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Home My WebLink About08-6556GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 W W W.GOLDBECKLAW.COM MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff Vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagors and Record Owners 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 08 - tor% aivi CIVIL ACTIOORTGAGE berm FORECLOGURF NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A 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 TELF-FONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, I-STA 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 hft://www.phfa.org/consumers/homeowners/real.aox. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw 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 72251 FC. 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 MIDWEST FIRST FINANCIAL LP IV, 11904 Arbor Street, Suite 200 Omaha, NE 68144. 2. The names and addresses of the Defendants are JILL A. COWOSKI, 6 Spring Valley Lane, Mechanicsburg, PA 17055 and CHRISTOPHER J. COWOSKI, 6 Spring Valley Lane, Mechanicsburg, PA 17055, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On March 09, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MADISON EQUITY CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1944, Page 2627. The mortgage has been assigned to: MIDWEST FIRST FINANCIAL LP IV by assignment of Mortgage April 23, 2007 as Book 736, Page 1342. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ................................................ .......$131,959.60 Interest from 06/01/2008 through 11/30/2008 at 10.0000% ..................... $6,708.77 Per Diem interest rate at $36.66 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,597.98 Late Charges from 07/01/2008 to 11/30/2008 .............................................$293.24 Monthly late charge amount at $58.65 Costs of suit and Title Search ......................................................................$900.00 Escrow Advance ..........................................................................................$763.06 Monthly Escrow amount $132.02 $147,222.65 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 Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $147,222.65, together with interest at the rate of $36.66, 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: 1 `7Y1C. GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, efM t* k-- y V04 , 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 Use statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: /1-3-08 #7225117C JILL A. COWOSKI and CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 EXhi6itA - " i .. • 0 LEGAL D SCRIPTION THE FOLLOWING DESC ED REAL COUNTY OF CUMBERLAND, AND C( ALL THAT CERTAIN TRACT OR PARCEL OF 1 CUMBERLAND COUNTY PENNSYLVANIA, S AS DESCRIBED IN ACCO DANCE WITH THE PHASE II RECORDED IN UMBERLAND COU PARTICULARLY DESCRI ED AS FOLLOWS, I BEGINNING AT A POINT N THE NORTHERN LANE, A 50 FOOT RIGHT F-WAY, AT THE SC AFOREMENTIONED PLA , THENCE ALONG S SPRING VALLEY LANE S UTH 65 DEGREES 0 85.46 FEET TO A POINT THE SOUTHEASTE AFOREMENTIONED PLA ; THENCE ALONG S 17 SECONDS WEST A Dl ANCE OF 116.12 FE] LANDS NOW OR FORME Y OF KEENETH R, ALONG SAID LANDS NO OR FORMERLY OF SECONDS EAST A DISTA CE OF 85.48 FEET T, OF LOT #77 ON THE AFO NTIONED PLAT DEGREES 54 MINUTES 1 SECONDS EAST A D PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255 BY FEE SIMPLE DEED F OM DAVID R. TI SET FORTH IN DEED BC?K 187, PAGE 501 COUNTY RECORDS. SITUATE IN THE TOWNSHIP UPPER ALLEN, kLTH OF PENNSYLVANIA, TO WIT: ND SITUATE IN UPPER ALLEN TOWNSHIP, AWN AS LOT #76, PHASE II, BOWMAN'S HILL 4AL SUBDIVISION PLAN OF BOWMAN'S HILL Y PLAN BOOK 68, PAGE 15, MORE WIT: RIGHT-OF-WAY LINE OF SPRING VALLEY UTHWESTERN CORNER OF LOT #77 ON THE SID NORTHERN RIGHT-OF-WAY LINE OF MINUTES 43 SECONDS WEST A DISTANCE OF tN CORNER OF LOT #75 ON T14E kID LOT #75 NORTH 24 DEGREES 54 MINUTES T TO A POINT AT THE SOUTHERN LINE OF WHITE AND MARTHA C. WHITE; THENCE WHITE NORTH 63 DEGREES 53 MINUTES 50 > A POINT AT THE NORTHWESTERN CORNER THENCE ALONG SAID LOT #77 SOUTH 24 STANCE OF 117.91 FEET TO A POINT AND SON AND DENISE P. THOMPSON, HIS WIFE AS RECORDED ON 10/20/1998, CUMBERLAND THE SOURCE DEED AS S ATED ABOVE IS TH . LAST RECORD OF VESTING FILED FOR THIS PROPERTY. THERE HAV) BEEN NO VESTING RANGES SINCE THE DATE OF THE ABOVE REFERENCED SOURCE. 1801778 U3687417 -41018 ma"aw uw. ,.nm Lo R?rdlr?. JRBWI944PGII >44 - xi Exhibit 0 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM DATE: August 6, 2008 FORECLOSURE Christopher J Cowosld 6 Spring Valley Lane Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mortgage on yon }+••••e is in default a? the lend inter to orecl S c information about the nature of the d fault is provided in the attached ping- The HOMEOWNER'S MORTGAGE ASSISTANCE MO RAM lHRMAP) maybe able to help to save pour home. This Notice explains how the program works. To see if HE can in you must MEET WITH A nNSi rMFR CREDI COUN T ING AGENCY WITIRN 33 DAYS FROM THE DATE OF TFUS NOTICE. Take ties Notice with you when you meet the Counseling Agency The name, address and phone number of Consumer Credit nun?l;no Ages 'ng Your ounty are sted at the end of this Notice If y ve Y_qu 'o a you may call the PenmULNj na House Finance Aged toll free at 1 $00-342-2397. Persons with impaired hearing can call (717)780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA,, PUEDE AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM DATE: August 6, 2008 FORECLOSURE Till A. Cowoski 6 Spring Valley Lane Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official noti ce that the mo eon your home is in default and the lender intends to foreclosure. Specific information about the nature of the drfA„lt is provided in the attached images. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRA?r MAID% - e able to help to save vour home This Notice explains how the ?roi¢ram works To see if HEMAP can help you muv?+ WITH A CONSUMER CREDIT COUNSELING AGENCY mmml ---FROM THE DATE OF TIJIS NOTICE. Take this Notice with you when you meet the Counseling encY The name, address and vhone number of Consumer Credit Course inQ Agencies ,;re un are listed at a end of this Notice If you have any gyou n,A? rill the Pennsvlyanra Housing Finance Agma toll free at 1 800 342 2397 (Persons with rmDarred heanng_can oU_ 717) 780-1869)v This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADRWO ES DE SUMA IMPORTANCIA, PUEDE AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CAS- SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. STATEMENTS OF POLICY HOMEO'WNER'S NAME(S): dill A Cowosid PROPERTY ADDRESS: 6 Spring Valley Lane, Mechanicsburg, PA 17055 LOAN ACCT. NO.: COW0643PA ORIGINAL LENDER: Madison Equity Corporation CURRENT LENDER/SERVICER: Midwest First Financial Limited Partnership IV HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MORTGAGE PA NTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (TFIE "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 three (33) 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 WTTHIN THE NEXT (33) DAYS IF YOU DO NOT APPT Y FOR EMERGENCY MORTGAGE ASSISDANCE, YOU MUST BRING YOr m MORTGAGE UP TO DATE THE PART OF S NOTICE CALLED "HOW TO YOUR MORTGAGED FAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP MAIL CONSUMER CREDIT OUNSELING AGENCIES If you meet with one of hP comsumer MORE= aaPnc;Pr lietr?i at the en r•?