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Home My WebLink About08-7261v/ GOLDBECK McCAFFERTY & McKEEVER 13Y: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff VS. SHARON L. YINGER Mortgagor and Record Owner 8 South Road Mechanicsburg, PA 17050 Defendant Term 01-VI t ?)toCIVIL AftON: MO GAGE FOP77"' OSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website bqp://www.phfa.org/consumers/homeowners/real.gwx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: httt)://www.vhiladelDhiafed.orp-/foreclosure/ 7). 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 homeretentionOgoldbecklaw.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 76237FC. 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 WACHOVIA MORTGAGE CORPORATION, PO Box 900001, 1100 Corporate Center Drive Raleigh, NC 26707-5066. 2. The names and addresses of the Defendant is SHARON L. YINGER, 8 South Road, Mechanicsburg, PA 17050, who is the mortgagor and record owner of the mortgaged premises hereinafter described. On June 14, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC AS NOMINEE FOR WACHOVIA MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1911, Page 0294. The mortgage has been assigned to: WACHOVIA MORTGAGE CORPORATION by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$146,004.12 Interest from 06/01/2008 through 12/31/2008 at 5.8750% .......................$5,029.00 Per Diem interest rate at $23.50 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$7,300.21 Late Charges from 07/01/2008 to 12/31/2008 .............................................$269.57 Monthly late charge amount at $44.93 Costs of suit and Title Search ......................................................................$900.00 Escrow Advance ...................................................... ....................................$662.01 Pro Rata MIP/PMI ................................................... ....................................$197.48 Fees .......................................................................... ......................................$33.00 NSF Charges ............................................................ ......................................$15.00 Recoverable Balance ................................................ ....................................$872.00 Monthly Escrow amount $284.87 $161,282.39 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 Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit `B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $161,282.39, together with interest at the rate of $23.50, 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 anSale of the Property. By: W/ G LDBECK McCAFF McKEEVER BY: MICHAEL T. MCKEE R, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: l?o? Mi ael T. McKe ver, Esquire I.D. #56129 E.x.hibitA • , EXHIBIT "A" ALL THAT CERTAIN tract of ground with the improvements thereon erected, situate in the TOWNSHIP OF SILVER SPRING, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Northern line of South Road at the North corner of Lot No. 34 on the hereinafter mentioned Plan of Lots; thence by the dividing line between Lots Nos. 33 and 34, North sixty- three (63) degrees fifty-four (54) minutes West, one hundred twenty- five (125) feet to a point; thence by the dividing line between Lot No. 33 and Lots Nos. 27 and 28, North twenty-six (26) degrees six (06) minutes East, one hundred (100) feet to a point; thence by the dividing line between Lots Nos. 32 and 33 on said plan, South sixty- three (63) degrees fifty-four (54) minutes East, one hundred twenty- five (125) feet to a point on the Northern line of South Road; thence by the Northern line of South Road, South twenty-six (26) degrees six (06) minutes Wes, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 33 in the Plan of Lots known as Northfield Farms which Plan is of record in the Cumberland County Recorder's Office in Plan Book 8, Page 22, plan also recorded in Plan Book 7, Page 37. BEING known and numbered as 8 South Road. BEING the same premises which Carrie R. Alexander, widow, by Deed bearing the date of 14th day of June, 202005, and about. to be herewith recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, Pennsylvania, granted and conveyed unto Sharon L. Yinger. UNDER AND SUBJECT TO restrictions and conditions as now appear of record. Parcel No. 38-22-0144-039 I Certify this to be recorded In Cumberland County PA Recorder of " nV 191 I PG 0 310 E.)