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HomeMy WebLinkAbout09-1174110 GGLDBECK 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 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. MICHAEL T. CALAMAN Mortgagor and Record Owner 35 Partridge Circle Carlisle, PA 17013 Defendant Term 7 No. c'10.L ACTION: MORTGAGE. 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT ANY INFORMATION OBTAWED 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: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org,/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadeIpWafed.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 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 Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825-6411. Please reference our Attorney File Number of 78010FC. 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 COUNTRYWIDE HOME LOANS SERVICING, L.P., 7105 Corporate Drive, PTX C 35 Plano, TX 75024. 2. The names and addresses of the Defendant is MICHAEL T. CALAMAN, 35 Partridge Circle, Carlisle, PA 17013, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On January 20, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICA'S WHOLESALE LENDER, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book: 1939 Page: 1559. The mortgage has been assigned to: COUNTRYWIDE HOME LOANS SERVICING, L.P. 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 February 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 ....................................................................................$85,590.09 Interest from 01/01/2008 through 02/28/2009 at 6.7500% .......................$6,723.50 Per Diem interest rate at $15.82 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,279.50 Late Charges from 02/01/2008 to 02/28/2009 .............................................$371.01 Monthly late charge amount at $28.54 Costs of suit and Title Search ...................................................................... $900.00 Monthly Escrow amount $200.01 $97,864.10 7. If the Mortgage is reinstated prior to a Sheriffs 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 terris judgment in mortgage foreclosure in the sum of $97,864.10, together with interest at the rate of $15.82, 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: 0 r GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Kee adman 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: a)-&3 Kai Seknan, assistant Vice President #78010FC - MICHAEL T. CALAMAN 35 Partridge Circle Carlisle, PA 17013 E?chifiitA ALL T6IAT OW M Not of IOW wNh to lmproveman? dm can aaoled, equals in ow TowaW* of NOFM MRtrabrt, *At WbM CWOY, PWNW%Vft bow" aril deac?kted, as m Wm BEGO"NA at a point an to raft M rloht of way ana of Parpldpa Ckda 81 #0 Mj#W W Comer of Lot No. $C; lhaioa d&Wa M rlipht of wayane North 59daptae84 mMuNs n o Me de Waet 18.001ret b e point brnp be =*N t mW of L d XK; *w= adwq L.ot No. MOW pwly Mira o Sp Iwo wall and Mrmuph e 10' NWFNW raawlerrt mild Nrayh b i0' pbalna arAeM+olent and Muouoh a M0' p eMrle ewarrart1140030 35 37 seor?nds Eat ? ? tM b a paint at Nrw d ierlde now or Ibmlt r d Oeapellhdb Ord 3naan flipper, Dad Book 31-0, Papaw Mlalaa rap Bald k"a amm el d 0118 66 minvlru" eeoonde ? ia>i.t8 featb a polyp bairp Mb norNlweat oatnb a I.ot Np. ? thence woeq LAt #lo. bC and POPW Mlnouoh a P O SIN wail and rwtwph aid N aaeaa111-tend m'lm h 00 4W awn" and Mt ouch said 8oalb 3o Oqp us 36 fntrrdee 37 eaoende Wier 246.33 feat b a point, Oft M pads or Kapodft COW WWMO 4,366 Nome hot mare or Iseu. HAVW M+vaort gaoled a two stay d**" In w4a amid nw>h wW aA 35 Pa *Wp Grate. Ca*k, PA 17015. aEM LOT NO."an Ow Fha Ra Won pm for i mri lrMO - Edabe, pnlpenas by R.J. FWw& Aeaopalee. MO.. WW recorded In Camba bW Coungr In Plait Book W Per 4a. SUBJECT, "OWEYM to such eomhwt k roabictlona and aonmaw" dial may Sp* to tar OW04ma dw tact of land, recorded or unmomrded. PWW 79-70-1Z5M7 be recorded Otimbalail-I County PA Recorder of Deeds 1 Rf 19 1' E..x..hibit B ®CENIfIhrAide- HOMELOANS PO Boot 9048 Ton ecdo, CA 925894048 Send Payments To: PO Baez NOW DaHas,TX 75288.0894 Send Correspondence to: PO Baot 5170, MS SV314B Strut Veley, CA 93055 091001.7 BLt1PAi PRESORT Rirst-chw Mail U.S. Postage and Fees Paid WSO 1054-10 7113 8257 1472 8645 4814 Michael T Calaman 35 PARTRIDGE CIR CARLISLE, PA 17013-8700 ytn i?3 MK HOME LOANS P.O. Box 880694 Send Payments to: Dabs, TX 75266-0694 PO Box 660694 Dates, TX 75268-0694 10/01/2008 Certified Mail: 7113 8257 1472 8695 4819 Return Receipt Requested Regular Mail MIct" T Calaman Account No.: 123574987 35 PARTRIDGE CIR Property Address: CARLISLE, PA 17013-8700 35 Partridge Circle Carlisle, PA 17013-8700 Current Servicer. Countrywide Home Loans Servicing LP FORECLOSURE This Is an 2" notice that the rnortaaoe on your horns is in defau and the lender intends to foreclose Specfrc about the nature of the debuft Is provided in the attic. : me The tjoiggAMER'8 EMERGEENCY MORTGAGE ASSISTANCE PROGRAM