• ': •'- lendei y NOT take action aa" ain, you for 9M e ? daVQ A?A1 the date of this meeting. The names. ses to en om numbers of designated consumer credit counseling agencies for the county in which the yrouertv is Iowted are set forth at the end of this Notice. t is only necessary to schedule one face-to-face meeting. Advise your lender immmed*ately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty three (33) 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 TIM PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can stall apply for Emergency Mortgage HOW TO CLmR YOUR MORTGAGE DEFAULT Bring it up to date NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 6 Spring Valley Lane, Mechanicsburg, PA, IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Start/End: 7/1/08 thru 8/1/08 at $1,173.04 per month. Monthly Payments Plus Late Charges Accrued $2,463.37 NSF: $0.00 Force placed insurance premiums due: $638.57 Other: $0.00 (Suspense): $0.00 Total amount to cure default $3,101.94 HOW TO C F. THE DEFAULT-You may cure the default within THIRTY THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,101.94, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY THREE (33) DAY PERIOD. As of the date of this letter, you owe the amount specified above. Because of interest, late charges, and other charges that may vary from day to day, the amount due on the day-that you pay may be greater. Hence, if you pay the amount shown above, an adjustment may be necessary after we receive your check, in which event we will inform you before depositing the check for collection. For further information, write the undersigned or call (402) 330-2274 and ask for Matt Huerta. Payments must be made ether by cash. cashier's che& certified check or money order made payable and sent to Midwest First Financial Limited Partnership IV, 11904 Arbor Street Suite 200, Omaha, NE 68144. You can cure any other default by taking the following action within THIRTY THREE (33) DAYS of the date of this letter. IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY THREE(33) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. The means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within TTY THREE (33) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure anon your mortgage p=?*. IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount to the lender, which may also include other reasonable costs. If you cure the default within the THIRTY TTiREE (331 DAY period. von- will not be required to pay attorney's fees OTHER L ER 0-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURF TFTR nFFar.JLT PRIOR TO ST?RrFR-1c ce_r,E ffyou have not cured the default within the THIRTY THREE (33) DAY proceedings have be ) period and foreclosure gun, you still have the right to cure he dPfanlt and ,ti?revent the sale at any time up to one hour fore the SherLf s q - You may do so by mydgg the total amount then nest due. plus any AtP Other C Aroma then due. reasonable aHnr ="s fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by perfo in any other rmQents under the mort?a$g?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 ATE-It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT LENDER- Midwest First Financial Limited Partnership Iv 11904 Arbor Street Suite 200 Omaha, NE 68144 (402) 330-2274 Contact Person: Matt Huerta (866) 240-7477 EFFECT OF-SHE F'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUIy1PTION 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, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED If this is the first notice that you have received from this office, be advised that: You may dispute the validity of the debt or any portion thereof If you do so in writing within thirty three (33) days from the date of this letter, this firm wiII obtain and provide you with written verification thereof; otherwise the debt will be assumed to be valid. Likewise if requested within thirty three (33) days from the date of this letter, the firm will send you the name and address of the original creditor if different from above. Very truly yours, Matt Huerta Asset Manager Account No.: COW0643PA Mailed by 1".Class mail and by certified Mail No: 7006 2760 0005 0979 7595 w a- Ln N 70FFICIA?LTS?E? m r- s c t&d r.. o Ran ` two 13 ?oaV«y 0 Total Poe Lpe & SM $ n, 0 _0 L7 arPOSwN& I%- ?-spa-?-- = s MIDWEST FIRST FINANCIAL, LPX moll 11904ARBORSTREET, SUITE 200 PUSrr OMAHA, NEBRASKA 88141 ,. Mi.UA1LEOFR0M'Z1PCO1 • ? / ??? 7QD6. 2760 0005 0979 7588 02 1A $-05.320 0004353003 AUOOQ 2008 x R. .88144 a .. wn UNCLA DATZ: August 6, 2008 V / Christopher J Cowodd Spring VaUey Lane • ?,? L - , Mechm1csburg,PA 17055 - - 13f 4ee44 - , 20 IN" MIDWtST FIRST FINANCIAL; LPIZ 11904ARgpR?E?SUITE200 DMAHA.NEBRA8KA88144 Iwo 7006 0 0005 0979 7595 02 IA $ 05.320 OD04353003 A0000 2008 . ! MAILEDFROM.ZIPCODE 88144 DATE: August 6, 2008 FO' Jill A. Cowosid 6 Spring Valley Lane Mechanicsburg, PA 19055 C! UN Viv% OO ? ? t _ c_-? S y Cj T cs? ? ?r' t a Vti p ? ?_? c,7 "j SHERIFF'S RETURN - REGULAR ` CASE NO: 2008-06556 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDWEST FIRST FINANCIAL LP IV VS COWOSKI JILL A ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COWOSKI CHRISTOPHER J the DEFENDANT , at 0915:00 HOURS, on the 8th day of November-, 2008 at 6 SPRING VALLEY LANE MECHANICSBURG, PA 17055 by handing to CHRISTOPHER COWOSKI 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 1i?1 P?D.- 00 16 00 Sworn and Subscibed to before me this day So Answers: ! Thomas Kline 11/12/2008 GOLDBECK MCCAFFERTY MCKE VE By: Deputy Sheriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-06556 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDWEST FIRST FINANCIAL LP IV VS COWOSKI JILL A ET AL MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COWOSKI JILL A DEFENDANT , at 0915:00 HOURS, on the 8th day of November , 2008 at 6 SPRING VALLEY LANE MECHANICSBURG, PA 17055 CHRISTOPHER COWOSKI, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. the by handing to Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.00 .00 10.00 .00 So Answers: ,.oOp K2 R. Thomas Kline ;/ 39.00 Sworn and Subscibed to before me this day 11/12/2008 GOLDBECK MCCAFFERTY M KEE R By. Deput Sheriff of , A. D. In the Court of Common Pleas of Cumberland County MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-6556 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 JILL A. COWOSKI and CHRISTOPHER J. COWOSKI by default for want of an Answer. Assess damages as follows: Debt Interest from 02/05/2009 to Date of Sale per diem at $36.66 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM I certify that written notice of the intention to file this praecipe was mailed or delivered to is to be entered and to his attorney of record, if any, after the default occurred and at lea filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T.q Attorney I.D. #5V29 AND NOW S" , - .2J MIDWEST FIRST FINANCIAL LP I and against JILL A. C want of an Answer and damages assessed in the sum of $150,2 $150,214.22 ALLEGED TO *hom judgment the date of the , Judgment is entered in favor of )PHER J. COWOSKI by default for as per the bove certification. rothonota v"1 Q s M y p y- ALL! Z v N r Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagors and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) No. 08-6556 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-caption tter t red against you. above-captioned It Lon Prothonotary -7 By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 72251FC 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 JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 TO: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-6556 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 A 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 LU X co O o. cr-I 72251FC 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: CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 TO: CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-6556 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 ge, C-.1 Ci j H 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, CHRISTOPHER J. COWOSKI, is about unknown years of age, that Defendant's last known residence is 6 Spring Valley Lane Mechanicsburg, PA 17055, and is engaged in the unknown business locatt unknown address. 2. That Defendant is not in the Military or Naval Servi/off the United States or its Allies, or otherwise within the provisions of the Soldiers' an/Y ilors' Civil Relief Action of Congress of 1940 and its Amendments. Date: A VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. That the above named Defendant, JILL A. COWOSKI, is about unknown years of age, that Defendant's last known residence is 6 Spring Valley Lane Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Servjee' of tke' United States or its Allies, or otherwise within the provisions of the Soldiers' ap& SaiVrs' Civil Relief Action of Congress of 1940 and its Amendments. Date: wO LO co L'i 2-1 s, cmr% ? N G? 