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Home My WebLink About09-0619GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 VS. FRANK E. COOVER Mortgagor and Record Owner 19 Wyrick Avenue Shippensburg, PA 17257 Plaintiff Term e l v No. D q - w y CIVIL ACTION: "V COFiT GAGiE LrCLtURE Defendant 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 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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, 0 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, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.asRx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/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 homeretentionna,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825-6411. Please reference our Attorney File Number of 77741FC. 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 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007- AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2, 10801 6th Street, Suite 130 Rancho Cucamonga, CA 91730. 2. The names and addresses of the Defendant is FRANK E. COOVER, 19 Wyrick Avenue, Shippensburg, PA 17257, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On October 05, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to ARGENT MORTGAGE COMPANY LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book: 1969 Page: 798. The mortgage has been assigned to: US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007- AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 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 August 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 ..................................................................................$118,788.89 Interest from 07/01/2008 through 01/31/2009 at 7.7500% .......................$5,396.50 Per Diem interest rate at $25.10 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$5,939.44 Late Charges from 08/01/2008 to 01/31/2009 .............................................$259.20 Monthly late charge amount at $43.20 Costs of suit and Title Search ......................................................................$900.00 Fees ................................................................................................................$37.00 Recoverable Balance ....................................................................................$198.00 $131,519.03 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the 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 $131,519.03, together with interest at the rate of $25.10, 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: A k? R? GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Renee Winters , 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: 01/19/2009 #77741FC FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 EythibitA Au the follawks dmcn'bed real Man lying and betag mutate in Shippeasbag Township, Ctmmbuland County, Perasylvmk bounded and Um tsd as follows; TRACT NO. 1; ScurAed on the Sots by Lot No. 6; on 60 8aM by land now or ftmerly of Gkirn, on the North by Lot No. 8; and ate the West by SbWm Ste*M BRING KNOWN AS LOT NO. 7 in the Pin of Lots known as John A. Wyrick's DevebMal; HAVING A MONTAGE CM Shippen Street of 75 fwt and an even depth of 200 feet from 6* center of Shipper Ste>etx, TRACT NO. 2: BEtiOMO at the caner of Lot No. 7 sad Shipper Street; thence in in F.tattowdly diread n 200 feet to lard now or fomnerly of Gkn and 94%dekl dw, thmoe in a Nathwwdly dbecdon along the sx= lands, 50 feet, more or lays, to booed now or fdtml* of L Reid; them is a wetaterly direction 200 feet along sage lands and Lot No. 4 to a p0W in Shipper Strew thence in a sottelewardly direction along Shippan Street 43 foes to the place of begWniog. Being the same real estate which Jatnas M Wdblay, widower, by his Attorney-in Faux. Elmer D Weibley+, by Power-a- Anotmey by his deed dated August 20,2= tend recorded in C mubaclend cou* Deed Book 253, Pap 1411 cmveyW to Sohn B. Dymond, who is being joie by Nancy G. Dymond, his wife. Pwesl# 36-35-23-8&029 9K 1969PGOB 14 01120=08 2.26.56 PM I CUMBER{" COUNTy JnSL 4 200657231 - Page 17 of 17 E.rhibit (B P.O. Box 1 Santa A a,OCA 92711-1000 7182 6389 3060 1350 7184 FRANK E COOVER U41 NW 19 WYRICK AVE SHIPPENSBURG, PA 17257 ACT 91 NOTICE n Citi Residential Lending Ci i October 02, 2008 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE AVISO: Este documento explica como los propietarios de casas pueden evitar perder sus hogares debido a demoras de pages. Para informacibn en espaflol Ilame a su prestamista. STATEMENTS OF POLICY Loan Number: 9000145889 Property Address: 19 WYRICK AVE, SHIPPENSBURG PA, 17257 Original Lender: Citi Residential Lending Current LenderfServicer: Citi Residential Lending THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mortoaae on your home is in default, and the lender intends to foreclose. Speck information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the proaram works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WIT HIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. 