or less, to a point on the Eastern side of said public road; thence Southward along said
public Road, twenty-five (25) feet, more or less to a point, the place of BEGINNING.
BEING THE SAME PREMISES which Paul E. Boyer and Catherine L. Boyer, husband
and wife, by Deed bearing date the 3'd day of May, 2007, and recorded on 151h day of
May, 2007 in the Office of the Recorder of Deeds in and for Cumberland County,
Pennsylvania, in Record Book 279, Page 4941, granted and conveyed unto Beneficial
Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania.
UNDER AND SUBJECT to restriction and conditions as now appear of record.
BEING KNOWN AS 26 SOUTH ENOLA DRIVE, ENOLA PA 17025
TAX MAP 09-15-1291-053
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-6310 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Wachovia Mortgage Corporation P O Box 900001 1100
Corporate Center Drive Raleigh, NC 26707-5066
Plaintiff (s)
From Robert C. Lewis Jr.
(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 $96,494.76
L.L. $.50
Interest from 01/17/2009 to date of sale per diem at $19.13
Atty's Comm % Due Prothy $2.00
Atty Paid $162.00
Other Costs
Plaintiff Paid
Date: January 21, 2009
(Seal)
tis R. Lon onot y
By:
REQUESTING PARTY:
Name Michael T. McKeever, Esq.
Goldbeck McCafferty & McKeever
Address: Suite 5000 - Mellon Independence Center
701 Market St.
Philadelphia, PA 19106
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court ID No. 56129
Deputy
G(tdbeck 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
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ROBERT C. LEWIS JR.
(Mortgagor(s) and Record Owner(s))
26 South Enola Drive
Enola, PA 17025
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 08-6310
AFFIDAVIT PURSUANT TO RULE 3129
WACHOVIA MORTGAGE CORPORATION, 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:
26 South Enola Drive
Enola, PA 17025
I .Name and address of Owner(s) or Reputed Owner(s):
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
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:
W,
I
BENEFICIAL CONSUMER DISCOUNT COMPANY
P.O. Box 9068
Brandon, FL 33509
BENEFICIAL CONSUMER DISCOUNT COMPANY
961 Weigel Drive
Elmhurst, IL 60126
BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
419 Village Drive, Suite 2
Carlisle, PA 17013
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
26 South Enola Drive
Enola, PA 17025
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to thee be of my rsonal knowledge or
information and belief. I understand that false statements herein are made subject to t e penal 'es of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: January 16, 2009
GOLDBECKT
BY: Michael T
Attorney for
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08-6310
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
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
ROBERT C. LEWIS JR.
Mortgagor(s) and Record Owner(s)
26 South Enola Drive
Enola, PA 17025
Defendant(s,'
Term
No. 08-6310
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: LEWIS 1R., ROBERT C.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
Your house at 26 South Enola Drive, Enola, PA 17025 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 $96,494.76 obtained by WACHOVIA MORTGAGE CORPORATION 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 WACHOVIA MORTGAGE CORPORATION, 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.
ACTION OF MORTGAGE
FORECLOSURE
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
' 08-6310
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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
08-6310
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www. hfa.orp-/consumers/homeowners/real qVx.
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 7364817C.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
CZ -wry
et" W
Co
Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
vs.
ROBERT C. LEWIS JR.
Mortgagor(s) and Record Owner(s)
26 South Enola Drive
Enola, PA 17025
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO.08-6310
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record
I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has coral
Act. i
Plai iff in this action, and
t VII the provisions of the
Michael T.1\
Attorney for
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SHORT DESCRIPTION
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 26 South Enola Drive
Enola, PA 17025
SOLD as the property of ROBERT C. LEWIS JR.
TAX PARCEL #09-15-1291-053
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ALL THAT CERTAIN piece or lot of land with the improvements thereon erected situate
in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described
as follows, to wit:
BEGINNING at a point on the Eastern side of Enola Drive, fonnerly known as Brick
Church Road, at the line of lands now or formerly of Lemuel R. Spong; thence Eastward
along said last mentioned lands, one hundred twenty-five (125) feet to a point; thence
Northward twenty-five (25) feet, more or less, to a point on the line running thorough the
center of the partition wall of the double house erected upon the lot herein conveyed and
the lot adjoining on the North; thence Westward along said line and along line of
property now or formerly of Paul E. Strickener, one hundred twenty-five (125) feet, more
or less, to a point on the Eastern side of said public road; thence Southward along said
public Road, twenty-five (25) feet, more or less to a point, the place of BEGINNING.