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-6556 ORDER FOR JUDGMENT Please enter Judgment in favor of MIDWEST FIRST FINANCIAL LP IV, and against COWOSKI and CHRISTOPHER J. COWOSKI for failure to file an Answer in the above acti (or sixty (60) days if defendant is the United States of America) from the date of service of e sum of $150,214.22. Michael T. McKeever Attorney for Plaintiff, I hereby certify that the above names are correct and that the prec' e residence address creditor is MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street uite 200 Omaha, N name(s) and last known address(es) of the Defendant(s) is/are JILL . COWOSKI, 6 Spri g Mechanicsburg, PA 17055 and CHRISTOPHER J. COWOSKI, 6 Spring Valley Lane e an GOLDBECK N BY: Michael T. Attorney foyPl TY (20) days nt, in the and that the PA 1705.x; ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $131,959.60 Interest from 06/01/2008 through $9,128.33 02/04/2009 Reasonable Attorney's Fee $6,597.98 Late Charges $469.19 Costs of Suit and Title Search $900.00 Escrow Payments Due 3 X $132.02 Escrow Advance AND NOW, this pr' day of`. 20( 4"A" M; Pro gothy c r ? a4 e r? 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6556 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 02/05/2009 to Date of Sale per diem at $36.66 (Costs to be added) $150.214.22 r ? x T UV N N fi C ti v C o ? `o MR- C= W Lw`/ ? 0 d 7 ? x v O r N a ? w W ? ?, 00 GL ? O ? ?? U ? ? w D': y ? ..- a ? ? a- w ti o w ? 3 x ? d x Q P64 y r N ? w Y O 67 Q` C`3 y y "? N d r+ .`? ? N 1 ? V Y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-6556 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDWEST FIRST FINANCIAL LP IV Plaintiff (s) From JILL A COWOSKI - CHRISTOPHER J COWOSKI 6 SPRING VALLEY LANE MECHANICSBURG PA 17055 (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 $ 150,214.22 L.L.$0.50 Interest FROM 2/05/2009 TO DATE OF SALE PER DIEM AT $36.66 Atty's Comm % Atty Paid $174.00 Plaintiff Paid Date: FEBRUARY 5, 2009 (Seal) REQUESTING PARTY: Name MICHAEL T MCKEEVER ESQUIRE Address: SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET, PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Due Prothy $2.00 Other Costs AJ1110 Cur R. Long, P ary By: Deputy Telephone: (215) 627-1322 Supreme Court ID No. 56129 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-6556 MIDWEST FIRST FINANCIAL LP IV, 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: 6 Spring Valley Lane Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 C'7 0 tM C,:.. C? •f G.? GOLDBECK McCAFFERTV & 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 08-6556 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s Term No. 08-6556 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: COWOSKI, JILL A. JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 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 $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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; A 08-6556 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-6556 08-6556 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention 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 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 72251FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. C7 ° xi G un CO 08-6556 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-6556 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: COWOSKI, CHRISTOPHER J. CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 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 $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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: 08-6556 I r 08-6556 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.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.oriz/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 72251 FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. tit. C-n r?7 C .J ,-} FTl Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-6556 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of r I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has Act. the aintiff in this action, and l ith all the provisions of the Michael T. Attorney ft -'; 2 . SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 6 Spring Valley Lane Mechanicsburg, PA 17055 SOLD as the property of JILL A. COWOSKI and CHRISTOPHER J. COWOSKI TAX PARCEL #42-29-2454-255 ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT # 75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #77 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255 k 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 72251 FC CF: 11/05/2008 SD: 06/10/2009 $150,214.22 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff VS. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 08-6556 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 Offico4ew4getent .. lt(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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 4 -- oo N m •N r 6 ° •- s? __ a G o ????jM(1 0 0 ? E Q q A a a CL ?? m? K a 3S S ? a a v -- ? c _ z p ?U ? J a Q LU Q LL EE in H Wm ? tE w cc Of Fn ? ? O?? ti 0 - m 42 r U') c U Q w r- N ~ a ty ty O LL LL 0 CL O CL Z Lh 0 a ~ C Q B z : M _a 47 ? r na q 4? E Z5 V? w _ GO w co t W) < U r- U m 3 O - Ma f-a Z Q C? !2 N e N > a U v u'? ? k x? 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O c U -i N y w o c p=, IL c) c p[ N ?C W G n U ch U- O O M U U U,- 0 U-) J N V) J C14 .. =; In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-6556 Civil Term Midwest First Financial LP IV Vs Jill A. Cowoski and Christopher J. Cowoski Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2009 at 1712 hours, she 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: Jill A. Cowoski and Christopher J. Cowoski, by handing both to Jill A. Cowoski, personally and as wife of Christopher J. Cowoski, at, 6 Spring Valley Lane, Mechanicsburg, Ctunbaiand County, Pennsylvania its cmitwts and at the same time hwong to her personally the said true and correct copy of the same. Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 0913 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jill A. Cowoski and Christopher J. Cowoski, located at, 6 Spring Valley Lane, Mechanicsburg, Cumberland County Pennsylvania, according to law. Thomas Kline, Sherif& 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: Jill A. Cowoski and Christopher J. Cowoski, by regular mail to their last known address of, 6 Spring Valley Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of April 2, 2009 and never returned to the Sheriffs Office So Answers, e R. Thomas Kline, Sheriff By 01 4, ?oct Real Estate Coordinator GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 08-6556 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 MIDWEST FIRST FINANCIAL LP IV, 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: 6 Spring Valley Lane Mechanicsburg, PA 17055 I.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 a CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MIDWEST FIRST FINANCIAL, LIMITED PARTNERSHIP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION, INC. 2411 Rolling Hills Drive Mechanicsburg, PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg, PA 17055 (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 'I, RY 2:1109 IiAAY 2 Atli 0. 5 1 In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-6556 Civil Term Midwest First Financial LP IV Vs Jill A. Cowoski and Christopher J. Cowoski T ;;!,.Y r 4 Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2009 at 1712 hours, she 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: Jill A. Cowoski and Christopher J. Cowoski, by handing both to Jill A. Cowoski, personally and as wife of Christopher J. Cowoski, at, 6 Spring Valley Lane, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 0913 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jill A. Cowoski and Christopher J. Cowoski, located at, 6 Spring Valley Lane, Mechanicsburg, Cumberland County Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Jill A. Cowoski and Christopher J. Cowoski, by regular mail to their last known address of, 6 Spring Valley Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of April 2, 2009 and never returned to the Sheriffs Office R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 17.28 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Milage 21.60 Levy 15.00 Surcharge 30.00 Post Pone Sale 20.00 Law Journal 355.00 Patriot News Share of Bills So Answers R. Thomas Kline, Sheriff 1 C By loo--j Real Estate Coordinator 344.42 15.43 881.23 ? ?»