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Home My WebLink About08-6535Ci / GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY1.1).#56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM WASHINGTON MUTUAL BANK, AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. HARRY J. ARNOLD DONNA L. ARNOLD Mortgagors and Record Owners 406 Brick Church Road Enola, PA 17025 Defendants CIVIL ACTION: MORTGAGE NOTICE FORECLOSURE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term e1111-1 No. (/J U5-35- RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, PSTA 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 ho://www.t)hfa.orp-/consumers/homeowners/real.4gx. 5). Call the Plaintiff (your lender) at 866-926-8937 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentign@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 61627FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is WASHINGTON MUTUAL BANK, AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW, 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendants are HARRY J. ARNOLD, 406 Brick Church Road, Enola, PA 17025 and DONNA L. ARNOLD, 406 Brick Church Road, Enola, PA 17025, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On August 31, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to WASHINGTON MUTUAL BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1965, Page 634. 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 December 01, 2007 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 ....................................................................................$95,425.69 Interest from 11/01/2007 through 10/31/2008 at 7.8500% .....................$10,649.87 Per Diem interest rate at $20.52 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,771.28 Late Charges from 12/01/2007 to 10/31/2008 .............................................$669.44 Monthly late charge amount at $41.84 Costs of suit and Title Search ......................................................................$900.00 Escrow Advance .......................................................................................$4,199.81 Fees ..............................................................................................................$108.80 Recoverable Balance .................................................................................$2,726.72 Suspense ..................................................................................................... ($747.67) Monthly Escrow amount $181.08 $118,703.94 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 date of the postmark on the Notice was the same as the date of the Notice. The Defendants had the required face to face meeting within the required time and Plaintiff has been advised that the Defendants filed an application for mortgage assistance with the Pennsylvania Housing Finance Agency, the Plaintiff has been advised by the Pennsylvania Housing Finance Agency that the Defendants' application has been rejected. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $118,703.94, together with interest at the rate of $20.52, 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:? Lpk T-IA co-V e1 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, LO'Allwhm , 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: ASH GT N MUTUAL BANK, AS SUCC SOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW A 01V 1s to ?J 0'7' `J)0 Inog &k ki Ctts7:C?" f'?1-NBC, A1072,0444 (,RSM*-77,PA/ - #61627fc HARRY J. ARNOLD and DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 E.)chibitA ALL THAT CERTAIN lot or piece of ground situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Michael C. D'Angelo, Registered Surveyor, dated June 13, 1975, as follows: BEGINNING at a point on the westerly side of Brick Church Road (50 feet wide) at the Northeast corner of Lot No. 15 on the hereinafter mentioned Plan; said point being measured along said road in a Northwardly direction 269.0 feet from the centerline of Dauphin Street; thence extending from said beginning point along the Northerly side of Lot No. 15 North 82 degrees 15 minutes west 150.00 feet to a pin on the Easterly side of a 10 foot alley; thence extending along said alley, North 8 degrees 22 minutes East 45.0 feet to a found stake a corner of Lot No. 13; thence extending along said lot, South 82 degrees 15 minutes East 150.0 feet to a found pin on the westerly side of Brick Church Road; thence extending along said road, South 8 degrees 22 minutes West 45.0 feet to the point and place of BEGINNING. BEING Lot No. 14, Block A on Plan of Lots of Enola Terrace, recorded in Plan Book 1, Page 3. '01%] 9 6*5*PG 0 6.5:0' Ex hibit B Washington Mutual PO Box 44118 Jacksonville, FL 32231-4118 September 14, 2007 #BWNCLNN# #0907299462906993# HARRY J ARNOLD 406 BRICK CHURCH RD ENOLA PA 17025 001259 1PC 0729462069 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0729462069 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency maybe able to help explain it. You may also want to contact an attorney in your area. The local bar association maybe 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 ROWDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDDKIR SU HIPOTECA. SP999 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NUMBER: ORIGINAL LENDER: Harry J. Arnold 406 Brick Church Rd Enola PA 17025 0729462069 Lbm CURRENT LENDER/SERVICER: Washington Mutual Bank 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 FOR C 1R . - 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 YT (ggl DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE„ YOU MU T EM . YOLnt MORTGAGE 1P TO DATE. THE PART OF THIS NOTICE-CALLED "HOW TO CURE YOUR MORT A D FA II T" EXPi AiNS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING A ..NCM - 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 tell phone numbers of designated consumer credit counseling agencies for h ,n y in which the proopcM 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 immedialdy of your intentions. APPLICATION FOR MORTGAGF. ASSISTANCE. - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) 001259/SP999 HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 406 Brick Church Rd Enola PA 17025 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 07/01/2007 $878.38 08/01/2007 $1179.64 09/0112007 $1179.64 Other charges (explainfitemize): Uncollected Late Charges $0.00 Uncollected Fees: $8.90 Corporate advances $815.22 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $4061.78 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): 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 $4061.