(hibit (B Wachovia Mortgage, FSB Post Office Box 900001 1100 Corporate Center Drive Raleigh, North Carolina 27675-9000 Raleigh, North Carolina 27607-5066 ? ACHOVIA SHARON L YINGER 8 SOUTH ROAD MECHANICSBURG, PA 17050 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM F ORECLOSURE September 3, 2008 This is an offi ial notice that the mort a e on our home is in default an d the lend r intends to foreclose. Specific information about the nature of the default is provided in the attached Rages. The HOMEOWNERIS MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can hel you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with ou when ou meet the Counseling Agency. The name address and hone number of Consumer Credit Counseling Agencies servin¢ your Counri are listed at the end of this Notice If you have any questions you may call the Pennsylvama Housing Finance Agency toll free at 1 800 342 2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO [HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM?EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Mortgagor SHARON L YINGER Co-mortgagor Property Address 8 SOUTH ROAD MECHANICSBURG, PA 17050 Loan Number 0005739462 Original Lender Current Lender/Servicer Wachovia Mortgage, FSB HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE EACTQ, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED EIOW 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 thhi (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in 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® Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner® Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it 0 to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 8 SOUTH ROAD, MECHANICSBURG, PA 17050 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Start/End: 07/01/2008 through 09/01/2008 at $1,183.45 per month. Total Amount of Delinquent Payments Due $ 3,550.35 Late Charges 89.86 Property inspections and NSF check charges, if any 15.00 Recoverable Corporate Advances 0.00 Other charges accrued, if any 0.00 LESS: Suspense (unapplied funds) - 0.00 LESS: Previously Posted - 0 TOTAL AMOUNT OF DELINQUENCY $ 3,655.21 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 3,655.21, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier® check, certified check or money corder made payable and sent to: Wachovia Mortgage, FSB, Attention: Payment Processing, 1100 Corporate Center Drive, Raleigh, NC 27607-5066. IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. The means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure upon your mortgage property. IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney [A fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys fees actually incurred by the lender even if they exceed $50.00. Any attorney N 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 N 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 ES SALE-If you have not cured the default o within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ri It cure the default and prevent the sale at any time up to one hour before the Sherin Sale You may do so by paying the total amount then past due plus an y late or other charges then due, reasonable attorney ® fees and costs connected with the foreclosure sale and any other costs connected with the Sherin Sale as Vecified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFFS SALE DATE-It is estimated that the earliest date that such a Sherif" 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 THE LENDER: Wachovia Mortgage, FSB Attention: Servicing Operations 1100 Corporate Center Drive Raleigh, NC 27607-5066 Phone: (800) 688-9224 Fax: 866/260-3962 Contact: Steve Kennedy EFFECT OF SHERIFF IS SALE-You should realize that a Sheriff[ 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 Sheriffl? Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may or may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and attomeyl§ fees and cost are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED Sent by Regular Mail, Certificate of Mailing (PS Form 3877), and Certified Mail Sincerely, s&M ?""4 Steve Kennedy Servicing Operations Wachovia Mortgage, FSB BLPA01 c ? ?? ley --, ?- , c? r r ? rn ? ? Ott ? 3 .? SHERIFF'S RETURN - REGULAR CASE NO: 2008-07261 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WACHOVIA MORTGAGE CORPORATION VS YINGER SHARON 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 YINGER SHARON L the DEFENDANT , at 1845:00 HOURS, on the 30th day of December-, 2008 at 8 SOUTH ROAD MECHANICSBURG, PA 17050 by handing to SHARON BOWERS (YINGER) a true and attested copy of COMPLAINT - MORT FORE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of together with So Answers: 00, R. Thomas Kline 12/31/2008 GOLDBECK MCCAFFERTY MCKFOIF, 18.00 8.10 .00 10.00 .00 36.10 day By: A. D. y `Sheri f f 1.J °t M tJ, Y-?R w: GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 VS. SHARON L. YINGER Mortgagor(s) and Record Owner(s) 8 South Road Mechanicsburg, PA 17050 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 08-CIVIL-7261 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to Plaintiff's Complaint filed on December 12, 2008 in the above captioned matter. GOLDBECK McCAFFERTY & McKEEVER BY: IVY 1??C a - Michael T. McKeever Attorney for Plaintiff -: GOLDBECK McCAFFERTY & McKEEVER Professional Corporation ATTORNEY FOR PLAINTIFF By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 VS. SHARON L. YINGER Mortgagor(s) and Record Owner(s) 8 South Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 08-CIVIL-7261 CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiffs Praecipe to Substitute Verification to Plaintiffs Complaint was served on Defendant(s) via first class mail on February 26, 2009 as follows: SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever Attorney for Plaintiff VERIFICATION I, 6Weft* un M. ai?'