? s/oc?a9 N C? Ck 'Vj 7 J Aa'12 88'73 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-6556 MIDWEST FIRST FINANCIAL LP IV, 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: 6 Spring Valley Lane Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 r Carlisle, PA 17013 MIDWEST FIRST FINANCIAL, LIMITED PARTNERSHIP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 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 6 Spring Valley Lane Mechanicsburg, PA 17055 (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 m erso knowle?ge or information and belief. I understand that false statements herein are made subject to the pe ties o 8 Pa. Section 4904 relating to unsworn falsification to authorities. DATED: February 4, 2009 r GOLDBECK McC ,YFERTY BY: Michael T. eever, Esq. Attorney for PI ' tiff 08-6556 GOLDBECK WCAFFERTY & 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s Term No. 08-6556 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: COWOSKI, JILL A. JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 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 $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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: 08-6556 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: htip://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-6556 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. 08-6556 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.orjZ/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 72251FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 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 08-6556 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) Term No. 08-6556 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: COWOSKI, CHRISTOPHER J. CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 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 $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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: 08-6556 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, 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. I . 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: ham://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 Carlisle, PA 17013 717-243-9400 08-6556 08-6556 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. hp fa.org/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(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 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 72251 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED INACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT # 75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH' 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #77 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 6 Spring Valley Lane Mechanicsburg, PA 17055 SOLD as the property of JILL A. COWOSKI and CHRISTOPHER J. COWOSKI TAX PARCEL #42-29-2454-255 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-6556 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDWEST FIRST FINANCIAL LP IV Plaintiff (s) From JILL A COWOSKI - CHRISTOPHER J COWOSKI 6 SPRING VALLEY LANE MECHANICSBURG PA 17055 (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 $ 150,214.22 L.L.$0.50 Interest FROM 2/05/2009 TO DATE OF SALE PER DIEM AT $36.66 Atty's Comm % Arty Paid $174.00 Plaintiff Paid Date: FEBRUARY 5, 2009 Due Prothy $2.00 Other Costs C ;1s. Lo ono (Seal) REQUESTING PARTY: Name MICHAEL T MCKEEVER ESQUIRE Address: SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET, PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 56129 By: Deputy Real Estate Sale # 40 04 February 13, 2009 the Sheriff levied upon the N r' dceTendant's interest in the real property situated in vi- _ L$per Allen Township, Cumberland County, PA CO LLJ F Down and numbered as 6 Spring Valley Lane, Mechanicburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 13, 2009 &"?"/ By; O'_ 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. r a Marie Coyne, EPor SWORN TO AND SUBSCRIBED before me this day of May. 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 i11AliAi. AIA" 110. 40 Writ No. 2008-6556 Civil Midwest First Financial LP IV VS. Jill A. Cowosld and Christopher J. Cowosld Atty.: Michael T. McKeever ALL THAT CERTAIN tract or parcel of land situate in Upper Al- len Township, Cumberland County, Pennsylvania, shown as Lot #76, Phase II, Bowman's Hill as described in accordance with the Final Subdivi- sion Plan of Bowman's Hill Phase II recorded in Cumberland County Plan Book 68, Page 15, more particularly described as follows, to wit: BEGINNING at a point on the northern right-of-way line of Spring Valley Lane, a 50 foot right-of-way, at the southwestern corner of Lot #77 on the aforementioned plan, thence along said northern right-of- way line of Spring Valley Lane South 65 degrees 05 minutes 43 seconds West a distance of 85.46 feet to a point at the southeastern corner of Lot # 75 on the aforementioned plan; thence along said Lot #75 North 24 degrees 54 minutes 17 seconds West a distance of 116.12 feet to a point at the southern line of lands now or formerly of Keeneth R. White and Martha C. White; thence along said lands now or formerly of White North 63 degrees 53 minutes 50 seconds East a distance of 85.48 feet to a point at the northwestern corner of Lot #77 on the aforementioned plan; thence along said Lot #77 South 24 degrees 54 minutes 17 seconds East a distance of 117.91 feet to a point and place of BEGINNING. CONTAINING 10,000 square feet. IMPROVEMENTS consist of a residmfial dwelling. BEING PREMISES: 6 Spring Valley Lane, Mechanicsburg, PA 17055. SOLD as the property of JILL A. COWOSKI and CHRISTOPHER J. COWOSKI. TAX PARCEL #42-29-2454-255. '*The Patriot-News Co. . 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patr1*otwXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/24/09 05/01/09 ..... ......... Sworn to a s. cribed before me this 12 day of May, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisner, Notary Public City Of Harrisburg, Dauphin County My Commission Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries 05/08/09 Reef Eats" Sde NO. 40 Wilt No. 20064M Ct 4tTWM MI ivast first IMr+ancW LP IV VS Jill A. Cowo*W,artd Christopher J. Cowoskl Attorney MIdwI T. McKeever LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE` IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDMSION PLAN OF BOWMAN'S HILL PHASE H RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT BEGINNING AT A POINT ON THE NORTHERN RIGHT-0F-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT- OF-WAY, AT THE- SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT OF WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT #75 ON THE AFOR ME MONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINEM 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO. A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE 'AND MARTHA C. WHITE,, THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THBAFOREMENTIONED ' PLAN; THENCE ALONG SAID LOT #77 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINMG, CONTAINING 10,000 SQUARE FEET. IMPROVEMENTS consist of a residyntial dwelling. BEING PREMISES: 6 Spring Valley Lane, Mechanicsburg, PA 17055 SOLD as the property of JILL A. COWOSKI and CHRISTOPHER J. COWOSKI TAX PARCEL #42-29-2454-255 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.RC.P 3180-3183 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6556 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 02/05/2009 to Date of Sale per diem at $36.66 (Costs to be added) $150,214.22 G DBECK Mc FERTY & McKEEVER XY: Michael T. McKeever Attorney for Plaintiff W > ^ F > " r y V N O U X30 ?? w c ? ? ? ? ?oN 0 VIE 00 ow-o> Q y a? ?n c, 0 U of Za w Qoa, C c ?oN v? ti O w °on a w u o a o?a a ©" a C-) ZD LL- a -? o00Vt0 00 fn C6 cv V 4 c * 0o y: 4 9 ? 