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa=nts must be made either by cash, cashier's check, certified check, or money order made payable and sent to: Washington Mutual PO BOX 41275 Jacksonville, FL 32203 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURE THE D .FA i .T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender Intends :ercise i • right. In amelerate he martgag debt This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to forw3ase upon your •IF THE MORTGAGE IN FOREMAIS .D IPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attoneey's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure he default within the THIRTY (301 DAY period. you will not he required to pav attorney's fees. OTHER LENDER REMF.Di c - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. SP999 RIGHT TO CURE THE D -FA 1 .T PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you may still have the right to cure the default and nrevent the gal at any time tin to one hour the lender and by performing any other requirement under the martgU , 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 gH .RIFFS SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: Washington Mutual Address: PO Box 44118 Jacksonville, FL 32231-4118 Phone Number: 1,888-1152-1745 Fax Number: 1-904-281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans com EFFECTS 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. SP999 ACT 91 NOTICE DATE OF NOTICE: January 18, 2008 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, ,you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, oy u may call the Pennsylvania Housing Finance Agent toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: January 18, 2008 TO: DONNA L. ARNOLD Homeowners Name: HARRY J. ARNOLD and DONNA L. ARNOLD Property Address: 406 Brick Church Road, Enola, PA 17025 Loan Account No.: 0729462069 Original Lender: WASHINGTON MUTUAL BANK Current Lender/Servicer: HOMEQ SERVICING CORP. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. . APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have Med bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Brine it uy to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 406 Brick Church Road, 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: (a) Monthly payment from 07/01/2007 thru 1/18/2008 (7 mos. at $878.38/month) $6,148.66 (b) Other charges; Escrow, Inspec., NSF Checks (c) Other provisions of the mortgage obligation, if any (d) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $6,148.66 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 $6,148.66 . PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Poments must be made either by cashier's check, certified check or money order made payable and sent to: WASHINGTON MUTUAL BANK Attention: Collection Department 7255 Baymeadows Way Jacksonville, FL 32256 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 morgsaee debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged Property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to nay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing anmother requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four 4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: WASHINGTON MUTUAL BANK Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 888-852-1745 Fax Number: 818-775-6260 Contact: Collection Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Collection Department Phone Number: 888-852-1745 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 T N ?- -' 3 ? :? s <'': I ? r SHERIFF'S RETURN - REGULAR yr . % CASE NO: 2008-06535 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS ARNOLD HARRY J ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE ARNOLD DONNA L was served upon the DEFENDANT , at 1022:00 HOURS, on the 7th day of November , 2008 at 406 BRICK CHURCH ROAD ENOLA, PA 17025 DONNA ARNOLD by handing to 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 - 16.0 0 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 11/12/2008 GOLDBECK MCCAFFERTY MCKEEVER By - --IT Deputy Sheriff of A. D. lk CASE NO: 2008-06535 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS ARNOLD HARRY J ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE ARNOLD HARRY J the DEFENDANT , at 1022:00 HOURS, on the 7th day of November , 2008 at 406 BRICK CHURCH ROAD ENOLA, PA 17025 by handing to HARRY ARNOLD a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 1f 1) 2)o Y fir' 18.00 15.00 .00 10.00 .00 43.00 Sworn and Subscibed to before me this day of , So Answers: ooreae-x-, - 'ww, ---- ;e4 R. Thomas Kline 11/12/2008 GOLDBECK MCCAFFERTY MCKEEVER By Pi eputy S eri f A.D. was served upon 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 WASHINGTON MUTUAL BANK, AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff Vs. HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6535 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pn.R.C.P. 2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of for Voluntary Substitution under Pa.R.C.P. 2352 and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the Plaintiff JPMorgan Chase Bank, National Association, as purchaser of the loans and other assets of Washington Mutual Bank, F/K/A Washington Mutual Bank, FA, 7255 Baymeadows Way, Jacksonville, FL 32256. Itt, -r'jtq ( MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 WASHINGTON MUTUAL BANK, AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6535 STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P. 2352 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned action is one in mortgage foreclosure regarding the premises as noted in the caption. 