fH Aat may be able to ha'.n to saw your thane. Thls Notice explains how the program works. To Ass r ttEYAP cap beb you =at MEET WM A G?8U1tER C n9T G?iN8 n p1? AGENCY ti:"TnYr Sii DAYS OF THE DATE OF TINS NOTICE. Take this Notice with you when you rne: with the Courns'led %penw. This Notice ferns Important hagaf information. N you have any questions, representatives at the Consumer CredN Couns*&V Agency may be able to help explain ft. You may also ward to contact an attorney in your area. The local bar assoclaWn nay be able to help you flnd a lawyer. LA NOTWXAC16N EN ADJINfTO ES DE SOMA I MPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVMNDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTFICAC16N OSTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRISA. PUEDE SER ELEGISLE PARA UN PRt8TAM0 POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDNMIR SU HMOTECA. HOMEOWNER'S NAME(S): Michael T Callan an PROPERTY ADDRESS: 35 Partridge Circle Cadisle. PA 170135700 LOAN ACCT. NO.: 123574987 ORIGNAL LENDER: CURRENT LENDERISERVICER: Countrywide Horror Loans Servicho LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM BE pLIGIBLE_FOR FwAUrsAr A8818TA.W'E WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND MAY oYOU MAKE FUTURE MORTGAGE PAYMENTS • Mdeyourdaedc b • l wriacmut nuebu on • yogrammormm"aft Me M ?inro rWMplrere send , W., dwc4 • pDp/ra?nteaaftItc lh wu drdc b the CGWM • Dartkd*Coarfepdfdefce • Dmt seed a3h ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM Pbase wdb ymr acourll nnlberon lee clwds and oweelmdaloe. We may rhage you a fee forrypWmm laknwd orneieebd by w bw dd irrdMm, Ktpato applim* law. Accm" Nurrlbar.1211574f1574 Mkhael T Calaman Belarim Due for d=W listed above: $9,838.08 as of 10112n. 35 PaNklge Circle Pbaee WdAs e-luae kftM eon on he iewne else of ens capon. of BLOPAt PM*al tlonal Eacm Countrywide PO BOX 880694 r- Dallas, TX 75288-0894 cerom 1235749.87400000383808000383808 IF YOU COMPLY WITH THE PROVISIONS OF. THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1985 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURf. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a `face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. IHI$_ MEETNG MUST OCCUR wmRw TH = UFVT 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 adion against you for thirty (30) days after the date of this meeting. The names, let Torin at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your of your intentions. APPLICATI(1?! FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH N 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 N 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 NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at. 35 Partridge Circle Cadisie, PA 17013-8700 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the folowing amounts are now past due Monthly Chances: 08/01/2008 Late Charges: 08101/2008 Other Late Charges Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: EiM ue: PiWid -mdaft=bMbw A abn usb send you kftndmm yctraaarR ACCOM tAaeba AridrN T Comw E-rad addrns $2,201.34 $57.08 $258.24 $1,321.42 ($0.00) $5,838..08 How we pod Oa+ P i AN aaspoed PRPW s Of I I t and YNaret wa be appUd b ft b QW aia M ft iMlallllali due, wine W.- lee IaotAMd a liehd bl law. r you slibrnl an arrant in addMon b your rhed d mm" XMK we wa apply yotr P*W to as lolowa (0 to outatendhp nwaiy wrm cf pdn<lpal ad idarnt. (n am= dalciandas, R Mb doWs and other aaowb you owe in anrcft with you ion and (N) b rsfte ma aatendg pdnrlp d belanca of yar ban pbw We* r you woman adiMwW WMA appkd bPoae papwb, rod w Vm pftW redxft. POaasaa ehaahC ority*W0 polq b b not MW podd tad dwb, wiaaa apec&* aped 10 bye ben mnolor «sed Wdo . YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (301 DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH M :3,838.08, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's chedL certified check or gLa ordw made payablend sent to: Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by taknc the following action within THIRTY (30) DAYS of the date of thisletter. (Do not use If riot applicable) 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 kdonds to exercks its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be oonsidered 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 fender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. 9 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 attorneys 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's fees will be added to the amount you owe the lender, which may also include other reasonable costs. N you cure the default within the THIRTY (301 DAY period, you wiN not be required to pay attorneys fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. 