BEING THE SAME PREMISES which Paul E. Boyer and Catherine L. Boyer, husband
and wife, by Deed bearing date the 3`d day of May, 2007, and recorded on 15`h day of
May, 2007 in the Office of the Recorder of Deeds in and for Cumberland County,
Pennsylvania, in Record Book 279, Page 4941, granted and conveyed unto Beneficial
Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania.
UNDER AND SUBJECT to restriction and conditions as now appear of record.
BEING KNOWN AS 26 SOUTH ENOLA DRIVE, ENOLA PA 17025
TAX MAP 09-15-1291-053
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GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Courtenay R. Dunn, Esq.
Attorney I.D. #206779
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
VS.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
No. 08-6310
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.
MOTION FOR SUBSTITUTED SERVICE
UNDER PA.R.C.P. 430(a)
Plaintiff, by and through its attorney, in support of its Motion for Substituted Service,
represents as follows:
Plaintiff is the holder of a first mortgage upon the premises 26 South Enola Drive, Enola,
PA, 17025, hereinafter, the "mortgaged premises".
2. Defendant, ROBERT C. LEWIS JR., is the mortgagor and real owner of the mortgaged
premmses.
3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, David
Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify
that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion,
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
it was not possible to locate or contact the Defendant to request his concurrence.
4. The last known address of Defendant, Robert C. Lewis Jr., is as set forth in Paragraph 2
of the Complaint.
The Sheriff has been unable to effect service of the Notice of Sale upon Defendant,
Robert C. Lewis Jr., at the property address, 26 South Enola Drive, Enola, PA, 17025, after numerous
attempts. The Sheriff was unable to locate the Defendant.
The following investigation was conducted in a good faith attempt to ascertain the
whereabouts of Defendant, Robert C. Lewis Jr.
WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff
to serve the Notice of Sale upon Defendant, Robert C. Lewis Jr., by posting the premises and certified and
regular mail to the Defendant's last known address.
Respectfully submitted,
zAr
David B. Fein, Esq.
Courtenay R. Dunn, Esq.
ProVest, LLC
Affidavit of Good Faith Investigation
Client provided information:
File Number: 73648FC
Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER
Subject Name: Robert C. Lewis Jr
Property Address:
Street: 26 South Enola Drive
City: Enola State: PA Zip 17025
Skip Results: Date of Birth: None Found ProVest File Number: 1631440
Last Known Dates: As of 5/7/2009
Street: 26 South Enola Drive Phone:
City: Enola State: PA Zip: 17025
Death Records: As of 5/7/2009, the Social Security Administration has no death record on file for Robert C.
Lewis Jr.
Social Security Number Search Completed.
Employment Search: Unable to verify current employer.
Creditor Information: Creditors indicated the last reported address for Robert C. Lewis Jr as 26 South Enola Drive,
Enola, PA 17025.
Department of Motor The Pennsylvania Department of Motor Vehicles provided no change for Robert C. Lewis Jr
Vehicle Records: from 26 South Enola Drive, Enola, PA 17025.
Public Licenses (Pilot, Search performed provided no information.
Real Estate, etc):
Voter Registration The County Voters Registration Office has no listing for Robert C. Lewis Jr.
Information:
National Postal Has no change for Robert C. Lewis Jr from 26 South Enola Drive, Enola, PA 17025.
Address Search:
Military Search: There was no active military status found
Comments:
717-232-7361: Called possible relative, Mary Lewis, left message on answering machine, no response.
717-732-4169: Called possible neighbor, Richard Poff, answering machine answered, no message left.
717-732-9201: Called possible neighbor, Michael Murray, answering machine answered, no message left.
On 5/7/2009, I, Tonya Hardin being duly sworn according to the law, deposes and says: I am employed by ProVest,
LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my
investigation.