2. The subject of the above-captioned action is a first mortgage on said premises recorded at Mortgage Book 1965, Page 634 in the Office of the Recorder of Deeds for this County. 3. The original Plaintiff is WASHINGTON MUTUAL BANK; AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW. 4. JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA is the successor in interest to the Plaintiff by Assignment lodged for recording in the Office of the Department of Records and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. 5. The real party in interest in the proceeding is JPMorgan Chase Bank, National Association, as purchaser of the loans and other assets of Washington Mutual Bank, formerly known as Washington Mutual Bank, FA (the "Savings Bank") from the Federal Deposit Insurance Corporation, acting as receiver for the Savings Bank and pursuant to its authority under the Federal Deposit Insurance Act, 12 U.S.C. § 1821(d). lolly submitted, Res ?' - t, EsQ ER AEL ?f • MCgEE 1vlICH 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 WASHINGTON MUTUAL BANK, AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff Vs. HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) CERTIFICATE OF SERVICE Term No. 08-6535 Michael T. McKeever, Esquire, hereby certifies that he did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on January 17, 2009. HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 Michael T • McKeever, Esq. C? C= (D Cw) `? f t'i Ln co I In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-6535 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 HARRY J. ARNOLD and DONNA L. ARNOLD by default for want of an Answer. Assess damages as follows: Debt Interest from 01/18/2009 to Date of Sale per diem at $20.52 Total (Assessment of Damages attached) $120,905.46 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMO S ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM TH MPLA^T. I certify that written notice of the intention to file this praecipe was mailed or delivered to the p y agains horn judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten ys prior the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. Attorney fff I.D. #56YZ AND NOW J?WA N A I ? C Judgment is entered in favor of JPMORGAN CHASE B-ANK, NAT ONAL ASSOCIATION, S P RC ASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, FWA WASHINGTON M AL BANK, FA and against HARRY J. ARNOLD and DONNA L. ARNOLD by default for want of an Answer and damages assessed in the sum of $120,905.46 as per the above certification. _ A othonotary Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville. FL 32256 Plaintiff No. 08-6535 vs. HARRY J.ARNOLD DONNA L. ARNOLD (Mortgagors and Record Owner(s)) 406 Brick Church Road 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 61627FC 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 2, 2008 TO: HARRY J.ARNOLD 406 Brick Church Road Enola, PA 17025 WASHINGTON MUTUAL BANK, AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 vs. HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 TO: HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-6535 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 61627FC 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 2, 2008 TO: DONNA L. ARNOLD 406 Brick Church Road Enola. PA 17025 WASHINGTON MUTUAL BANK, AS SUCCESSOR IN INTEREST TO LONG BEACH MORTGAGE COMPANY BY OPERATION OF LAW 7255 Baymeadows Way Jacksonville, FL 32256 vs. HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 TO: DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-6535 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 r 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, HARRY J. ARNOLD, is about unknown years of age, that Defendant's last known residence is 406 Brick J'e ad Enola, PA 17025, and is engaged in the unknown business located at unknown add2. That Defendant is not in the Military or Nof the United States or its Allies, or otherwise within the provisions of the Soldie ors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 0 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, DONNA L. ARNOLD71so t unknow n years of age, that Defendant's last known residence is 406 Brick Church Roa A 17025, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval S Xr/vicee United States or its Allies, or otherwise within the provisions of the Soldierivil 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 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW HARRY J.ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 08-6535 ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK, NATIONAL PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUT WASHINGTON MUTUAL BANK, FA, and against HARRY J. ARNOLD and DO failure to file an Answer in the above action within (20) days (or sixty (60) days if fe of America) from the date of service of the Complaint, in the sum of $120,905.46. Michael T. 1 Attorney for I hereby certify that the above names are correct and that the pr ise residence creditor is JPMORGAN CHASE BANK, NATIONAL ASSOCIAFs) , AS PURCH? AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, WASHINGT( 7255 Baymeadows Way Jacksonville, FL 32256 and that the nam d last known Defendant(s) is/are HARRY J. ARNOLD, 406 Brick Church Road Enola, PA 1702 a: 406 Brick Church Road Enola, PA 17025; ?41 , AS F A LD for United States :s? of the judgment OF THE LOANS UTUAL BANK, FA s(es) of the )NNA L. AANOLD, GOLDBECK VCAFFERTY & McKEEVER BY: Michael McKeever ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 11/01/2007 through 01/17/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 3 X $181.08 Escrow Advance Fees Recoverable Balance Suspense $95,425.69 $12,250.43 $4,771.28 $794.96 $900.00 $543.24 $4,199.81 $41.00 $2,726.72 ($747.67) $120,905.46 GOLDBECK MdC,,, BY: Michael T. M? Attorney for Plai ti VER AND NOW, this -2/'V+ day of Ja`Zt-? 