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 SOMA 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 VMTINWI9 07 PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 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: Z IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, z IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND z 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 CONSUMER CREDIT COUNSELING AGENCIES --If you meet with one of the consumer credit counseling ag@Lwy listed at the and of this notice. the lender may NOT take action against you for thirty (3W dMm 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's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (80) 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. "MVIMnsm October 02, 2008 Loan Number: 9000145889 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 datel. NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property located at: 19 WYRICK AVE, SHIPPENSBURG, PA 172571S SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 08101108 thru 10/01/08 Minimum Payments plus late charge or other fees: $2678.40 Minimum Amount to Cure Default: $2678.40 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable):N1A 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 $2678.40 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: Citi Residential Lending P.O. Box 5928 Carol Stream, IL 60197-5928 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.) WA IF YOU DO NOT CURE THE DEFAULT--ltyou 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 loforeclose upon your mortgaged prop2 . 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 begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (a DAY Period. You will rat be reguired 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 Sheriffs Sale. You may do so by paying the minimum amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writina by the lender and by ormi 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 SHERIFF'S SALE DATE-- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately (8) 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 CONTACTTHE LENDER: Citi Residential Lending PO Box 11000 Santa Ana, CA 92711-1000 Phone Number 800-430-5282 Fax Number 949-882-3528 EFFECT OF SHERIFF'S SALE --You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE --You_ mayor 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: z TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTH ER LENDING INSTITUTION TO PAY OFF THIS DEBT. z TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. z TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) z TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, z TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. Z TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED If you need additional assistance or counseling you may also find a Housing Counseling Agency in your area by calling Toll-free (800) 589-4287 or TDD (800) 877-8339. Citi Residential Lending Cc: Citi Residential Lending Attn: Collections Department Loan Number: 9000145889 Mailed by 19t Ckm Mail and by Certified Mail PWTUMPIS-a r? N C=z -n m W _ 7 t $ C: SHERIFF'S RETURN - REGULAR CASE NO: 2009-00619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS COOVER FRANK E GERALD N WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE COOVER FRANK E was served upon DEFENDANT the at 0019:45 HOURS, on the 9th day of February , 2009 at 19 WYRICK AVENUE SHIPPENSBURG, PA 17257 by handing to FRANK E COOVER DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 18.00 Affidavit .00 Surcharge 10.00 .00 46.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 02/11/2009 GOLDBECK MCCAFFERTY & MCKEEVER By: Deputy Sh ff 0 f A. D. rf rri In the Court of Common Pleas of Cumberland County US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. FRANK E. COOVER (Mortgagor(s) and Record Owner(s)) 19 Wyrick Avenue Shippensburg, PA 17257 Defendant(s) No. civil 09-619 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 FRANK E. COOVER by default for want of an Answer. Assess damages as follows: Debt $133,631.53 Interest from 04/21/2009 to Date of Sale per diem at $25.10 Total (Assessment of Damages attached) 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 Aocii 102 010o l , Judgment is entered in favor of US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 and against FRANK E. COOVER by default for want of an Answer and damages assessed in the sum of $133,631.53 as per the above certification. _ n Pxbthonotary _,/ 77741FC 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: March 3, 2009 TO: FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2007- AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 vs. FRANK E. COOVER (Mortgagor(s) and Record Owner(s)) 19 Wyrick Avenue Shippensburg, PA 17257 TO: FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 Plaint if Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. civil 09-619 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 (I0) 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 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, FRANK E. COOVER, is about unknown years of age, that Defendant's last known residence is 19 Wyrick Avenue Shippensburg, PA 17257, 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: ??? 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 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE FRANK E. COOVER (Mortgagor(s) and Record owner(s)) 19 Wyrick Avenue Shippensburg, PA 17257 Defendant(s) No. civil 09-619 ORDER FOR JUDGMENT Please enter Judgment in favor of US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007- AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2, and against FRANK E. COOVER 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 $133,631.53. 