Affiant Namtt`. a Hard
ubscr?bed A q0 5w,-tri to Ore Me.
Nr kXY -?ut.)'x.:
Date: 5/7/2009
LIIF
MY COMMMIM81 I EWK
I+ip"Mb6r2Q, 2tMt
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-6310 Civil Term
Wachovia Mortgage Corporation
Vs
Robert C. Lewis, Jr.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made a diligent search and inquiry
for the within named defendant to wit: Robert C. Lewis, but was unable to locate them in his
bailiwick. He therefore
returns the writ NOT FOUND, according to law.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that
on April 4, 2009 at 1118 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 Robert C. Lewis,
Jr., located at, 26 South Enola Drive, Enola, Cumberland County Pennsylvania, according to
law.
So-Answers _
R. Thomas Kline, Sheriff
B
Y
Real Estate Coordinator
GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Courtenay R. Dunn, Esq.
Attorney I.D. #206779
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
vs.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
VERIFICATION
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
No. 08-6310
1, IV V I ? 1 ' HAD , Attorney for Petitioner do hereby verify that the facts set
forth in the foregoing Motion for Substituted Service 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.
BY: David B. ein, Esq.
Courtenay R. Dunn, Esq.
GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Courtenay R. Dunn, Esq.
Attorney I.D. #206779
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066"
vs.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
No. 08-6310
MEMORANDUM OF LAW IN SUPPORT OF MOTION
FOR SUBSTITUTED SERVICE UNDER Pa R C P 430(a)
Plaintiff has filed a Notice of Sheriff's Sale against Defendant, Robert C. Lewis Jr.,
which the Sheriff has been unable to personally serve upon Defendant, Robert C. Lewis Jr. As noted in
the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts
without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a).
CONCLUSION
For reasons stated above and in the attached Motion, the Court should enter an order
allowing Plaintiff to serve the Notice of Sheriff's Sale upon Defendant, Robert C. Lewis Jr., by posting
the premises and certified mail and regular mail to the Defendant's last known address.
Respectfully submitted,
IA"PE--
David B. Fein, Esq.
Courtenay R. Dunn, Esq.
GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Courtenay R. Dunn, Esq.
Attorney I.D. #206779
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
vs.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
CERTIFICATE OF SERVICE
Of Cumberland County
No. 08-6310
N.vid bFbn does hereby certify that true and correct copies of the
foregoing Motion for Substituted Service have been served upon the Defendant, Robert C. Lewis Jr., this U "
day of n?O /fir , 2009, by first class mail, postage prepaid.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
BY: David B. Fein, Esq.
Courtenay R. Dunn, Esq.
IN THE COURT OF COMMON PLEAS
RLED- FFICE
OF THE PP,')If,-'r',}O;ARY
2009 MAY I I AM 11: Q Q
r'
MAY 12'20096
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
vs.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
ORDER
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
08-6310
AND NOW, this I Z-_ day of 2009, upon consideration of the Plaintiffs
Motion for Substituted Service under Pa.R.C.P. 430(a) a d it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant, Robert C. Lewis Jr., has been
unsuccessful, it is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of
Sheriff's Sale upon Defendant, Robert C. Lewis Jr., by posting a copy of the Notice upon the premises 26
South Enola Drive, Enola, PA, 17025, and Plaintiff is directed to serve the Notice of Sheriff Sale by
certified and regular mail to the {defendant's last known address at 26 South Enola Drive, E la, PA,
0,400- -40 (% i+3A -1W V-PV- M ('W-9- .t?+ `bk4 CC4 (4-/?6w, ?,
17025, and that all farther service of legal papers, including but not limited to motions, petitions and rules
be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale
pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Robert C. Lewis
Jr., by sending copies of same to Defendant's last known address by certified and r 1 it and by
posting the premises. BY
J. L v v.
Distribution list:
chael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 7 Market Street,
Philadelphia, PA 19106-1532
ROBERT C. LEWIS JR., 26 South Enola Drive Enola, PA 17025
Corl enla E Ll?-L
LLJ C ' ?