2009 damag/s are assessed as above. A A dk 0.0 P rothy C=7 IKJ CO r U 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 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. HARRY J.ARNOLD DONNA L.ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6535 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 01/18/2009 to Date of Sale per diem at $20.52 (Costs to be added) ALL THAT CERTAIN lot or piece of ground situate in East Pennsboro Township. Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Michael C. D'Angelo, Registered Surveyor, dated June 1 3., 1975, as follows: BEGINNING at a point on the Westerly side of Brick Church Road (50 feet wide) at the Northeast corner of Lot No. 15 on the hereinafter mentioned Plan; said point being measured along said road in a Northwardly direction 269.0 feet from the centerline of Dauphin Street; thence extending from said beginning point along the Northerly side of Lot No. 15 North 82 degrees 15 minutes West 150.00 feet to a pin on the Easterly side of 10 foot alley; thence extending along said alley, North 8 degrees 22 minutes East 45.0 feet to a found stake a corner of Lot No. 13; thence extending along said lot, South 82 degrees 15 minutes East 150.00 feet to a found pin on the Westerly side of Brick Church Road; thence extending along said road, South 8 degrees 22 minutes West 45.0 feet to the point and place of BEGINNING. BEING LOT No. 14 Block A on Plan of Lots of Enola Terrace, recorded in Plan Book 1, Page 3. TAX PARCEL NO: 09-14-0834-082 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6535 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMorgan Chase Bank, National Association, as purchaser of the loans and other assets of Washington Mutual Bank, f/k/a Washington Mutual Bank, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff (s) From Harry J. Arnold Donna L. Arnold (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 $120,905.46 L.L.$.50 Interest from 01/18/2009 to date of sale per diem at $20.52 Atty's Comm % Due Prothy $2.00 Atty Paid $178.00 Plaintiff Paid Other Costs Date: January 21, 2009 (Seal) //z Z'4h5Z4 - - rtis R. Lon thonota 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 Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. HARRY J. ARNOLD DONNA L. ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) 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 comp Act. NO. 08-6535 in this action, and provisions of the Michael T. D Attorney for J -! IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA V. IN RE: WASHINGTON MUTUAL BANK, Moving Party HARRY J. ARNOLD DONNA L. ARNOLD CHARLES J. DEHART, III ESQ., Respondents HARRY J. ARNOLD dba H AND A LANDSCAPING LLC DONNA L. ARNOLD, Debtors CHAPTER 13 CASE NO: 1-08-bk-00347-MDF RE: DOCKET ENTRY NO: 44 MOTION FOR RELIEF FROM STAY 11 U.S.C. Section 362 and 1301 ORDER Upon consideration of Movant's Motion for Relief from the Automatic Stay, it is ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under 11 U.S.C. Sections 362 and 1301 of the Bankruptcy Reform Act of 1978 (The Code) 11 U.S.C. 1 I U.S.C. Sections 362 and 1301 (if applicable), are modified to allow Washington Mutual Bank and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriffs Sale regarding the premises 406 Brick Church Road Enola, PA 17025 and a possessory action if necessary. The stay provided by Bankruptcy Rule 4001(a)(3) has been waived. Case 1:08-bk-00347-MDF Doc 49 Filed 11/14/08 Entered 11/14/0814:58:49 Desc Main Document Page 1 of 2 ,-% 1. Movant may, at its option, provide and enter into a potential forbearance agreement, loan modification, refinance agreement or other loan workout/ loss mitigation agreement. The moving party may contact the debtor(s) via telephone or written correspondence to offer such an agreement. B the {_'oiuI. Hall rupl _ Judge (JDK) 'has docuITZeF2t iE electroMci7fly S'sgneCY and filed on the Same dcIte. Dated: November 14, 2008 Case 1:08-bk-00347-MDF Doc 49 Filed 11/14/08 Entered 11/14/08 14:58:49 Desc Main Document Page 2 of 2 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-6535 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, 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: 406 Brick Church Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 Nam and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square 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 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: WASHINGTON MUTUAL BANK 1400 South Douglass Road, Suite 100 Anaheim, CA 92806 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 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 perky which may be affected by the sale. TENANTS/OCCUPANTS 406 Brick Church Road 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 b t of my e onal knowledge or information and belief. I understand that false statements herein are made subject to t e pena e of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: January 17, 2009 GOLDBECK AFFERTY & McKEEVER BY: Michael T. cKeever, Esq. Attorney for P aintiff =ca ?i. CC) 08-6535 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 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 vs. HARRY J. ARNOLD DONNA L. ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 Plaintiff Defendant(s Term No. 08-6535 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: ARNOLD, HARRY J. HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 Your house at 406 Brick Church Road, 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 $120,905.46 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 08-6535 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: ht!p://www.philadelphiafed.ory/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 08-6535 Carlisle, PA 17013 717-243-9400 08-6535 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 866-926-8937 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(cygoldbecklaw.