?i? as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: ?2 /S OS 41?qd #76237FC - SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 ?'? c _ s <J _ ?° w ? ?,? ? ? i'.; ' rr ? ? c'xz? ? 1 i ? ,? .. ,.. y In the Court of Common Pleas of Cumberland County WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff vs. SHARON L. YINGER (Mortgagor(s) and Record Owner(s)) 8 South Road Mechanicsburg, PA 17050 Defendant(s) No. 08-CIVIL-7261 PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against SHARON L. YINGER by default for want of an Answer. Assess damages as follows: Debt Interest from 02/20/2009 to Date of Sale per diem at $23.50 Total (Assessment of Damages attached) $162,832.12 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW Feb 010` 01009 , Judgment is entered in favor of WACHOVIA MORTGAGE CORPORATION and against SHARON L. YINGER by default for want of an Answer and damages assessed in the sum of $162,832.12 as per the above certification. P othonotary 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, SHARON L. YINGER, is about unknown years of age, that Defendant's last known residence is 8 South Road Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: (`j .i 76237FC 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: January 20, 2009 TO: SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 VS. SHARON L. YINGER (Mortgagor(s) and Record Owner(s)) 8 South Road Mechanicsburg, PA 17050 TO: SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 Defendant(s) Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-CIVIL-7261 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 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff V& IN THE COURT OF COMMON PLEAS of Cumberland County SHARON L. YINGER (Mortgagor(s) and Record owner(s)) 8 South Road Mechanicsburg, PA 17050 Defendant(s) CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 08-CIVIL-7261 ORDER FOR JUDGMENT Please enter Judgment in favor of WACHOVIA MORTGAGE CORPORATION, and against SHARON L. YINGER for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $162,832.12. Z 11: ? ?/- --? Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 and that the name(s) and last known address(es) of the Defendant(s) is/are SHARON L. YINGER, 8 South Road Mechanicsburg, PA 17050; Z??- GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff i ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 06/01/2008 through 02/19/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 1 X $284.87 Escrow Advance Pro Rata MIP/PMI Fees NSF Charges Recoverable Balance $146,004.12 $6,204.00 $7,300.21 $359.43 $900.00 $284.87 $662.01 $197.48 $33.00 $15.00 $872.00 $162,832.12 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 0 day of C& 2009 damages are assessed as above. Pr rothy y ?°n let voi i Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff No. 08-CIVIL-7261 VS. SHARON L. YINGER (Mortgagors and Record Owner(s)) 8 South Road Mechanicsburg, PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-caption tte,-`r b e d against you. urt Long Prothonotary By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff vs. SHARON L. YINGER Mortgagor(s) and Record Owner(s) 8 South Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-CIVIL-7261 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 02/20/2009 to Date of Sale per diem at $23.50 (Costs to be added) $162,832.12 GOLDB CK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ?• ? O W O O N ? w H Q HUO H °7xr' ti/ Q U y H U z Q ~ 3 m H O O r W O r, cod bA Z ; 9 O c ?t+ t)b i? ZI O ~ W ? W O ? i C O ? W 1 T ' UQ P4 a N• H N U H U ?p U y O rte' .-? n+ Q M y ? cd o O Ica N ? O P•+ 0 V -b? 00 iA+ d 00 -TI -M, Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 vs. SHARON L. YINGER Mortgagor(s) and Record Owner(s) 8 South Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-CIVIL-7261 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Plaintiff Defendant(s) Michael T. McKeever Attorney for plaintiff ? ? i? C .rte ,a ? , r~, ?? r z ? -?-, ?