1? C6 ?9 C6 t- t" ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT 977 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT # 75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #77 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255 PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MECHANICSBURG, PA 17055 MUNICIPAITY: UPPER ALLEN TOWNSHIP BEING THE SAME PREMISES WHICH DAVID R. THOMPSON AND DENISE P. THOMPSON, HUSBAND AND WIFE, BY DEED DATED 10/13/1998 AND RECORDED 10/20/1998 IN DEED BOOK 187 AT PAGE 501, GRANTED AND CONVEYED UNTO CHRISTOPHER J. COWOSKI AND JILL A. COWOSKI, HUSBAND AND WIFE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. Term No. 08-6556 ACTION OF MORTGAGE FORECLOSURE JILL A. COWOSKI CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JILL A. COWOSKI AND CHRISTOPHER J. COWOSKI Your house (real estate) at (address) 6 Spring Valley Lane Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff s Sale on (date): U J(time): 10:00 a.m. (place of sale): Commissioners Hearing Room - 2nd floor, Cumberland County Courthouse to enforce the court judgment of $150,214.22, obtained by the judgment creditor against you. IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE 111"RICT OF PENNSYLVANIA IN RE: Christopher Cowoski Debtor MIDWEST FIRST FINANCIAL LP IV Moving Party VS. Christopher Cowoski Jill A. Cowoski Debtor (Co-Debtor) CHAPTER 13 NO.1-09-bk-04401 MDF Charles J. DeHart, III Esq. I 11 U.S.C. Section 362 and 1301 Trustee 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. 11 U.S.C. Sections 362 and 1301 (if applicable), are modified to allow MIDWEST FIRST FINANCIAL LP IV and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriffs Sale regarding the premises 6 Spring Valley Lane Mechanicsburg, PA 17055 and a possessory action if necessary. The stay provided by Bankruptcy Rule 4001(a)(3) has been waived. 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 via telephone or written correspondence to offer such an agreement. By the Cowl, Dated: December 21, 2009 B J VG) This document is ekctropacagy signed and filed' on the same date. Case 1:09-bk-04401-MDF Doc 48 Filed 12/21/09 Entered 12/22/0916:24:09 Desc Main Document Page 1 of 1 0 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff VS. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-6556 MIDWEST FIRST FINANCIAL LP IV, 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: 6 Spring Valley Lane Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: FRED-4Ot rRac OF THE PROTHONOTARY 2010 JAN -7 PM 3: 08 CUM k-=«.;w'qu COUNTY PENNSYLVWA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 ,N 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 MIDWEST FIRST FINANCIAL, LIMITED PARTNERSHIP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION, INC. 2411 Rolling Hills Drive Mechanicsburg, PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: January 6, 2010 .DBECK McCAFFERTY & McKEEVER Michael T. McKeever, Esq. rney for Plaintiff /k 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 08-6556 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s Term No. 08-6556 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: COWOSKI, JU-L A. JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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: f 08-6556 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, 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 1-866413-2311. 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: bZ://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-6556 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretentionkpoldbecklaw.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 72251FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. .. 08-6556 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff VS. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s Term No. 08-6556 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: COWOSKL CHRISTOPHER J. CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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: i 08-6556 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, 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. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd 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: httn://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 i 08-6556 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.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/eonsumers/homeowners/real.gpx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 72251 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6556 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDWEST FIRST FINANCIAL LP, IV, Plaintiff (s) From JILL A. COWOSKI and CHRISTOPHER J. COWOSKI (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 $150,214.22 L.L. Interest from 2/5/09 to Date of Sale per diem at $36.66 -- To be Determined Atty's Comm % Atty Paid $1,076.73 Plaintiff Paid Date: 1/07/10 Due Prothy $2.00 Other Costs r David D. Buell, Prothonotary (Seal) REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 By: Deputy 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 2010 K,`A'i 21 PH 1: U'y cutvi MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff VS. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 08-6556 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/ (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: Keith C. Halil° Legal Secretary 72251 FC CF: 11/05/2008 SD: 06/02/2010 $150,214.22 COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE of o: o? 0 C3 TAN r sN•-o ?O4U a rv CD X O t tO CO ? N g v Lu 6 o o3tnan _ N o Q o o ? {mot T e- tne 7,u?'A o r w g ? 5 b ° am7SAS H xmil§z a2 13 s as W a Z Z w a RU _ ¢ cn ? Y W op w W CD E J e z U V a Z DODD u j o v O to w Z a v to z N ¢ W 2 o d' O Om o Z O Z O WW rg CO (L ? J D W r- 32y Of - a EX co co l z S L m - i a a° a u~iw W Y z ) c? V '. m O S vii X d 3 MCI Z om N ao ooo? 2 D m o m E I ® E 3 3 E O V) Y> u) OOO at oc)m0 ¢ 3 amt ¢ = ?a tn0 m d ¢av? ko u? 0 W¢ J o- ao >? =M z w? co m z u) W ¢ o ?a co Q ?V(DoY? LU ID W Lo LO ED OW z 0:D o= N ch L6 cD ti m C7 [n F- n- m C O C Cm G m w Q v Q. m m ug E `o d a ?E 0 a8 CL oa F d' li Z m p C CL CL y c 0 o. m C i C H ffi C) u o N N C) Y/ II^^ m V! Q ?: A o U U a N w `O C d o O 04 (Q C] N ? U L, C a C 7 .n U cn L° O 1 O oa+°r U U Lt_ ¢ L U. J N J to C14 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor (1-10to at +Gap?d t Kk OFF49OF rK? S14V Midwest First Financial LP, IV vs. Case Number Jill A Cowoski (et al.) 2008-6556 SHERIFF'S RETURN OF SERVICE 04/0612010 02:43 PM - Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on 4/6/10 at 1443 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 Jill A. Cowoski and Christopher J. Cowoski, located at, 6 Sprinc Valley Lane, Mechanicsburg, Cumberland County, Pennsylvania according to law. 04/06/2010 02:43 PM - Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on 4/6/10 at 1443 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Jill A. Cowoski, by making known unto, Christopher J. Cowoski, spouse, at, 6 Spring Valley Lane, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 04/06/2010 02:43 PM - Noah Cline, Deputy Sheriff, who being duly swam according to law, states that on 4/6/10 at 1443 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Christopher J. Cowoski, by making known unto, Christopher J. Cowoski, personally, at, 6 Spring Valley Lane, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same SHERIFF COST: $908.42 April 20, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) Go wrtysuHe S.",e R, Teeoso". iix:. GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 08-6556 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 MIDWEST FIRST FINANCIAL LP IV, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 6 Spring Valley Lane Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MIDWEST FIRST FINANCIAL, LIMITED PARTNERSHIP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION, INC. 2411 