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 61627FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. r? C n w Y ? co r • 08-6535 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 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 vs. HARRY J. ARNOLD DONNA L. ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff Defendant(s) Term No. 08-6535 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: ARNOLD, DONNA L. DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 Your house at 406 Brick Church Road, 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 $120,905.46 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 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: .A- 08-6535 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION. AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orj4/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row AP 08-6535 Carlisle, PA 17013 717-243-9400 t 08-6535 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 866-926-8937 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(i?g?oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 61627FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. C"> r-a a ` Ti C. .n -TI r . r?-s 1? + ) ^r 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 61627FC CF: 11/04/2008 SD: 06/10/2009 $120,905.46 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. HARRY J.ARNOLD DONNA L. ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-6535 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 Sheriff s Office{oexpotepoed"it (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( } Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff I't TA {IVY (?.? `T r I i U. I 1 1- N nt 1 'i* o lL "-r- I . 5 w is ¢ L t zd I Z ' ?1 rJ CD Z FN^ gi r q?L'? 0. U- Q ? is O $OC 0 m ( u? cf3 O '1Q1?i7' aC o ZO m X01 S N c U N Y am co- 0 ?O o IF as Q?o? L3? V N ? ? ? ?U o ? ? as St v 4 s cL u,- G N K s N ?? Z W? h ?p01. ?caoN ?1JZm. N$?° uJ?? S Q C QN d 8?°oz ro? 00 ? nQnQ U? ? Cl. 1 1 N= 1 UaYW? 'S to mpW EJ}`?? 1 n?dCD m m C N u 4 m N t m a 0 a m 0 a a ? ui 4 c it a i? i Sa a o? m !Zn m 0 N O aN r o ? m o ' N I r m N d O O Q J 4 Z 06 1 ?] Q -i V )- LL tC 11 --------------------- e (Y) CD y vi ._ f k' !eN CM ? _: dr 0 T N OD OC to o w{ ?---r - m C49 7c r 060 $is jw V . r1A I i I 11 1 J{ 0 $$33„ u' H AS ?j -, a' C7C3? Z is !s W i zzuj air. ?` ? L. ?O??O, F" c j a25 Ygru 71L- j tau lid •' Z??p=OfI it C9 t!f w. d r I I f 'i N ?C'1 CE 0 c c_ m ? p ? OZZ DC ? Q U Z a?f E U ? a ? a UL CO r Q R cc = In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-6535 Civil Term JP Morgan Chase Bank, National Association, as purchaser of the Loans and other Assets VS Harry J. Arnold and Donna L. Arnold Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on February 3, 2009 at 1651 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Harry J. Arnold and Donna L. Arnold, by handing both to Donna L. Arnold, personally and as wife of Harry J. Arnold, at, 406 Brick Church Road, Enola, personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1108 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 Harry J. Arnold and Donna L. Arnold, located at, 406 Brick Church, Enola, Cumberland County Pennsylvania, according to law. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Harry J. Arnold and Donna L. Arnold, by regular mail to their last known address of 406 Brick Church, Enola, PA 17025. This letter was mailed under the date of April 1, 2009 and never returned to the Sheriffs Office Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Harry J. Arnold and Donna L. Arnold, by regular mail to their last known address of, 406 Brick Church, Enola, PA 17013. This letter was mailed under the date of April 2, 2009 and never returned to the Sheriffs Office So Answers, R. ?fo!m!!Kline, Sh ff Ile. By Real late Coordinator GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. HARRY J.ARNOLD DONNA L. ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-6535 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, 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: 406 Brick Church Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 DONNA L. ARNOLD 406 Brick Church Road 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 CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square 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 EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola, PA 17025 4. Name and address of the last recorded holder of every mortgage of record: WASHINGTON MUTUAL BANK 1400 South Douglass Road, Suite 100 Anaheim, CA 92806 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 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 406 Brick Church Road 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 unworn falsification to authorities. DATED: May 27, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff F??_I? _ ? teJ ?`?! f?. td ?Lii v:1 . , ?? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 62421 FC CF: 11/05/2008 SD: 06/10/2009 $176,333.93 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR ABFC 2007-WMC1 TRUST 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE JEAN WHITEHEAD MICHAEL R. WHITEHEAD Mortgagor(s) and Record Owner(s) 247 Ridge Hill Road Mechanicsburg, PA 17050 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 08-6555 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,4eernptitent (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). { ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff affi a U 6 fl ------------- h - --------------- - - ----- - -- I! ? ', O ? ` ?1i 1 1 i ` k ? W p, ?y 1 i i; LL! V4y i i 1 R V l I a °L i? -? O A "`? ` I I 0000 aC i m ? d 4 , i f!1 i?? 9 ? ? 4 O W ? ? 1 b U Rp U a. 1 0000 d d :i i 1 Y m 0 W o! ri co J F ?r' 0oTR cT)ar. ' l i l C6 ?i '6 i? Ia `a I d s r* i 11 ?cu w lit z? ,r c D T U .g as U W u. W h W r2? lL ? 4 Q ? W LL', I T o m? I ? IL !, N OO O IVpILi InW !O¦p? -O Imo 3? a yO N r ` O _- ?? -NW Vo o c > O.J•? -_ N p ....