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 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 and that the name(s) and last known address(es) of the Defendant(s) is/are FRANK E. COOVER, 19 Wyrick Avenue Shippensburg, PA 17257; GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 07/01/2008 through 04/20/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 2 X $0.00 Fees Recoverable Balance $118,788.89 $7,379.40 $5,939:44 $388.80 $900.00 $0.00 $37.00 $198.00 $133,631.53 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 61'; day of Apr; 2009 damages are assessed as above. P Prothy R LED-01 YE OF THE 2009 APR 22 hi 1: 49 * 14.00 Pa ATH ?? 3?89oi '` aa-q 10 19 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff No. civil 09-619 vs. FRANK E. COOVER (Mortgagors and Record Owner(s)) 19 Wyrick Avenue Shippensburg, PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned tter e tered against you. urt Long Protho otary 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 r PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE FRANK E. COOVER Mortgagor(s) and Record Owner(s) 19 Wyrick Avenue Shippensburg, PA 17257 Defendant(s) No. civil 09-619 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 04/21/2009 to Date of Sale per diem at $25.10 $133,631.53 (Costs to be added) OLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff cn p, o ? b o n N O- ? ? A r tD ? N > + ' coo 2y? N ??+ a a o C n ro n K x o ? ?Z 9 cr C4 c ~ "? tD ??n ?x0?> Oa o> 2 O rT, Z?l '•+, K ? ? N Q Z > M Iyrb. oo O0 0 "PJ n ? rn Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 vs. FRANK E. COOVER Mortgagor(s) and Record Owner(s) 19 Wyrick Avenue Shippensburg, PA 17257 Plaintiff Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. civil 09-619 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. Michael ?TWK?eever???? Attorney for plaintiff f1LE(?--`v?-r?vE OF THE PF,. T f-.,,0 TARY X1'09 APIA 22 Pi l 1: 4 9 +^ rr A'+A V 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 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. FRANK E. COOVER (Mortgagor(s) and Record Owner(s)) 19 Wynck Avenue Shippensburg, PA 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. civil 09-619 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2, 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: 19 Wyrick Avenue Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 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 Id% +I PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 CITIFINANCIAL Attention: Payment Processing Fort Mill, SC 29715 CITIFINANCIAL MORTGAGE CO., INC. 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street P.O. Box 15530 Harrisburg, PA 17105 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 19 Wyrick Avenue Shippensburg, PA 17257 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 21, 2009 OLDB K Mc AFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff FILED4),-'f lOE Or THE l;? r` r 'r„, r Y 211,09 APR 22 P.11 1: 4 9 civil 09-619 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. FRANK E. COOVER Mortgagor(s) and Record Owner(s) 19 Wyrick Avenue Shippensburg, PA 17257 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. civil 09-619 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: COOVER, FRANK E. FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 Your house at 19 Wyrick Avenue, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 02, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $133,631.53 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE civil 09-619 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007- AMC2, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: htip://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 civil 09-619 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 civil 09-619 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 hLtp://www.phfa.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825- 6411. Please reference our Attorney File Number of 77741 FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-619 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, as Trustee in Trust for the Registered Certificates Holders of CITIGROUP MORTGAGE LOAN TRUST 2007- AMC2, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2, Plaintiff (s) From FRANK E. COOVER (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 $133,631.53 L.L. $.50 Interest from 4/21/09 to Date of Sale per diem at $25.10 Atty's Comm % Due Prothy $2.00 Atty Paid $165.00 Other Costs to be added Plaintiff Paid Date: 4/22/09 Curtis R. Long rothonota (Seal) By: 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 Deputy GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC-2. ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2007- AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. CIVIL 09-619 FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: C s-x -„ W l ?? -- }rn w Kindly mark the above case Discontinued and Ended upon payment of your costs only. Michael T. McKeever, Esquire Attorney for Plaintiff GOLDBECK WCAFFERTY & 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 US BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED CERTIFICATES HOLDERS OF CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2007-AMC2 10801 6th Street Suite 130 Rancho Cucamonga, CA 91730 Plaintiff vs. FRANK E. COOVER 19 Wyrick Avenue Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. civil 09-619 PRAECIPE TO VACATE JUDGMENT TO THE PRO"HONO'TARY: C c ! U r" Ti rn pL' ? :.J Kindly vacate the judgment upon payment of your costs cnly. MICHAEL T. MCKEEVER, ESQUIRE 48.00 PD A7T`/ 0 aolo