3
»
L?t CL
LJ
? w
by V
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
73648FC
CF: 10/24/2008
SD: 06/10/2009
$96,494.76
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
VS.
ROBERT C. LEWIS JR.
Mortgagor(s) and
Record Owner(s)
26 South Enola Drive
Enola, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 08-6310
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:
( ) Personal Service by the Sheriffs Office/competent adult (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?R-44fine/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,
J -- T
BY: Michael T. McKeever, Esquire
Attorney for Plaintiff
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WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
vs:
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
08-6310
ORDER
(Tr
AND NOW, this 17- day of t4, 2009, upon consideration of the Plaintiffs
Motion for Substituted Service under Pa.R.C.P. 430(a) a d it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant, Robert C. Lewis Jr., has been
unsuccessful, it is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of
Sheriff's Sale upon Defendant, Robert C. Lewis Jr., by posting a copy of the Notice upon the premises 26
South Enola Drive, Enola, PA, 17025, and Plaintiff is directed to serve the Notice of Sheriff Sale by
certified and regular mail to the efendant's last known address at 26 S?ou?tth?Enola Drive, E laa, PA,
17025'and that all huther s (!t -x
ervice of legal papers, including but not limited to motions, petitions and rules
be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale
pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Robert C. Lewis
Jr., by sending copies of same to Defendant's last known address by certified and
posting the premises.
J •
Distribution list: j/ V
Michael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center,
Philadelphia, PA 19106-1532
ROBERT C. LEWIS JR., 26 South Enola Drive Enola, PA 17025 '
r?,?
Form 3877
Domestic USPS Firm Mailing Book
------------------
Name and Address of Sender: Permit Number
Sequence Number
JOSEPH A GOLDBECK JR 1989A
MELLON INDEPENDENCE CENT
701 MARKET ST STE 5000 Ascent - MAC v7.50.7.70.J
PHILADELPHIA, PA 19106
- ------------------------------
Piece ID Article N Delivery Address SS Fee Postage Value Sender Charges
Addressee Name Type Insur./Register Due Total
73648RL6-10 71114342363000602151 LEWIS JR., ROBERT C. C 2.80 0.44 4.34
26 South Enola Drive ERR 1.10
\? Enola, PA 17025 /
77821LS6-24 71114342363000602168 STORM, LAWRENCE C 2.80 0.44
315 Fusilier Circle a/k/a/ Cour ERR 1.10
Fort Washington, PA 19034
4.34
65927RP6-24 71114342363000602175 POUNCY, ROBERT L. C 2.80 0.44 4.34
308 Ruscombe Avenue ERR 1.10
Glenside, PA 19038
65927LP6-24 71114342363000602182 POUNCY, LULA B. a/k/a LULA MAE C 2.80 0.44 4.34
308 Ruscombe Avenue ERR 1.10
Glenside, PA 19038
63284JS6-24 71114342363000602199 SKABLA JR. A/K/A JOSEPH L. SKAB C 2.80 0.44 4.34
122 Old Soldiers Road ERR 1.10
Cheltenham, PA 19012
63284JS6-24.0171114342363000602205 SKABLA JR. A/K/A JOSEPH L. SKAB C 2.80 0.44 4.34
3855 Blair Mill Road, Apt. 2228 ERR 1.10
Horhsam, PA 19044
--------------------------------------------------------------------------------
Page Totals: 6 23.40 2.64 26.04
Cumulative Totals: 6 23.40 2.64 26.04
----------------------------------------- ---`-----
USP ?ER FICATION
Total Nu r of Pieces Received: ?Y -
J -
Round Stamp:
Signatur of Receivi Employee
Form 3877 (Facsimile) D e of Manifest: 05/19/2009
Page 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
AFFIDAVIT OF SERVICE
WACHOVIA MORTGAGE CORP., ROBERT C. LEWIS, JR.
Plaintiff (Petitioner) VS. Defendant (Respondent)
CASE and/or DOCKET: 08-6310
SHERIFF'S SALE DATE: 6/10/09
I, va4 ,declare that I am a Pennsylvania State Constable and/or Process Server, in and for the County of
B at I am not a party to this action, not an employee of a party to this action, or an attorney to the action, and that within the
boundaries of the state were service was effected. I was authorized by law to perform the said service.