+AVI i C-0 --LION 9. m L cfi m gH- S =v - CL m E c `?? Ema p° m N ca o My ? % LL x N' L 0m i ' c ?i I d -? c ? c I II i i c m o Z5 E I b; a ???? .25 O z N tl- IO y m Q to 0? a E { ??I O d cco°o.. a U U a w G N x c of U ????? W to C13 nMaz c ~ l W z ? ? w tea' o ? yQ I vYpWdN mm?QO?i a)aW Qco EJH?JO Z0?paO,' i?- I N <) V tf> (fl I- 00 m Lo m d - r+ c m E N Q v 10 a i c a C ° ?o m o N 0 g' -> m • a ? O O V O 0 q? N m O Z ` O CL m ci O E w w m ~ , _ 0o O c J CL '- p W z = a U ? co ? K N N atf ? H a U w ,m - S is o? ti W H (U Q 2 T ?? U- ? z N Z ja w LL FJ 0 N W a tD n In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-6555 Civil Term U.S. Bank National Association, as Trustee for ABFC 2007-WMC1 Trust Jean Whitehead and Michael R. Whitehead law, bLamaj, that on February 5, 2009 at 2033 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Jean Whitehead and Michael R. Whitehead, by handing both to Michael R. Whitehaed, personally and as husband for Jean Whitehead, at, 247 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same 1. to him pelsondly dm Mdd trw =a coymt M" of M same. Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 0751 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 Jean Whitehead and Michael R. Whitehead, located at, 247 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner. The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Jean Whitehead and Michael R. Whitehead, by regular mail to their last known address of 247 Ridge Hill Road, Mechanicsburg, PA 17050. This letter was mailed under the date of April 1, 2009 and never returned to the Sheriffs Office So Answers, R. Thomas Kline, S n Rea state Coordinator GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR ABFC 2007-WMC1 TRUST 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. JEAN WHITEHEAD MICHAEL R. WHITEHEAD Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 08-6555 247 Ridge Hill Road Mechanicsburg, PA 17050 Defendant(s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR ABFC 2007-WMC1 TRUST, 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: 247 Ridge Hill Road Mechanicsburg, PA 17050 I.Name and address of Owner(s) or Reputed Owner(s): JEAN WHITEHEAD 247 Ridge Hill Road Mechanicsburg, PA 17050 MICHAEL R. WHITEHEAD 247 Ridge Hill Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: JEAN WHITEHEAD 247 Ridge Hill Road Mechanicsburg, PA 17050 MICHAEL R. WHITEHEAD 247 Ridge Hill Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 SILVER SPRINGS TOWNSHIP 31 East Main Street P.O. Box 1001 New Kingston, PA 17072 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 TENANT/OCCUPANT 247 Ridge Hill Road Mechanicsburg, PA 17050 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: May 27, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 2 tfl9 h ll,? y 2- 8 1 111 "0: 13 . r In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008- 4??Civil Term National City Real Estate Services LLC, SB/M National City MoVtgagq,-Jjiq,, "'a' National City Mortgage Company VS Harry J. Arnold and Donna L. Arnold Ronald Hoover, Deputy Sheriff, who being duly sworn according to law states, that on February 3, 2009 at 1651 hours he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Harry J. Arnold and Donna L. Arnold, by making known unto Donna L. Arnold, personally and as wife of Harry J. Arnold, at, 406 Brick Church Road, Enola Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1108 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 Harry J. Arnold and Donna L. Arnold„ located at, 406 Brick Church Road, Enola, Cumberland County Pennsylvania. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 16.81 Advertising 15.00 Posting Sale Bills 15.00 Law Library .50 Prothonotary 2.00 Mileage 27.00 Levy 15.00 Surcharge 30.00 Share of bills 15.43 Law Journal 355.00 Patriot News Post Pone Sale So Answers, MMM vo ZOO ' R. Thomas Kline, eriff By Real Estate Coordinator 315.49 20.00 857.23 ? F/() t-16 ua so C& 7/17.3 ?e,. .2Asf77 tf 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 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL, BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-6535 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, 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: 406 Brick Church Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 f I 3. Name and last known address of ev cry judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION I Courthouse Square Carlisle. PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bide. - Room 432 P.O. Box 2675 Harrisburg. PA 17105-2675 DOMFSTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. PA 17013 4. Name and address of the last recorded holder of every mortgage of record: WASHINGTON MUTUAL BANK 1400 South Douglass Road. Suite 100 Anaheim. CA 92806 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 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 per?y which may be affected by the sale. 7 TENANTS/OCCUPANTS 406 Brick Church Road 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 b t of my e onai knowledge or information and belief. I understand that false statements herein are made subject to t e pena e of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: January 17, 2009 GOLDBECK AFFERTY & McKEEVER BY: Michael T. cKeever, Esq. Attorney for P aintiff 08-6535 GOLDBECK McCAFFERTY & MCKEEYER 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 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 vs. HARRY J. ARNOLD DONNA L. ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff Defendant(s; Term No. 08-6535 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: ARNOLD, HARRY J. HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 Your house at 406 Brick Church Road, 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 $120,905.46 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 08-6535 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION. AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK. F%K/A WASHINGTON MUTUAL BANK, FA, 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 tiling a petition asking the Court to strike or open judgment. if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriff's 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.philadell2hiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 08-6535 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.liud.g_ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 866-926-8937 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionQygoldbecklaw.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 61627FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-6535 L The sale will be cancelled if you pay to 1PMORGAN CHASE BANK, NATIONAL ASSOCIATION. AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK. F K/A WASHINGTON MUTUAL BANK., FA. the back payments. late charges, costs and reasonable attorney's tees 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 tiling 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 Brood cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or.ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: ht!p://www.Rhiladelphiafed.orp,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 08-6535 Carlisle. PA 17013 717-243-9400 . . .. 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. 08-6535 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 littp://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 866-926-8937 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention a,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 fine'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 61627FC. Para informacion en espanol puede communicarse con Loretta at 215-825-6344. 08-65 35 . ,, . 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 JPMORGAN CHASE BANK. NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 vs. HARRY J. ARNOLD DONNA L. ARNOLD Mortgagor(s) and Record Owner(s) 406 Brick Church Road Enola, PA 17025 IN THE COURT OF COMMON PI_I_:AS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE. FORECLOSURE Plaintiff Defendant(s Term No. 08-6535 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: ARNOLD, DONNA L. DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 Your house at 406 Brick Church Road, Enola, PA 17025 is scheduled to be sold at Sheriff's Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $120,905.46 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 08-6535 . 1. The sale will be cancelled if you pay to .1PMORGAN CHASE BANK. NATIONAL ASSOCIATION. AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK. F/K-'A WASHINGTON MUTUAL BANK. FA. 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 %?as improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orp-/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row 08-6535 r? Carlisle. PA 17013 717-243-9400 08-6535 I 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 maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other- loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 866-926-8937 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(&?oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our fire'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 61627FC. Para infonnacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN lot or piece of ground situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Michael C. D'Angelo, Registered Surveyor, dated June 13, 1975, as follows: BEGINNING at a point on the Westerly side of Brick Church Road (50 feet wide) at the Northeast corner of Lot No. 15 on the hereinafter mentioned Plan; said point being measured along said road in a Northwardly direction 269.0 feet from the centerline of Dauphin Street; thence extending from said beginning point along the Northerly side of Lot No. 15 North 82 degrees 15 minutes West 150.00 feet to a pin on the Easterly side of 10 foot alley; thence extending along said alley, North 8 degrees 22 minutes East 45.0 feet to a found stake a corner of Lot No. 13; thence extending along said lot, South 82 degrees 15 minutes East 150.00 feet to a found pin on the Westerly side of Brick Church Road; thence extending along said road, South 8 degrees 22 minutes West 45.0 feet to the point and place of BEGINNING. BEING LOT No. 14 Block A on Plan of Lots of Enola Terrace, recorded in Plan Book 1, Page 3. TAX PARCEL NO: 09-14-0834-082 IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 406 Brick Church Road Enola, PA 17025 SOLD as the property of HARRY J. ARNOLD and DONNA L. ARNOLD TAX PARCEL #09-14-0834-082 .i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUM13ERLA,ND) NO 08-6535 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMorgan Chase Bank, National Association, as purchaser of the loans and other assets of Washington Mutual Bank, f/k/a Washington Mutual Bank, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff (s) From Harry J. Arnold Donna L. Arnold (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 $120,905.46 L.L.$.50 Interest from 01/18/2009 to date of sale per diem at $20.52 Atty's Comm % Due Prothy $2.00 Atty Paid $178.00 Other Costs Plaintiff Paid Date: January 21, 2009 24?4x?i,44 is R. Long, n tary(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 # 18 On January 28, 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 406 Brick Church Road, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. { Date: January 28, 2009 By' 0) Q-1.t04 °- dJ-1 t LZ -.1 d 8Z Wir bNZ c- , +FIR r? PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: May 1, May 8, and May 15, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Coyne, SWORN TO AND SUBSCRIBED before me this 15 day of Map. 