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 total amount then past due, plus any late or other charges than due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curling your detauk in it* manner set forth M this notice will restore your mortgage to the same position as N you had rover defaulted. EAST POSSIBLE SHERMF'S SALE DATE - it is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (0) months from the data of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will Increase the longer you wait You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Counbyw/de Home Loans Servidng LP Address: P. O. Box 600M Daf/44 TX 75266-M4 Phone Number. 1-806.669.6651 Fax Number: 1-805577-3432 Contact Pomon: MS PTX-36 Atfendon: Loan Counselor EFFECT OF SHERIFFS SALE - You should realize that a Shoff s Sale will end your ownership of the managed property and your right to occupy it if you continue to live In the property after the Shoff sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. Nl. 7113 8257 1472 8695 4819 TO HAVE THE MORTGAGE *RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your ban is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (1) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the abovedescrib¢d inspections and property preservation efforts will be charged to your account as provided In your security instrument. If you are unable to cure the default on or before October 31, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It Is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least '%of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are Interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance. Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by October 31, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Carrier immediately at 1-800-669-6654. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Adana Canty Intareitlt CCCS of Western PA Hot" Aut-t Community Acycn Ccmniesioi y 2000 Linglestown Road 40 E High Street Harrisburg PA 17102 of Captral Region , Ge ysburg, PA 17325 888.511.2227 717.334.1518 1514 Derry Street HaM PA 17104 ?u9, 717.232.9757 Lareship, Inc. Marenalhe PHFA 2320 North 5th street 43 Philadelphia Avenue 211 Nast From Sleet Harrisburg, PA 17110 Waynesboro, PA 17288 717.232.2207 717.78boro Han". PA 17110 717.780.3940 800.342.2397 Q? C' r*l co `? cn _ ( 3 L!J -Na 0 "'e C_J SHERIFF'S RETURN - REGULAR CASE NO: 2009-01174 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNRTYWIDE HOME LOANS SERVICI VS CALAMAN MICHAEL T BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE CALAMAN MICHAEL T the DEFENDANT , at 0008:27 HOURS, on the 28th day of February , 2009 at 35 PARTRIDGE CIRCLE CARLISLE, PA 17013 by handing to MICHAEL CALAMAN 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 Service Affidavit Surcharge 18.00 4.50 .00 10.00 .00 32.50 Sworn and Subscibed to before me this day So Answers: 40 R. Thomas Kline 03/02/2009 GOLDBECK MCCAF,FERTY & MCKEEVER By: Deputy Sheriff was served upon of , A. D. ??- "?` '? ? ;??` t?Qr ?ri'?t at r ` In the Court of Common Pleas of Cumberland County COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. MICHAEL T. CALAMAN (Mortgagor(s) and Record Owner(s)) 35 Partridge Circle Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-1174 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 MICHAEL T. CALAMAN by default for want of an Answer. Assess damages as follows: Debt Interest from 4/4/09 to Date of Sale per diem at $15.82 Total (Assessment of Damages attached) $98,859.08 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 attomey 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 A pri ( .tk 01001 , Judgment is entered in favor of COUNTRYWIDE HOME LOANS SERVICING, L.P. and against M CHAEL T. CALAMAN by default for want of an Answer and damages assessed in the sum of $98,859.08 as per the above certification. othonotary op 78010FC 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 24, 2009 TO: MICHAEL T. CALAMAN CALAMAN, MICHAEL T. 35 Partridge Circle Carlisle, PA 17013 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 VS. MICHAEL T. CALAMAN (Mortgagor(s) and Record Owner(s)) 35 Partridge Circle Carlisle, PA 17013 Plaintiff Defendant(s) TO: MICHAEL T. CALAMAN 35 Partridge Circle Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-1174 MIPORTANT 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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 i 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, MICHAEL T. CALAMAN, is about unknown years of age, that Defendant's last known residence is 35 Partridge Circle Carlisle, PA 17013, 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: Jf64t to 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 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. MICHAEL T. CALAMAN (Mortgagor(s) and Record owner(s)) 35 Partridge Circle Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-1174 ORDER FOR JUDGMENT Please enter Judgment in favor of COUNTRYWIDE HOME LOANS SERVICING, L.P., and against MICHAEL T. CALAMAN 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 $98,859.08. 