SERVICE UPON: ROBERT C. LEWIS, JR.
ADDRESS: 26 SOUTH ENOLA DRIVE, ENOLA PA IMS
On: 15I1 11499 At: 11 tow" • i
Description: Approximate Age _ Height _ Weight - Race _ Sex _ Hair _
With Documents: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
Manner of Service
By handing to:
? DEFENDANT(S) PERSONALLY SERVED
? ADULT FAMILY MEMBER WITH WHOM THE SAID DEFENDANT(S) RESIDE.
? NAME. RELATIONSHIP:
? ADULT IN CHARGE OF DEFENDANTS RESIDENCE.
? NAME: RELATIONSHIP:
POSTED PROPERTY
? AGENT OR PERSON IN CHARGE OF PLACE OF BUSINESS.
? NAME: TITLE:
? MILITARY STATUS: NO / YES BRANCH:
COMMENTS:
DEFENDANT WAS NOT SERVED BECAUSE:
- MOVED -UNKNOWN NO ANSWER-VACANT OTHER
SERVICE WAS ATTEMPTED ON THE FOLLOWING DATES/TIMES:
1.) 2.) 3.)
SWORN TO AND SUB CIBED
BEFO E THIS DAY OF
.2009
NOTARY
]a jA 7_X a
CON T E/PROCESS SERVER
73648FC
CTMMONWEALTH OF Pzh'-NSYLVANIA
NOTAR;A SEAL
I TERESA A. Iu INZOn;awlemao1180, 93 EAST MAIN STRMr- BAY SHORE, NY 11706631.6N.6163631.666.6295(F)
Washington Twp., Berks County
Commission Expkes December 5 2009
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,
May 29, 2009
AfEant 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.
a Marie Coyne 'tor
SWORN TO AND SUBSCRIBED before me this
29 day of May, 2009
1 -Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COMW
My COMMINon Expires Apr 28, 201 O
CUMBERLAND LAW JOURNAL
ACTION OF MORTGAGE
FORECLOSURE
in the Court of Common Pleas of
Cumberland County
Civil Action-Law
No. 08-6310
WACHOVIA MORTGAGE
CORPORATION, P.O. Bohr 900001,
1100 Corporate Center Drive,
Raleigh, NC 26707-5066,
plaintiff
VS.
ROBERT C. LEWIS JR.,
Mortgagor(s) and Record Owner(s),
26 South Enola Drive,
Enola, PA 17025,
De fendant(s)
THIS LAW FIRM IS A DEBT COL-
LECTOR AND WE ARE ATTEMPTING
TO COLLECTA DEBT. THIS NOTICE
IS SENTTO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMA-
TION OBTAINED FROM YOU WILL
BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF
REAL PROPERTY
TO: ROBERT C. LEWIS JR., Defen-
dant, whose last known address
is 26 South Enola Drive, Enola,
PA 17025.
Your house at 26 South Enola
]hive, Enola, PA 17025, is aeheduled
to be sold at Sherift Sale on Wednes-
day, June 10, 2009, at 10:00 A.M.,
In Commisaianers Hearing Rm., 2nd
FL Courthouse to enforce the court
judgment of $96,494.76 obtained by
WACHOVIA MORTGAGE CORPORA-
TION against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT
THIS SHERIFF'S SALE. To prevent
this Sheriff's Sale you must take
immediate action: 1. The We will be
cancelled U you pay to WACHOVIA
MORTGAGE CORPORATION, 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 im-
properly 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
PROPER'T'Y AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S
SALE DOES NOT TAKE PLACE. 1. If
the SheriB'e 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 at (717)
240-6390.2. You maybe able to peti-
tion the Court to set aside the sale if
the bid price was grossly inadequate
compared to the value of your prop-
erty. 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 at (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. S. You have a
right to remain in the property until
the RM 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 Sheriff e
CUMBERLAND LAW JOURNAL
Sale. This schedule will state who will
be receiving that money. The money
will be paid out in accordance with
this schedule unless exceptions (rea-
sons why the proposed distribution
is wrong) are filed with the Sheriff
within ten (10) days after the sched-
ule 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
32 S. Bedford St.
Carlisle, PA 17013
(7I7) 249-3166
LEGAL SERVICES INC.