_ ?Y ? {`? Goldbeck McCafferty & McKeever BY: Michael. T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW SHARON L. YINGER (Mortgagor(s) and Record Owner(s)) 8 South Road Mechanicsburg, PA 17050 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-CIVIL-7261 AFFIDAVIT PURSUANT TO RULE 3129 WACHOVIA MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 8 South Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7261 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WACHOVIA MORTGAGE CORPORATION, Plaintiff (s) From SHARON L. YINGER (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 gamishee(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 $162,832.12 L.L. $.50 Interest from 2/20/09 to Date of Sale per diem at $24.50 Atty's Comm % Due Prothy $2.00 Atty Paid $155.10 Other Costs to be Added Plaintiff Paid Date: 2/20/09 Curtis R. e?g1 thoc tary (Seal) By; Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, 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. 56129 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.456129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 76237FC CF: 12/12/2008 SD: 06/10/2009 $162,832.12 WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff vs. SHARON L. YINGER Mortgagor(s) and Record Owner(s) 8 South Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-CIVIL-7261 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ?Q Personal Service by the Sheriffs Office%etnpetetttati?f(copy of return attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( } Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff r cc 4 x y U N U D N 8 z zl C U _ c n =nPie '$; 1 U = 0 yy ? It mn > ? tggt y 4 rnw 00 o N dD °Wo IL N p O ? k q? v rr n 10 1 0 o g r mot a;R CL wg w? m `O co rx a CL W Q Z 6 V y jQ J'_'N W U p U DODO o ce LL ? a r ? 02 O Q) z v am CO O M E p g? J w o 0 co OOOOO w . : H w m w fjo f: a: L) U I 'o b m r N ?f ? > r S , ? ly y AR ?9i06 \ z' co o a < c~n Q aYO?a j WaCLUJ co 0 ? OUJ§< + I z05z ?y v) PC_) a.- M to I? co mm a 0 Q E .m+ a r a o. 0 CL m `o c € S a • . o ? o ? O a c ? o CL O a ? Ea w U ?? a v i N m Q X = E U Z o o LL i 5 ? t N Q Z t A m Q ? (? In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-7261 Civil Term Wachovia Mortgage Corporation Vs Sharon L. Yinger R. Thomas Kline, Sheriff, who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Sharon L. Yinger, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within, Real Estate Writ of Execution, Notice of Sheriff's Sale of Real Property and Legal Description, according to law. York County Return, And now, the 27`h day of March, 2009, served the within, Real Estate Writ, Notice of Sheriff's Sale, Legal Description, upon Sharon L. Bowers, f/k/a Sharon L. Yinger, at, 1210 York Haven Road, Apartment 2, York Haven, Pennsylvania its contents and at the same time handing to her a true and correct copy of the same. So Answers; Richard Keuerleber, Sheriff, York County, Pennsylvania Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1326 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 Sharon L. Yinger, located at, 8 South Road, Mechanicsburg, Cumberland County Pennsylvania, according to law. So Ans R. Thomas Kline, Sheriff By I ReaCla t e Coordinator GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. SHARON L. YINGER Mortgagor(s) and Record Owner(s) 8 South Road Mechanicsburg, PA 17050 ACTION OF MORTGAGE FORECLOSURE Term No. 08-CIVIL-7261 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 WACHOVIA MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 8 South Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SHARON L: YINGER 8 South Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 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: MEMBERS 1 ST FEDERAL CREDIT UNION 5000 Louise Drive Mechanicsburg, PA 17055 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 8 South Road Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: May 27, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff i -,r H, y A, 10: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND f SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which FANNIE MAE is the grantee the same having been sold to said grantee on the 10TH day of JUNE A.D., 2009, under and by virtue of a writ Execution issued on the 20TH day of FEB, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 7261, at the suit of WACHOVIA MTG CORP against SHARON L YINGER is duly recorded as Instrument Number 200922892. IN TESTIMONY WHEREOF, I have hereunto set my hand an eal of said office this day of (LZ /? , A.D. / of Deeds How; i ?. nuti<"W E)0; c 1h;, RW hey of Jan.3®tg In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-7261 Civil Term Wachovia Mortgage Corporation Vs Sharon L. Yinger R. Thomas Kline, Sheriff, who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Sharon L. Yinger, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within, Real Estate Writ of Execution, Notice of Sheriff's Sale of Real Property and Legal Description, according to law. York County Return, And now, the 27th day of March, 2009, served the within, Real Estate Writ, Notice of Sheriff's Sale, Legal Description, upon Sharon L. Bowers, f/k/a Sharon L. Yinger, at, 1210 York Haven Road, Apartment 2, York Haven, Pennsylvania its contents and at the same time handing to her a true and correct copy of the same. So Answers; Richard Keuerleber, Sheriff, York County, Pennsylvania Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1326 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 Sharon L. Yinger, located at, 8 South Road, Mechanicsburg, Cumberland County Pennsylvania, according to law. R.Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Sharon L. Yinger, by regular mail to her last known address of, 1210 York Haven Road, Apartment 2, York Haven, PA 17370. This letter was mailed under the date of April 14, 2009 and never returned to the Sheriffs Office R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 10, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of Fannie Mae of P.O. Box, 650043, Dallas, TX 75265-0043 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $ 1,031.85. Sheriff's Costs: Docketing 30.00 Poundage 20.23 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 4 IF Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Milage 18.00 Levy 15.00 Surcharge 20.00, Deputize York County 52.70 Out of County 9.00 Law Journal 371.00 Patriot News 315.49 : Share of Bills 15.43' Distribution of Proceeds 25.00 Sheriff's Deed 49.50 1,031.85 So Answers, op, R. Thomas Kline, Sheriff By A Real Estate Coordinator v 'I Pak .z sa 1 J 7 S-s/ Goldbeck McCafferty & McKeever BY_ Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WACHOVIA MORTGAGE CORPORATION PO Box 900001 1 100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff VS. SHARON L. YINGER (Mortgagor(s) and Record Owner(s)) 8 South Road Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-CIVIL-7261 WACHOVIA MORTGAGE CORPORATION; Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 8 South Road Mechanicsburg, PA 17050 I Name and address of Owner(s) or Reputed Owner(s): SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 4. Name and address of the last recorded holder of every mortgage of record: r -MEMBERS 1 ST FEDERAL CREDIT UNION 5000 Louise Drive Mechanicsburg, PA 17055 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 8 South Road Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) 1 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: February 19, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 08-CIVIL-7261 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.456129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WACHOVIA MORTGAGE CORPORATION PO Box 900001 1100 Corporate Center Drive Raleigh, NC 26707-5066 Plaintiff vs. SHARON L. YINGER Mortgagor(s) and Record Owner(s) 8 South Road Mechanicsburg, PA 17050 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-CIVIL-7261 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: YINGER, SHARON L. SHARON L. YINGER 8 South Road Mechanicsburg, PA 17050 Your house at 8 South Road, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $162,832.12 obtained by WACHOVIA MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WACHOVIA MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. IN THE COURT OIF 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. ALL THAT CERTAIN tract of ground with the improvements thereon erected, situate in the TOWNSHIP OF SILVER SPRING, County of Cumberland and State of Pennsylvania, bounded and described as follows, wit: BEGINNING at a point on the Northern line of South Road at the North corner of Lot No. 34 on the hereinafter mentioned Plan of Lots; thence by the dividing line between Lots Nos. 33 and 34; North sixty three (63) degrees fifty-four (54) minutes West, one hundred twenty five (125) feet to a point; thence by the dividing line between Lot No. 33 and Lots Nos. 27 and 28, North twenty-six (26) degrees six (06) minutes East, one hundred (100) feet to a point; thence by the dividing line between Lots Nos. 32 and 33 on said plan, South sixty-three (63) degrees fifty-four (54) minutes East, one hundred twenty five (125) feet to a point on the Northern line of South Road; thence by the Northern line of South Road, South twenty-six (26) degrees six (06) minutes West, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 33 in the Plan of Lots known as Northfield Farms which Plan is of record in the Cumberland County Recorder's Office in Plan Book 8, Page 22, plan also recorded in Plan Book 7, Page 37. BEING known and numbered as 8 South Road. BEING the same premises which Carrie R. Alexander, widow, by Deed bearing the date of 14`x' day of June, 202005, and about to be herewith recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, Pennsylvania, granted and conveyed unto Sharon L. Yinger. UNDER AND SUBJECT TO restrictions and conditions as now appear of record TAX PARCEL #: 38-22-0144-039 BEING KNOWN AS: 8 South Road, Mechanicsburg, PA 17050 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7261 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WACHOVIA MORTGAGE CORPORATION, Plaintiff (s) From SHARON L. YINGER (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 $162,832.12 L.L. $.50 Interest from 2/20/09 to Date of Sale per diem at $24.50 Atty's Corn % Due Prothy $2.00 Arty Paid $155.10 Other Costs to be Added Plaintiff Paid Date: 2/20/09 Curtis R. L4 g, Prot ho otary 9 (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, 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. 56129 Real Estate Sale # 60 On February 27, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Silver Springs Township, Cumberland County, PA Known and numbered as 8.South Road, Mechanicsburg, More fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 27, 2009 By 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. Pla Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 5 day of May, 2009 : A", C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 60 Writ No. 2008-7261 Civil Wachovia Mortgage Corporation VS. Sharon L. Yinger Atty.: Michael T. McKeever ALL THAT CERTAIN tract of ground with the improvements there- on erected, situate in the TOWNSHIP OF SILVER SPRING, County of Cum- berland and State of Pennsylvania, bounded and described as follows, wit: BEGINNING at a point on the Northern line of South Road at the North corner of Lot No. 34 on the hereinafter mentioned Plan of Lots; thence by the dividing line between Lots Nos. 33 and 34; North sixty three (63) degrees fifty-four (54) minutes West, one hundred twenty five (125) feet to a point; thence by the divid- ing line between Lot No. 33 and Lots Nos. 27 and 28, North twenty-six (26) degrees six (06) minutes East, one hundred (100) feet to a point; thence by the dividing line between Lots Nos. 32 and 33 on said plan, South sixty-three (63) degrees fifty- four (54) minutes East, one hundred twenty five (125) feet to a point on the Northern line of South Road; thence by the Northern line of South Road, South twenty-six (26) degrees six (06) minutes West, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 33 in the Plan of Lots known as Northfield Farms which Plan is of record in the Cumberland County Recorder's Office in Plan Book 8, Page 22, plan also recorded in Plan Book 7, Page 37. BEING known and numbered as 8 South Road. BEING the same premises which Carrie R. Alexander, widow, by Deed bearing the date of 14th day of June, 202005, and about to be herewith re- corded in the Office of the Recorder of Deeds, in and for the County of Cum- berland, Pennsylvania, granted and conveyed unto Sharon L. Yinger. UNDER AND SUBJECT TO re- strictions and conditions as now appear of record. TAX PARCEL #: 38-22-0144- 039. BEING KNOWN AS: 8 South Road, Mechanicsburg, PA 17050. 4 ,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 ZhtPatriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stocKholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/24/09 05/01/09 05/08/09 ......._1. ?-?... .. ..... . Sworn to a bribed before me thi 12ia f May, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisser, Notary Public CRY Of Harrisburg; Dauphin county My Commission Expires Nov. 26.2011 Member, Pennsylvanla Association of Notaries Real Estate Sale No. 60 Writ No. 2008-7261 Civil Term Wachovia Mortgage Corporation VS Sharon L.Yinger Attorney Michael T. McKeever LEGAL DESCRIPTION ALL THAT CERTAIN tract of ground with the improvements thereon erected, situate in the TOWNSHIP OF SILVER SPRING, County of Cumberland and State of Pennsylvania, bounded and described as follows, wit: BEGINNING at a point on the Northern line of South Road at the North comer of Lot No. 34 on the hereinafter mentioned Plan of Lots; thence by the dividing line between Lots Nos. 33 and 34; North sixty three (63) degrees fifty-four (54) minutes West, one hundred twenty five (125) feet to a point; thence by the dividing line between Lot No. 33 and Lots Nos. 27 and 28, North twenty-six (26) degrees six (06) minutes East, one hundred (100) feet to a point; thence by the dividing line between Lots Nos. 32 and 33 on said plan, South sixty-three (63) degrees fifty-four (54) minutes East, one hundred twenty five (125) feet to a point on the Northern line of South Road; thence by the Northern line of South Road, South twentv-six (26) decrees six (06) minutes West, one hundred (100) feet to a point, the place of BEGINNING. BEING Lot No. 33 in the Plan of Lots known as Northfield Farms which Plan is of record in the Cumberland County Recorder's Office in Plan Book 8, Page 22, plan also recorded in Plan Book 7, Page 37. BEING known and numbered as 8 South Road. BEING the same premises which Carrie R. Alexander, widow, by Deed bearing the date of 14th day of June 20, 2005, and about to be herewith recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, Pennsylvania, granted and conveyed unto Sharon L. Ynger. UNDER AND SUBJECT TO restrictions and conditions as now appear of record TAX PARCEL #: 38-22-0144-039 BEING KNOWN AS: 8 South Road, Mechanicsburg, PA 17050