Rolling Hills Drive Mechanicsburg, PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 19, 2010 GOLDBECK McC ERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F;. Sheriff Jody S Smithy Chief Deputy tt;?', -r ( j s AND qua, ? ?t t ? ? DIF? J h Richard W Stewart Solicitor OFFICE (r ', 6MtERIFF LVi' !y Midwest First Financial LP, IV Case Number vs. Christopher & Jill Cowoski (et al.) 2008-6556 SHERIFF'S RETURN OF SERVICE 04/06/2010 02:43 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1443 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 Jill A. Cowoski and Christopher J. Cowoski, located at, 6 Sprint Valley Lane, Mechanicsburg, Cumberland County, Pennsylvania according to law. 04/06/2010 02:43 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1443 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Jill A. Cowoski, by making known unto, Christopher J. Cowoski, spouse, at, 6 Spring Valley Lane, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 04/06/2010 02:43 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1443 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Christopher J. Cowoski, by making known unto, Christopher J. Cowoski, personally, at, 6 Spring Valley Lane, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same 06/01/2010 Property sale postponed to 8/4/2010. 07/27/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney McKeever on 7/22/10 SHERIFF COST: $783.02 July 29, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF . 5.0 L'j jqo- 4k.4 7N1i4 '' ) ?? 16 (c) CountySuite Shenff, Teleosoft. Inc. • 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-6556 AFFIDAVIT PURSUANT TO RULE 3129 MIDWEST FIRST FINANCIAL LP IV, 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: 6 Spring Valley Lane Mechanicsburg, PA 17055 I.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 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 • ` V 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 MIDWEST FIRST FINANCIAL, LIMITED PARTNERSHIP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION, INC. 2411 Rolling Hills Drive Mechanicsburg, PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: January 6, 2010 1Jt$t4-,& MCC;APFERTY & McKEEVER Michael T. McKeever, Esq. -ney for Plaintiff 1 4 08-6556 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) Term No. 08-6556 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: COWOSKI, JILL A. JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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: 08-6556 1. The gale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, 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 1-866413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-6556 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orp-/consumers/homeowners/real.qWx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 72251 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT # 75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT 477 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID 4:42-29-2454-255 PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MECHANICSBURG, PA 17055 MUNICIPAITY: UPPER ALLEN TOWNSHIP BEING THE SAME PREMISES WHICH DAVID R. THOMPSON AND DENISE P. THOMPSON, HUSBAND AND WIFE, BY DEED DATED 10/13/1998 AND RECORDED 10/20/1998 IN DEED BOOK 187 AT PAGE 501, GRANTED AND CONVEYED UNTO CHRISTOPHER J. COWOSKI AND JILL A. COWOSKI, HUSBAND AND WIFE. • 08-6556 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 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s, Term No. 08-6556 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: COWOSKI, CHRISTOPHER J. CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV 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: 08-6556 1. The stile will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP 1V, 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 1-866413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: hM://www philadelphiafed orgJforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-6556 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www. hfa.org/consumers/homeowners/real aVx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretentionkp-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 72251 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT # 75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT 977 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT 977 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255 PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MECHANICSBURG, PA 17055 MUNICIPAITY: UPPER ALLEN TOWNSHIP BEING THE SAME PREMISES WHICH DAVID R. THOMPSON AND DENISE P. THOMPSON, HUSBAND AND WIFE, BY DEED DATED 10/13/1998 AND RECORDED 10/20/1998 IN DEED BOOK 187 AT PAGE 501, GRANTED AND CONVEYED UNTO CHRISTOPHER J. COWOSKI AND JILL A. COWOSKI, HUSBAND AND WIFE. k WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-6556 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDWEST FIRST FINANCIAL LP, IV, Plaintiff (s) From JILL A. COWOSKI and CHRISTOPHER J. COWOSKI (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 $150,214.22 L.L. Interest from 2/5/09 to Date of Sale per diem at $36.66 -- To be Determined Atty's Comm % Atty Paid $1,076.73 Pl ' ff P d Date: 1/07/10 Due Prothy $2.00 Other Costs amti aid (Seal) REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 J? David D. Buell, Protho tary By: Deputy Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 ; . f e On March 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered, 6 Spring Valley Lane, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: Real Estate Coordinator I Z .Z d l l Ntlf O?OZ ?xjja 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: April 16, April 23, and April 30, 2010 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. f C/I sa Marie Coyne/Editor SWORN TO AND SUBSCRIBED before me this da of April, 2010 Notary NOTARIAL SEAL KIOWACOUM No" N& AftW 00W". CUMOERLANO COW" My CQrAb" b0m Apr 40.2014 Wff t so. 28804 ? C_ Midwest First Financial LP, IV VS. Jill A. Cowoski Christopher J. Cowoski Atty. Michael McKeever ALL THAT CERTAIN tract or parcel of land situate in Upper Al- len Township, Cumberland County, Pennsylvania, shown as Lot #76, Phase II, Bowman's Hill as described in accordance with the final subdivi- sion plan of Bowman's Hill Phase II recorded in Cumberland County Plan Book 68, Page 15, more particularly described as follows, to wit: BEGINNING at a point on the northern right-of-way line of Spring Valley Lane, a 50 foot right-of-way, at the southwestern corner of Lot #77 on the aforementioned plan, thence along said northern right-of- way line of Spring Valley Lane South 65 degrees 05 minutes 43 seconds West a distance of 85.46 feet to a point at the southeastern corner of Lot # 75 on the aforementioned plan; thence along said Lot #75 North 24 degrees 54 minutes 17 seconds West a distance of 116.12 feet to a point at the southern line of lands now or formerly of Keeneth R. White and Martha C. White; thence along said lands now or formerly of White North 63 degrees 53 minutes 50 seconds East a distance of 85.48 feet to a point at the northwestern corner of Lot #77 on the aforementioned plan; thence along said Lot #77 South 24 degrees 54 minutes 17 seconds East a distance of 117.91 feet to a point and place of BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255. PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MECHANICSBURG, PA 17055. MUNICIPAITY: UPPER ALLEN TOWNSHIP. BEING THE SAME PREMISES which David R. Thompson and Denise P. Thompson, husband and wife, by deed dated 10/13/1998 and recorded 10/20/1998 in Deed Book 187 At Page 501, granted and conveyed unto Christopher J. Co- wood and Jill A. Cowoski, husband and wife. Er ZN1JJ03 A €1AA0890 3#1009 V14jo#1 NalA"'" ,H01 "d ]JOIJIM3 SS 10 tsigx3 no,ssimmo0 YM The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-295-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patriot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 she 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 she 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: 04/16/10 04/23/10 04/30/10 Sworn to and ubscribed before me ttYfs 18 ay of May, 2010 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Klsner, Notary Public Lower Paxton Tep., OaupNn County My Commission Expires Nov. 26, 2011 Member, PennsYlvanla Association of Notaries Wyk No. 900"659 MA Term 460w6a Rkst FkwwW LP, IV Vsr Jill A CciuJoskl , Chrlstophsr J Cowosld My: Mlahssl McKeever ALL THAT CERTAIN tract or parcel of land situate • n. Upper Allen Township, Cumberland County,- Pennsylvania, shown as LOT #76, PHASE 11,-BOWMAN'S HILL as described in accordance with the final subdivision plan of BOWMAN'S HILL PHASE U recorded in Cumberland County Plan Book 68„Page 15, more particularly described as follows, to wit: BEGINNING at a point on the northern right-of- way line of String Valley Lane, a50 foot right-of- way, at the Southwestern Comer of lot #77 on the aforementioned Plan, thence along said northern right-of-way line of Spring Valley Lane South 65 degrees 05 minutes 43 seconds west a distance of 85.46 Feet to a point at the Southeastern comer of lot # 75 on the aforementioned plan; thence' along said lot #75 north 24 degrees 54 minutes 17 seconds west adistance of 116,12 Feet to a point at the southern be of lands now or formerly of Keeneth R. White and,Marft C. White; thence along said hinds now or formerly of White North 63 degrees 53 minutes 50 seconds easta distance of 85.48 Feet to apoint at the Northwestern comer of lot.#77 on the aforementioned plan; thence along said lot #77 south 24 degrees 54 minutes 17 seconds east a distance of 117.91 Feet to a point and place of beginning. CONTAINING 10,000 SQUARE FEET TAX ID #: 42-29-2454-255 PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MBCHANICSBURG, PA 17055 Mumcipaity: UPPER ALLEN TOWNSHIP Being the same premises which david R. Thompson And Denise P. Thompson, husband and wife, by deed dated 10/1311998 and recorded 1W O/1998 in Deed Book 187 at Page 501, . VatiWmdowmyW meta mrie"LCowodd and Jill A. Cowodd, huAW and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-6556 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDWEST FIRST FINANCIAL LP IV Plaintiff (s) From JILL A. COWOSKI AND CHRISTOPHER J. COWOSKI (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 $150,214.22 L.L. Interest FROM 2/5/2009 to Date of Sale per diem at $36.66 Atty's Comm % Due Prothy $2.00 Atty Paid $1,883.75 Other Costs Plaintiff Paid Tate: 3/4/11 i D vid D. Buell, Pr thonotary (Seal) By: REQUESTING PARTY: Name: GARY MCCAFFERTY, ESQUIRE Address: GOLDBECK, MCCAFFERTY & MCKEEVER SUITE 5000- MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 42386 Deputy • PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Goldbeck, McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 IN THE COURT OF COMMON PLEAS Omaha, NE 68144 VS. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 02/05/2009 to Date of Sale per diem at $36.66 (Costs to be added) O ojw{.agy,64pd a 30i to cap t (a.o0 0 I. a3 4. so ++•, DOvu Oct r. ay. oo ++ 8g15.75 Id a By: of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6556 rr, CU " M - a 7D C. r -<> 1 ?- 'Z.J r ? --? CD . ? CD -r C) p,C ?? c s C)rr; $150,214.22 GO ECI ACCAFFERTY MCKEEVER Michael c 9 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 4 a, oa cAe Co. VJ4 of ex Tssum z Q E., ? W U o ¢ X30° w h ??cv ?o C) Z cC ?• 0 ¢ U0 F? ,p v O q3 c? a Q, b N M- v.. a y 00 00 0W^:$> x 40 3 `d v, " ca p ate4 Qo ti nn p U U Ex-+ A ? z 0-4 A» ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT # 75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #77 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255 PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MECHANICSBURG, PA 17055 MUNICIPAITY: UPPER ALLEN TOWNSHIP BEING THE SAME PREMISES WHICH DAVID R. THOMPSON AND DENISE P. THOMPSON, HUSBAND AND WIFE, BY DEED DATED 10/13/1998 AND RECORDED 10/20/1998 IN DEED BOOK 187 AT PAGE 501, GRANTED AND CONVEYED UNTO CHRISTOPHER J. COWOSKI AND JILL A. COWOSKI, HUSBAND AND WIFE. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff F;LE:')-OFF1CL k,, I vlE JPRDTHONOTARN'. 2011 APR -4 Ate 10: 253 CUMBERLAND COUNTY %I& MIA MIDWEST FIRST FINANCIAL LP N 11904 Arbor Street IN THE COURT OF COMMON PLEAS Suite 200 Omaha, NE 68144 f Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-6556 MIDWEST FIRST FINANCIAL LP IV, Plaintiff in the above action, by counsel, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 6 Spring Valley Lane Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: o Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MIDWEST FIRST FINANCIAL, LIMITED PARTNERSHIP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION, INC. 2411 Rolling Hills Drive Mechanicsburg, PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg, PA 17055 (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 information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: March 29.2011 By: 4DBEC2 CCAFFERTY MCKEEVER Micha ver Pa. 29 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 08-6556 GOLDBECK McCAFFERTY & McKEEVER Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP N 11904 Arbor Street Suite 200 Omaha, NE 68144 "I ;- FI r ; . r ROTHONOTAR` . 2011E - AM 10, 2 CUMBERLA.D COUt4TY IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s; Docket No. 08-6556 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: COWOSKI, JILL A. JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, 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 1-866413-2311. CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 08-6556 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: hqp•//www hin iladelphiafed org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-6556 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.oriz/consumers/homeowners/real.qVx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongizoldbecklaw 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 72251 FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor L" 1 N 0 30 PM 1. 27 in,IJMuFiLAi%0 Ca.)'T4T 'r PENNSYLVANIA Midwest First Financial LP, IV vs. Jill A Cowoski (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2008-6556 06/2012011 03:03 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 6 Spring Valley Lane, Mechanicsburg, PA 17055, Cumberland County. 06/27/2011 09:01 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Christopher J Cowoski at 6 Spring Valley Lane, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 06/2712011 09:01 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be CHRISTOPHER COWOSKI - HUSBAND, who accepted as "Adult Person in Charge" for Jill A Cowoski at 6 Spring Valley Lane, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 08/25/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 10/5/2011 10/05/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 12/7/2011 11/2912011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $843.54 SO ANSWERS, 6Z '`" November 30, 2011 RON R ANDERSON, SHERIFF '.oiP? J ll `. ;P.? ( TPt . So'( 1r7;. 1 Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street IN THE COURT OF COMMON PLEAS Suite 200 Omaha, NE 68144 of Cumberland County Plaintiff VS. CIVIL ACTION - LAW JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) No. 08-6556 AFFIDAVIT PURSUANT TO RULE 3129 MIDWEST FIRST FINANCIAL LP IV, Plaintiff in the above action, by counsel, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 6 Spring Valley Lane Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MIDWEST FIRST FINANCIAL, LIMITED PARTNERSHIP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION, INC. 2411 Rolling Hills Drive Mechanicsburg, PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg, PA 17055 (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 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: March 29. 2011 By: /1 11-11' N LDBEC CCAFFERTY MCKEEVER Micha ver Pa. 29 Gary McCafferty Pa. ID 42386L.--" Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 08-6556 GOLDBECK McCAFFERTY & McKEEVER Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s; of Cumberland County CIVIL, ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 08-6556 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: COWOSKI, CHRISTOPHER J. CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP N, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. IN THE COURT OF COMMON PLEAS 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 08-6556 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 11F 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: hiip://www.philadelphiafed.oreforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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. 08-6556 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit. Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hqp://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 72251FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-6556 GOLDBECK McCAFFERTY & McKEEVER Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s, of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 08-6556 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: COWOSYL JILL A. JILL A. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Your house at 6 Spring Valley Lane, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $150,214.22 obtained by MIDWEST FIRST FINANCIAL LP IV against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. IN THE COURT OF COMMON PLEAS 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 08-6556 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: hq://www.philadelphiafed.orWforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 j' 08-6556 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orgLconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 72251FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE H, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT # 75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE SOUTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETH R. WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #77 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255 PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MECHANICSBURG, PA 17055 MUNICIPAITY: UPPER ALLEN TOWNSHIP BEING THE SAME PREMISES WHICH DAVID R. THOMPSON AND DENISE P. THOMPSON, HUSBAND AND WIFE, BY DEED DATED 10/13/1998 AND RECORDED 10/20/1998 IN DEED BOOK 187 AT PAGE 501, GRANTED AND CONVEYED UNTO CHRISTOPHER J. COWOSKI AND JILL A. COWOSKI, HUSBAND AND WIFE. WRIT OF EXECUTION and/or ATTACHMENT i, COMMONWEALTH OF PENNSYLVANIA) N008-6556 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDWEST FIRST FINANCIAL LP IV Plaintiff (s) From JILL A. COWOSKI AND CHRISTOPHER J. COWOSKI (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 $150,214.22 L.L. Interest FROM 2/5/2009 to Date of Sale per diem at $36.66 Atty's Comm % Due Prothy $2.00 Atty Paid $1,883.75 Other Costs Plaintiff Paid Date: 4/4/11 O..D Buell, Prot onotary (Seal) By: Deputy REQUESTING PARTY: Name: GARY MCCAFFERTY, ESQUIRE Address: GOLDBECK, MCCAFFERTY & MCKEEVER SUITE 5000- MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 TRUE COPY FROM RECORD In Testimony whereck I lure unto set my hand and the seal of said Cwt KCerflsle, Pa. This _-?L-day of .20 11 Prothonotary Supreme Court ID No. 42386 On May 11, 201 1 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered as, 6 Spring Valley Lane, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 11, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2008-6556 Civil Midwest First Financial LP, IV vs. Jill A. Cowoski Christopher J. Cowoski Atty.: Michael McKeever ALL THAT CERTAIN tract or parcel of land situate in Upper Al- len Township, Cumberland County, Pennsylvania, shown as Lot #76, Phase II, Bowman's Hill as described in accordance with the final subdivi- sion plan of Bowman's Hill Phase II recorded in Cumberland County Plan Book 68, Page 15, more particularly described as follows, to wit: BEGINNING at a point on the northern right-of-way line of Spring Valley Lane, a 50 foot right-of-way, at the southwestern corner of Lot #77 on the aforementioned plan, thence along said northern right-of- way line of Spring Valley Lane South 65 degrees 05 minutes 43 seconds West a distance of 85.46 feet to a point at the southeastern corner of Lot # 75 on the aforementioned plan; thence along said Lot #75 North 24 degrees 54 minutes 17 seconds West a distance of 116.12 feet to a point at the southern line of lands now or formerly of Keeneth R. White and Martha C. White; thence along said lands now or formerly of White North 63 degrees 53 minutes 50 seconds East a distance of 85.48 feet to a point at the northwestern corner of Lot #77 on the aforementioned plan; thence along said Lot #77 South 24 degrees 54 minutes 17 seconds East a distance of 117.91 feet to a point and place of BEGINNING. CONTAINING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255. PROPERTY ADDRESS: 6 SPRING VALLEY LANE, MECHANICSBURG, PA 17055. MUNICIPAITY: UPPER ALLEN TOWNSHIP. BEING the same premises which David R. Thompson and Denise P. Thompson, husband and wife, by deed dated 10/ 13/ 1998 and record- ed 10/20/1998 in Deed Book 187 at Page 501, granted and conveyed unto Christopher J. Cowoski and Jill A. Cowoski, husband and wife. 18 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: July 15, July 22 and July 29, 2011 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. L Li Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this da of Jul 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suites300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE ?latr ?o!•.?Cews Nov'yoL 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 Holiy Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the law s of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 30C, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News ar J The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County an( 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 n their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither shE nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of th s statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify th s statement on. beha,i of he Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted .everaily by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Reci riling 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 I Below: 07/15/11 07/22/11 "_R 07/29111 Sworn to andsubscribed be?obre me t is pfAugust, 2011 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Sherrie L Kisrw, Notary Public i_ower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 201 a. ?t ether "ennsvivania As' elation of Nota*ies 20094M CkV Team Adweet Pffa M LR IV Vs Jill A Cowoski Christopher J Cowoskl Attr Michael McKeever All That Certain Tract Or Parcel Of Land Situate In Upper Allen Township, Cumberland County, Pennsylvania, Shown As Lot #76, Phase k ban's Silt As Described In Accordance With The Final Subdivision Plan Of Bowman's Hill Phase Ii Recorded In Cumberland County Plan Book 68, Page 15, More Particularly Described As Follows, To Wit: Beginning At A Point On The Northern Right-Of-Way Line Of Spring Valley Lane, A 50 Foot Right-Of-Why, At The Southwestern Corner Of Lot #77 On The Aforementioned Plan, Thence Along Said Northern Right- Of-Way Line Of Spring Valley Lane South 65 Degrees 05 Minutes 43 Seconds West A Distance Of 85.46 Feet To A Point At The Southeastem Comer Of Lot # 75 On The Aforementioned Plan; Thence Along Said Lot #75 North 24 Degrees 54 Minutes 17 Seconds West A Distance Of 116.12 Feet To A Point At The Southern Line Of Lands Now Or Formerly Of Keeneth R. White And Martha C. White; Thence Along Said Lands Now Or Formerly Of White North 63 Degrees 53 Minutes 50 Seconds Fast A Distance Of 85.48 Feet To A Point At The Northwestern Comer Of Lot #77 On The Aforementioned Plan; Thence Along Said Lot #77 South 24 Degrees 54 Minutes 17 Seconds East A Distance Of 119:91 Feet To A Point And Place Of Beginning. Containing 10,000 Square Feet. Tare Id #: 42-29-2454-255 Property Address: 6 Spring Valley Lane, Mechanicsburg, Pa 17055 Municipaity: Upper Allen Township Being The Same Premises Which Dated R, Thompson And Denise P Thompson, Hi.sbaud And Wife, By Deed Dated 10113/1998 And Recorded 1012011948 In Deed Book 187 At Page 501, Granted And Conveyed Unto Clristopher J, Cowoski And Jill A. Cwroeld, Hind And Wife.