401 E. Louther St.
Ste. 103
Carlisle, PA 19013
(717) 243-9400
MICHAEL T. McKEEVER,
ESQUIRE
GOLDBECK, McCAFFERTY &
MCKEEVER, P.C.
Attys. for Plaintiff
suite 5000
Mellon Independence Center
701 Market St.
Philadelphia, PA 19106
(215) 825-6318
May 29
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1100 Corporate Center Drive
Raleigh, NC 26707-5066
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
ROBERT C. LEWIS JR.
Mortgagor(s) and Record Owner(s)
26 South Enola Drive
Enola, PA 17025
Defendant(s)
ACTION OF MORTGAGE FORECLOSURE
Term
No. 08-6310
AFFIDAVIT PURSUANT TO RULE 3129
WACHOVIA MORTGAGE CORPORATION, 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:
26 South Enola Drive
Enola, PA 17025
1.Name and address of Owner(s) or Reputed Owner(s):
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
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:
BENEFICIAL CONSUMER DISCOUNT COMPANY
P.O. Box 9068
Brandon, FL 33509
BENEFICIAL CONSUMER DISCOUNT COMPANY
961 Weigel Drive
Elmhurst, IL 60126
BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL
MORTGAGE COMPANY OF PENNSYLVANIA
419 Village Drive, Suite 2
Carlisle, PA 17013
5. Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale.
TENANTS/OCCUPANTS
26 South Enola Drive
Enola, PA 17025
(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: June 5, 2009
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
CAF THE vp
Y
2009 JUN -9 pm 1: 52
ft A
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which WACHOVIA MTG CORP is the grantee the same having been sold to said
grantee on the 2ND day of SEPT A.D., 2009, under and by virtue of a writ Execution issued on the 21
dajy of JAN, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2008
Number 6310, at the suit of WACHOVIA MTG CORP against ROBERT C LEWIS JR is duly recorded
as Instrument Number 200933427.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this (-2 day of
A.D. oC
n
Recorder of Deeds
MJCU a r u r,Wnuai;and County. Cadsk, PA
my Corot e EVwa$ ft tW try d tjK *10
f" 1
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-6310 Civil Term
Wachovia Mortgage Corporation
Vs
Robert C. Lewis, Jr.
Fit rr -4"
r, "E • n
v
y riJ
if .
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made a diligent search and inquiry
for the within named defendant to wit: Robert C. Lewis, but was unable to locate them in his
bailiwick. He therefore
returns the writ NOT FOUND, according to law.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that
on April 4, 2009 at 1118 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 Robert C. Lewis,
Jr., located at, 26 South Enola Drive, Enola, Cumberland County Pennsylvania, according to
law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after
due and legal notice had been given according to law, he exposed the within described
premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County,
Pennsylvania on September 2, 2009 at 10:00 o'clock A.M. He sold the same for the sum of
$1.00 to Attorney Michael T. McKeever, on behalf of, Wachovia Mortgage Corporation, of,
P.O. Box 900001, 1100 Corporate Center Drive, Raleigh, NC 26707-5066, being the buyer in
this execution, paid to Sheriff R. Thomas Kline the sum of $ 796.04.
Docketing 30.00
Poundage 15.61
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 48.00
Auctioneer 10.00
Law Library .50
Prothonotary 2.00
Mileage 27.00
Levy 15.00
Surcharge 20.00
Post Pone Sale 40.00
Law Journal 355.00
Patriot News 113.00
Share of bills 15.43
Distribution of proceeds 25.00
Sheriff's deed
So Answers,
R. Thomas Kline, Sheriff
By
NA?-
Real Estate Coordinator
49.50
796.04 ??gl??oq
5-D
71978
/tom 31-t 7 g
Y
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
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1101) Corporate Center Drive
Raleigh. NC 26707-5066
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
ROBERT C. LEWIS JR.