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires A 28, 2010 pr FAAL NSW*M ilws 300. if Writ No. 2008-6535 Civil JP Morgan Chase Bank, National Association, as purchaser of the Loans and other Assets of Washington Mutual Bank f/k/a Washington Mutual Bank, F.A. VS. Harry J. Arnold and Donna L. Arnold Atty.: Michael T. McKeever ALL THAT CERTAIN lot or piece of ground situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and de- scribed in accordance with a survey by Michael C. D'Angelo, Registered Surveyor, dated June 13, 1975, as follows: BEGINNING at a point on the Westerly side of Brick Church Road (50 feet wide) at the Northeast cor- ner of Lot No. 15 on the hereinafter mentioned Plan; said point being measured along said road in a North- wardly direction 269.0 feet from the centerline of Dauphin Street; thence extending from said beginning point along the Northerly side of Lot No. 15 North 82 degrees 15 minutes West 150.00 feet to a pin on the Easterly side of 10 foot alley; thence extend- ing along said alley, North 8 degrees 22 minutes East 45.0 feet to a found stake a comer of Lot No. 13; thence extending, along said lot, South 82 dope" 15 ndautes lit 150.00 Awt to a hund pin an the ?l?eaberl?y ids of Brick Church Road, t>?caie alb said road, South 8 dtgrom 22 mkutea Went 45.0 fed to the point and place of WGINNING. BEING LOT No. 14 Block A on Plan of Lots of Enola Terrace, re- corded in Plan Book 1, Page 3. TAX PARCEL NO: 09-14-0834- 082. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 406 Brick Church Road, Enola, PA 17025. SOLD as the property of HARRY J. ARNOLD and DONNA L. ARNOLD. TAX PARCEL #09-14-0834-082. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE the Patrl'otwNtws Now you know CARLISLE PA 17013 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 and cribed before me this 12 day of May, 2009 A.D. Notary Public COMMONWEAL`rH OF_PENNSYLVANIA grata 4 Sea! Shama L. ftrar, Notary Public Carrisburg, Dauphin county W ssion Expires Nov. 26, 2011 Membesylvaia Association ofNotaries Real FaUft 4ale Mo. 18 Writ No. =O&SM t TwM JP Morgan ? hank, I+ A>feaotatlan, atr purcha er of to Loarw and other Asseb ef Water Mutual Bonk, FIWAWtphVn Mutual Sank, FA VS Harry J. Arnold and Donne L. Arnold Attorney IM~,T. McKeever LEGAL DESCRIPTION ALL THAT CERTAIN lot or piecc.of ground situate in East Petmsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Michael C. D'Angelo; Registered Surveyor, dated Joe 13,1975, as follows: BEGINNING at a point on the Westerly side of Brick Church Road (50 feet wide) at the Northeast corner of Lot No. 15 on the hereinafter mentioned flan; said point being measured along said road in a Northwardly direction 269.0 fed from the centerline of Dauphin Street; thence extending from said beginning poutt along the Northerly side of Lot No. 15 North 82 degrees 15 minutes West 156,00 feel to a pin on the Easterly side of 10 foot alley; thence extending along said alley, North 8 degrees 22 minutes East 45.0 feet to a found stake a comer of Lot No. 13; thence extending along said lot, South 82 degrees 15 mimosa East 150.00 feet to a found pin on the Westerly side of Brick Church Road; thence extending along said road, South 8 degrees 22 minutes West 45.0 feet to the point and place of BEGINNING. BEING LOT No. 14 Block A on Plan of Lots of Enola Terrace, recatded in Plan Book 1, Page 3. TAX PARCEL NO, 09-14.083402 IMPROVEMENTS consist of a residential dwelling. BEING PREMISES; 406 Brick Church Road Enola, PA 17025 SOLD as the property of HARRY J. ARNOLD and DONNA L. ARNOLD TAX PARCEL 409-14.11834-082 ,j KML LAW GROUP,P.C. , • Suite 5000—BNY Independence Center 701 Market Street ' Philadelphia,PA 19106-1532 _ CO 215-627-1322 ` `iL " t' (� T`` ,, ; , Attorney for Plaintiff ' ' -� f JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,AS PURCHASER OF THE IN THE COURT OF COMMON PLEAS LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A of Cumberland County WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville,FL 32256 Plaintiff vs. No. 08-6535 HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s)and Record owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. By: ' KML LAW&TrIPa. . Michael ID 56129 Jay E.Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa.ID 27615 David Fein Pa.ID 82628 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff a a X33©a y KML LAW GROUP, P.C. ' SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 (215)627-1322 ATTORNEY FOR PLAINTIFF JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,AS PURCHASER OF THE IN THE COURT OF COMMON PLEAS LOANS AND OTHER ASSETS OF OF Cumberland COUNTY WASHINGTON MUTUAL BANK,F/K/A WASHINGTON MUTUAL BANK, FA CIVIL ACTION -LAW Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE HARRY J. ARNOLD DONNA L. ARNOLD No. 08-6535 (Mortgagor(s)and Record Owner(s)) Defendant(s) CERTIFICATE OF SERVICE Angela M. Smith,hereby certifies that he/she did serve true and correct copies of Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on - 47 . HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 By. KML LA GROUP, P.C. Angela M. Smith, Legal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone) KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 `� ''? 111 ; 215-627-1322 JPMORGAN CHASE BANK,NATIONAL Y LVA. .iA ASSOCIATION, AS PURCHASER OF THE IN THE COURT OF COMMON PLEAS LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A OF CUMBERLAND COUNTY WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff No. 08-6535 vs. HARRY J. ARNOLD DONNA L. ARNOLD (Mortgagor(s) and Record owner(s)) 406 Brick Church Road Enola, PA 17025 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW R UP,P.C. F/K/A GO EUK cCAFFERTY& McKEEVER By: J Mac ever Pa. ID 56129 Jay E. ivitz a. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa.ID 27615 David Fein Pa.ID 82628 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, AS PURCHASER OF THE IN THE COURT OF COMMON LOANS AND OTHER ASSETS OF PLEAS WASHINGTON MUTUAL BANK, F/K/A OF CUMBERLAND COUNTY WASHINGTON MUTUAL BANK, FA Plaintiff CIVIL ACTION - LAW VS. ACTION OF MORTGAGE HARRY J. ARNOLD FORECLOSURE DONNA L. ARNOLD (Mortgagor(s) and Record Owner(s)) No. 08-6535 Defendant(s) CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on 0� HARRY J. ARNOLD 406 Brick Church Road Enola, PA 17025 DONNA L. ARNOLD 406 Brick Church Road Enola, PA 17025 KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFER7TY& McKEEVER By: &MSmith,A ela Legal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone)