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Home My WebLink About08-6858GA14 r% OLDBECK 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE STRUCTURED ASSET INVESTMENT LOAN TRUST, 2004-11 4650 Regent Blvd Irving, TX 75063 Plaintiff VS. CHRISTINA A. JONES TORREY K. JONES Mortgagors and Record Owners 12 Maple Avenue Walnut Bottom, PA 17266 Defendants IN THE COURT OF I OMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ?c JTerm N Q , Uk5f CIVIL ACTION: MORTGAGE po"MOSURF 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 TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, RSTA 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 WILL BE USED FOR THE PURPOSE OF CO i E TMG THE DEBT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website ho://www.nhfa.orconsumers/homeowners I . 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 homeretentionna ?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 71641FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE STRUCTURED ASSET INVESTMENT LOAN TRUST, 2004-11, 4650 Regent Blvd, Irving, TX 75063. 2. The names and addresses of the Defendants are CHRISTINA A. JONES, 114 South Main Street, Marysville, PA 17053 and TORREY K. JONES, 114 South Main Street, Marysville, PA 17053, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On March 17, 2004 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to TRIBECA LENDING CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1858, Page 2539. The mortgage has been assigned to: LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE STRUCTURED ASSET INVESTMENT LOAN TRUST, 2004-11 by assignment of Mortgage September 24, 2008 as Document # 200832309. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance .................................................. $81,270.90 Interest from 04/01/2008 through 09/30/2008 at 11.6250%0 .....................$4,736.03 Per Diem interest rate at $25.88 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,063.55 Late Charges from 05/01/2008 to 09/30/2008 .............................................$207.04 Monthly late charge amount at $41.41 Costs of suit and Title Search ......................................................................$900.00 Real Estate Taxes .........................................................................................$515.28 Fees ................................................................................................................$40.00 Recoverable Balance ........................................................................................$7.00 Monthly Escrow amount $237.80 $91,739.80 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. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $91,739.80, together with interest at the rate of $25.88, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I,L'jYlfS /ZGT Fa/ as the officer for American Home Mortgage Servicing, Inc. successor in interest to Option One Mortgage Corporation of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: l D -V f ci , -- American Home Mortgage Servicing, Inc. successor in interest to Option One Mortga Corporation G OLsA ,q - 0013793872 CHRISTINA A. JONES and TORREY K. JONES ExhibitA . Sep 09 2008 2:33PM HP LRSERJET 3330 P.29 SCMOIDDl,E "An ALL TEAT CBRTAIN LOT OY OROtAID, WITH IMPpAVWIBIIlB 171Ri081 BRBCM, SITQi1TB IN TBB VILLim 03P JACRDONVILIMP am= BMW TORNSH,IP, C018BR7JAM .COUNTY, PBNNMVANIA, Rome= AND DWMIBBD AS VOLLOKBi 320118F G AT A POST IN TBB SAWMILL ROAD; TBHACB ALOW SAID ROAD NORTN 41 DBOiR = NUT, 10 PBRCIQB TO A POST: THBNCB BY LAND 90VTH 35 3/4 DHGRBBB NAW, 16.4 PBRCNNS TO A POBT; THBNCB BY LAND SOVM 4 DRORHBS BAST, 10 PBRCHBS TO A POST; THBNCB NCV= 35 3/4 DBORNBS BAST, 16.4 PBRCNNS TO THE PLAC! 07 BS1liMMn=. SAID LOT CONTAINING 1 ACRB, MORN OR LBBB KITH IMPROVEPOW i. SOURCR OF TITLN: BOOK 117 PADS 819 (RNCORDBD 05/22/1998) APN: 41-31-2230-009 03/04/2004 09:25:09 (Blizaboth Congoa] I Certify this to be recorded In Cumberland County PA Recorder of Deeds BK 1 BSSPG2555 VMP2W4 11:6&'38 AM CUMBERLAND couWTV hatt 206410747 . Popp 17 of 20 Exhibit 0 o % ol a- 100 N wo??, ?x x h OV O ? ? p Q O w ? O CD M co n n gNo r S Vi- Z>= Wm> 0 o cm' O w? 9 D V - N 9 co 4 o R! Ill O r t Ln a 'o! 8 co N N IN ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COPRENDE 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 PROBRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. FORECLOSURE 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. July 17, 2008 Christina A Jones 12 Maple Ave Walnut Bottom, PA 17266-9701 Homeowners Name: Torrey K Jones Christina A Jones Property Address: 12 Maple Ave, Walnut Bottom PA 17266 Loan Account No.: 0013793872 Original Lender: OPTION ONE MORTGAGE CORPORATION Current Lender/Servicer: American Home Mortgage Svc. Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to OP820 (Page 1 of 9) , I a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice, or you may find them by visiting the website at http://www.phfa.org/ applications/counseling_agencies.aspx. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions to schedule one face-to-face meeting. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. (Page 2 of 9) OP820 015 R36 YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. (Page 3 of 9) OP821 011 R36 1 Re: Loan No. 0013793872 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 12 Maple Ave, Walnut Bottom PA 17266 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments: 3 MONTHS @ $ 1,066.03 MONTHS @ $.00 3 (b) Previous late charges; $ 198213.13 (c) Other charges; Escrow, Inspection, NSF checks $ .00 (d) Other provisions of the mortgage obligation, if any $ 0.00 (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 3411.22 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): OP822 (Page 4 of 9) HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $3411.22, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Overnight Mail Address American Home Mortgage Svc.Inc. 4600 Regent Blvd., Suite 200 Irving, TX 75063-1730 Western Union Quick Collect Pay to: American Home Mortgage Svc. Code City: Option,Ca Code State: California You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable.) (Page 5 of 9) OP822 020 R36 Eli Re: Loan No. 0013793872 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. OP823 (Page 6 of 9) Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (6) SIX Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. (Page 7 of 9) OP823 013 R36 F51- Re: Loan No. 0013793872 HOW TO CONTACT THE LENDER: Name of Lender: American Home Mortgage Servicing, Inc. Address: 4600 Touchton Road East Bldg 200 Ste 102 Attn: Trivonda Porter, Sara Haliko and Selena Moore Address: Jacksonville, FL 32246 Phone Number: 877-304-3100 Fax Number: 1-866-497-1263 Contact Persons: Trivonda Porter, Sara Haliko and Selena Moore Office hours: Monday through Friday 8:00 a.m. to 5:00 p.m. EST Email Address: PHFA@OOMC.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: * 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 CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT 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. OP824 (Page 8 of 9) * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS DOES NOT IMPLY THAT AHMSI IS ATTEMPTING TO COLLECT MONEY FROM ANYONE WHOSE DEBT HAS BEEN DISCHARGED UNDER THE BANKRUPTCY LAWS OF THE UNITED STATES. (Page 9 of 9) OP824 032 R36 M y J a ra N O Ls t q J .? 7 m GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE STRUCTURED ASSET INVESTMENT LOAN TRUST, 2004-11 4650 Regent Blvd Irving, TX 75063 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. CHRISTINA A. JONES TORREY K. JONES 12 Maple Avenue Walnut Bottom, PA 17266 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 08-6858 By: y&4t/'/ /N16AAC GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF C 0 N Vim) cl ! SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-06858 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS JONES CHRISTINA A ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: JONES CHRISTINA A but was unable to locate Her in his bailiwick He therefore County, Pennsylvania, to deputized the sheriff of PERRY serve the within COMPLAINT - MORT FORE On December 23rd , 2008 , this office was in receipt of the attached return from PERRY Sheriff's Costs: So answers: Docketing 6.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kline Dep Perry County 52.40 Sheriff of Cumberland County Postage 3.55 80.95 12/23/2008 GOLDBECK MCCAFFERTY MCKEEVER Sworn and subscribe to before me this day of A. D. ' :-? ?-.? -- ? - c:? ._.., ..?? J??? S !,7i _r ,.7 '" ..C3 ?+ ,.,?- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-06858 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS JONES CHRISTINA A ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT JONES TORREY K but was unable to locate Him deputized the sheriff of PERRY to wit: in his bailiwick. He therefore serve the within COMPL,4TMT - Mnv- -nnn County, Pennsylvania, to On December 23rd , 2008 , this office was in receipt of t attached return from PERRY Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 00 So answers- "r R. Thomas Kline Sheriff of Cumberland County 16.00 12/23/2008 GOLDBECK MCCAFFERTY MCKEEVER Sworn and subscribe to before me this day of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-06858 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS JONES CHRISTINA A ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JONES CHRISTINA A DEFENDANT the at 1200:00 HOURS, on the 21st day of November , 2008 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 JANE ADAMS, ATTORNEY FOR by handing to CHRISTINA A JONES a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 12/23/2008 GOLDBECK MCCAFFERTY MCKEEVER By: <- kc,? Deputy S riff of A.D. ?.y ?_ } t I?. ?? '. ?,k. ..?. ? ? ?. 9 ??? 6 E„?"! r? . . f? "` SHERIFF'S RETURN - REGULAR CASE NO: 2008-06858 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS JONES CHRISTINA A ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JONES TORREY K DEFENDANT the , at 1835:00 HOURS, on the 18th day of December , 2008 at 627 HOOT OWL ROAD BOILING SPRINGS, PA 17007 TORREY JONES by handing to 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: So Answers: Docketing 6.00 Service 19.80 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 35.80 12/23/2008 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: '- before me this day De tY sheriff of A.D. - 3 w rt -1 - ? :?`N- ; tit ?• _ .. r::^; GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE STRUCTURED ASSET INVESTMENT LOAN TRUST, 2004-11 4650 Regent Blvd Irving, TX 75063 Plaintiff VS. CHRISTINA A. JONES TORREY K. JONES 12 Maple Avenue Walnut Bottom, PA 17266 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 08-6858 PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: only. Kindly mark the above case Settled, Discontinued and Ended upon payment of your costs i rhAt hA (Aft M C L T. MC EVER, ESQUIRE rn CO