(Mortgagor(s) and Record Owner(s))
26 South Enola Drive
Enola, PA 17025
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-6310
AFFIDAVIT PURSUANT TO RULE 3129
WACHOVIA MORTGAGE CORPORATION, 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:
26 South Enola Drive
Enola, PA 17025
].Name and address of Owner(s) or Reputed Owner(s):
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
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:
i
BENEFICIAL CONSUMER DISCOUNT COMPANY
P.O. Box 9068
Brandon, FL. 33509
BENEFICIAL CONSUMER DISCOUNT COMPANY
961 Weigel Drive
Elmhurst, IL 60126
BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
419 Village Drive, Suite 2
Carlisle, PA 17013
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
magi be affected by the sale.
TENANTS/OCCUPANTS
26 South Enola Drive
Enola, PA 17025
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the be/ my rsonal knowledge or
information and belief. I understand that false statements herein are made subject to t e penal 'es of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DAJED: January 16, 2009
EEVER
GOLDBECK Vaintiff
BY: Michael Attorney for
i ,
08-6310
t
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
WACHOVIA MORTGAGE CORPORATION
PO Box 900001
1 100 Corporate Center Drive
Raleigh, NC 26707-5066
Plaintiff
vs.
ROBERT C. LEWIS JR.
Mortgagor(s) and Record Owner(s)
26 South Enola Drive
Enola, PA 17025
Defendant(s)
Term
No. 08-6310
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: LEWIS JR., ROBERT C.
ROBERT C. LEWIS JR.
26 South Enola Drive
Enola, PA 17025
Your house at 26 South Enola Drive, Enola, PA 17025 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 $96,494.76 obtained by WACHOVIA MORTGAGE CORPORATION 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 WACHOVIA MORTGAGE CORPORATION, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call
our office at 215-825-6329 or 1-866-413-2311.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
08-6310
You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
You may contact the Foreclosure Resource Center: 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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
08-6310
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.orv-/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 73648FC.
Para information en espanol puede communicarse con Loretta al 215-825-6344.
ALL THAT CERTAIN piece or lot of land with the improvements thereon erected situate
in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described
as follows, to wit:
BEGINNING at a point on the Eastern side of Enola Drive, formerly known as Brick
Church Road, at the line of lands now or formerly of Lemuel R. Spong; thence Eastward
along said last mentioned lands, one hundred twenty-five (125) feet to a point; thence
Northward twenty-five (25) feet, more or less, to a point on the line running thorough the
center of the partition wall of the double house erected upon the lot herein conveyed and
the lot adjoining on the North; thence Westward along said line and along line of
property now or formerly of Paul E. Strickener, one hundred twenty-five (125) feet, more
or less, to a point on the Eastern side of said public road; thence Southward along said
public Road, twenty-five (25) feet, more or less to a point, the place of BEGINNING.
BEING THE SAME PREMISES which Paul E. Boyer and Catherine L. Boyer, husband
and wife, by Deed bearing date the 3rd day of May, 2007, and recorded on 15"' day of
May, 2007 in the Office of the Recorder of Deeds in and for Cumberland County,
Pennsylvania, in Record Book 279, Page 4941, granted and conveyed unto Beneficial
Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania.
UNDER AND SUBJECT to restriction and conditions as now appear of record
BEING KNOWN AS 26 SOUTH ENOLA DRIVE, ENOLA PA 17025
TAX MAP 09-15-1291-053
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) N008-6310 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Wachovia Mortgage Corporation P O Box 900001 1100
Corporate Center Drive Raleigh, NC 26707-5066
Plaintiff (s)
From Robert C. Lewis Jr.
(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 $96,494.76 L.L.$.50
Interest from 01/17/2009 to date of sale per diem at $19.13
Atty's Comm %
Due Prothy $2.00
Atty Paid $162.00 Other Costs
Plaintiff Paid
Date: January 21, 2009
C AisR. 4-P?-o-not/a
(Seal) By:
Deputy
REQUESTING PARTY:
Name Michael T. McKeever, Esq.
Goldbeck McCafferty & McKeever
Address: Suite 5000 - Mellon Independence Center
701 Market St.
Philadelphia, PA 19106
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court ID No. 56129
Real Estate Sale # 15
On January 27, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA
Known and numbered as 26 South Enola Drive,
Enola, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: January 27, 2009
By: V "I C-.
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, accordin? 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.
Marie
SWORN TO AND SUBSCRIBED before me this
15 day of May, 2009
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
MY Commission Expires Apr 28, 2010
RRAL MAID 9A IX NO. 15
Writ No. 2008-6310 Civil
Wachovia Mortgage Corporation
VS.
Robert C. Lewis, Jr.
Atty.: Michael T. McKeever
ALL THAT CERTAIN piece or
lot of land with the improvements
thereon erected situate in East
Pennsboro Township, Cumberland
County, Pennsylvania, bounded and
described as follows, to wit:
BEGINNING at a point on the
Eastern aide of Enola Drive, ftmerly
known as Brick Church Road, at
the One of lands now or formerly of
Limmel R Spcn& thence Eastward
elag said last mentioned lands, one
hundred twenty-five (125) feet to a
point; thence Northward twenty-five
(25) feet, more or less, to a point on
the line running thorough the center
of the partition wall of the double
house erected upon the lot herein
conveyed and the lot adjoining on
the North; thence Westward along
said line and along line of property
now or formerly of Paul E. Strickener,
one hundred twenty-five (125) feet,
more or less, to a point on the East-
ern side of said public road; thence
Southward along said public Road,
twenty-five (25) feet, more or less to a
point, the place of BEGINNING.
BEING THE SAME PREMISES
which Paul E. Boyer and Catherine
L. Boyer, husband and wife, by
Deed bearing date the 3rd day of
May, 2007, and recorded on 15th
day of May, 2007 in the Office of
the Recorder of Deeds in and for
Cumberland County, Pennsylvania,
in Record Book 279, Page 4941,
granted and conveyed unto Benefi-
cial Consumer Discount Company
d/b/a Beneficial Mortgage Company
of Pennsylvania.
UNDER AND SUBJECT to restric-
tion and conditions as now appear
of record.
BEING KNOWN AS 26 SOUTH
ENOLA DRIVE, ENOLA PA 17025.
TAX MAP 09-15-1291-053.
'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
ZhePatriot-News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
04/24/09
05/01/09
05/08/09
Sworn to an subs ibed before me this 12 day of May, 2009 A.D.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
tctaria} Seai
Shema L. Kisnef. Notary Public
j City Of Harrisburg, Dauphin County
My Corrrrr>isslon Expires Nov. 26, 2011
Member, Pennsylvania Association of Notaries
Real Estate Sale No. 15
Writ. No. 2008-6310 Civil Term
Wachovla MortgaSge Corporation
Robert C. Lewis, Jr.
Attorney Michael T. McKeever
LEGAL DaWpApTJON
AIL THAT CERTAIN piece or lot of land with
the improvements thereon erected situate in East
Pennsboro Township. Cumberland County,
Pennsylvania, bounded and described as follows,
to wit:
BEGINNING at a point on the Eastern side of
Enola Drive, formerly known as Brick Church
Road, at the line of lands now or formerly of
Lemuel R. Spong; thence Eastward along said
last mentioned lands, one hundred twenty-five
(125) feet to a point; thence Northward twenty-
five (25) feet, more or less, to a point on the line
running thorough the center of the partition wall
of the double house erected upon the lot herein
conveyed and the lot adjoining on the North:
thence Westward along said line and along line
of property now or formerly of Paul E.
strickener, one hundred twenty-five (125) feet,
more or less, to a point on the Eastern side of
said public road; thence Southward along said
public Road, twenty-five (25) feet, more or less
to a point, the place of BEGINNING.
BEING THE SAME PREMISES which Paul E.
Boyer and Catherine L. Boyer, husband and
wife, by Deed hearing date the 3rd day of May.
2007, and recorded on 15th day of May, 2007 in
the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Record
Book 279, Page 4941, granted and conveyed
unto Beneficial Consumer Discount Company dl
bla Beneficial Mortgage Company of
Pennsylvania.
UNDER AND SUBJECT to restriction and
conditions as now appear of record.
BEING KNOWN AS 26 SOUTH ENOLA
DRIVE, ENOLA PA 17025
T,'A MAP 09-15-1291-053