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 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are MICHAEL T. CALAMAN, 35 Partridge Circle Carlisle, PA 17013; 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 01/01/2008 through 04/03/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 2 X $200.01 $85,590.09 $7,261.38 $4,279.50 $428.09 $900.00 $400.02 $98,859.08 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 7?k day of Aptt I , 2009 damages are assessed as above. P rothy / SL?I TAR, OF 'fff "T nag APR CUMi r SYLVAN' *14.00 P d A Cwt1517(A 10 W Ia33ctQ s ? J Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. MICHAEL T. CALAMAN (Mortgagors and Record Owner(s)) 35 Partridge Circle Carlisle, PA 17013 No. 09-1174 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 tter h red 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 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. MICHAEL T. CALAMAN Mortgagor(s) and Record Owner(s) 35 Partridge Circle Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-1174 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 4!4!09 to Date of Sale per diem at $15.82 $98,859.08 (Costs to be added) q-t-- ?11 tl?? - GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff tip Q '_ Ll s s d OZ q Q?- ?Q =?c Gad o- 0 0 ,CC -an cl- C6 LL- cr Q U ui a a z ,^ F V, ? ?Or.M W O U sin. z x x o in U a O U i' H d? ?U U o s» ? r, v Cc' N boo a ?QQ G7 ci ALL THAT CERTAIN tact of land with the improvements thereon erected, situate in the Township of North Middleton, Cumberland County, Pennsylvania, bounded and described, as follows: BEGINNING at a point on the northern right of way line of Partridge Circle at the southwest corner of Lot No. 3C; thence along said right of way line North 59 degrees 24 minutes 23 seconds West 18.00 feet to a point being the southeast corner of Lot 30A; thence along Lot No. 3-A and partly through a partition wall and through a 10 feet emergency easement and through a 40 feet pipeline easement and through a 50 feet pipeline easement North 30 degrees 35 minutes 37 seconds East 242.95 feet to a point at line of lands now or formerly of George Shatto and Susan Burger, Deed Book 31-0, Page 568; thence along said lands South 68 degrees 55 minutes 58 seconds East 18.16 feet to a point being the northwest corner of Lot No. 3-C; thence along Lot No. 3-C and partly through a partition wall and through said 10 feet easement and through said 40 feet easement and through said 50 feet easement South 30 degrees 35 minutes 37 seconds West 245.33 feet to a point, being the place of BEGINNING. CONTAINING 4,395 square feet, more or less. HAVING thereon erected a two story dwelling known and numbered as 35 Partridge Circle, Carlisle, PA 17013. BEING LOT NO. 3-B on the Final Re-Subdivision Plan for Middleton Estates prepared by R. J. Fisher & Associates, Inc., and recorded in Cumberland County in Plan Book 69, Page 48. SUBJECT, HOWEVER to such easements, restrictions and conditions that may apply to the afore-described tact of land, recorded or unrecorded. Parcel 29-15-1252-047 PROPERTY ADDRESS: 35 PARTRIDGE CIRCLE, CARLISLE PA 17013 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 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. MICHAEL T. CALAMAN (Mortgagor(s) and Record Owner(s)) 35 Partridge Circle Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-1174 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS SERVICING, L.P., 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: 35 Partridge Circle Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): MICHAEL T. CALAMAN 35 Partridge Circle Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: MICHAEL T. CALAMAN 35 Partridge Circle Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX-C-35 Plano, TX 75024 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 3300 South-West 34th Avenue Suite 101 Ocala, FL 34474 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: AMERICA'S WHOLESALE LENDER 4500 Park Granada, MSN# SVB-314 Calabasas, CA 91302 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 35 Partridge Circle Carlisle, PA 17013 (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: Apol 3, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff RLEFICE OF THE M. OPJ NOTARY 2009 APR -7 PM 1: S9 CUN6'l`- .?.' aL) L,?eUN PENNISYLVANlA Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. MICHAEL T. CALAMAN Mortgagor(s) and Record Owner(s) 35 Partridge Circle Carlisle, PA 17013 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. 09-1174 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 T. McKeever Attorney for plaintiff RLED"OFFICE CF IWE t N lIONOTARY 2009 APR --7 PM t 59 rat ! B,l ." U I NNS)`l.VAIOA 09-1174 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 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. MICHAEL T. CALAMAN Mortgagor(s) and Record Owner(s) 35 Partridge Circle Carlisle, PA 17013 Defendant( Term No. 09-1174 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: CALAMAN, MICHAEL T. MICHAEL T. CALAMAN 35 Partridge Circle Carlisle, PA 17013 Your house at 35 Partridge Circle, Carlisle, PA 17013 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 $98,859.08 obtained by COUNTRYWIDE HOME LOANS SERVICING, L.P. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 09-1174 1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS SERVICING, L.P., 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: http;Hwww.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 09-1174 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website htip://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionngoldbecklaw.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 78010FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1174 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff (s) From MICHAEL T. CALAMAN (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 $98,859.08 L.L. $.50 Interest from 4/4/09 to Date of Sale per diem at $15.82 Atty's Comm % Due Prothy $2.00 Atty Paid $151.50 Other Costs to be added Plaintiff Paid Date: 4/07/09 Curtis R. Long, Prothono ry (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 _ SHERIFF'S OFFICE OF CUMBERLAND ,, Ronny RAnderson ~=' Tt~E F~~7I;~~°~QT~=;R' Sheriff Jody S Smith ~a«ntr crt ~nurg~r~~~~ ~~ ~ d ~~7 ~ ~! ~~ ~~~ Chief Deputy ~~ ._ ~ ;~~'< CGMSE~I_A~d~ CQ~~~~ Richard W Stewart ~Et~~~aY~.~'A~lI~`w Solicitor c~~'=E ~ ~ "'~~ `"~~'~~ Countrywide Home Loans Servicing LP vs. Michael T Calaman Case Number 2009-1174 SHERIFF'S RETURN OF SERVICE 03/30/2010 08:11 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2010 at 2008 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 Michael T. Calaman, located at 35 Partridge Circle, Carlisle, Cumberland County, Pennsylvania according to law. 03/30/2010 08:11 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2010 at 2008 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Michael T. Calaman, by making known unto, Michael T. Calaman, personally, at 35 Partridge Circle, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 05/27/2010 Property sale postponed to 7/7/2010. 07/06/2010 Property sale postponed to 8/4/2010. 08/04/2010 Ronny R. Anderson, 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 August 4, 2010 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, P.O. Box 650043, Dallas, Tx, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1,037.41 SHERIFF COST: $1,037.41 October 13, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF a .~ ~ . ~. ~~~~~~ (cj CouotySuite Sheriff, Teleosoft. Inc. E ..Z '~ r .# ti GOLbBECK 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 09-1174 COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. MICHAEL T. CALAMAN Mortgagor(s) and Record Owner(s) 35 Partridge Circle Carlisle, PA 17013 Defendants Term No. 09-1174 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: CALAMAN, MICHAEL T. MICHAEL T. CALAMAN 35 Partridge Circle Carlisle, PA 17013 Your house at 35 Partridge Circle, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $98,859.08 obtained by COUNTRYWIDE HOME LOANS SERVICING, L.P. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CNII.. ACTION -LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 09-1174 1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS SERVICING, L.P., the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of 717-240-6390, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 . ~ t 09-1174 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 78010FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. . µ ALL THAT CERTAIN tact of land with the improvements thereon erected, situate in the Township of North Middleton, Cumberland County, Pennsylvania, bounded and described, as follows: BEGINNING at a point on the northern right of way line of Partridge Circle at the southwest corner of Lot No. 3C; thence along said right of way line North 59 degrees 24 minutes 23 seconds West 18.00 feet to a point being the southeast corner of Lot 30A; thence along Lot No. 3-A and partly through a partition wall and through a 10 feet emergency easement and through a 40 feet pipeline easement and through a 50 feet pipeline easement North 30 degrees 35 minutes 37 seconds East 242.95 feet to a point at line of lands now or formerly of George Shatto and Susan Burger, Deed Book 31-0, Page 568; thence along said lands South 68 degrees 55 minutes 58 seconds East 18.16 feet to a point being the northwest corner of Lot No. 3-C; thence along Lot No. 3-C and partly through a partition wall and through said 10 feet easement and through said 40 feet easement and through said 50 feet easement South 30 degrees 35 minutes 37 seconds West 245.33 feet to a point, being the place of BEGINNING. CONTAINING 4,395 square feet, more or less. HAVING thereon erected a two story dwelling known and numbered as 35 Partridge Circle, Carlisle, PA 17013. BEING LOT NO. 3-B on the Final Re-Subdivision Plan for Middleton Estates prepared by R. J. Fisher & Associates, Inc., and recorded in Cumberland County in Plan Book 69, Page 48. SUBJECT, HOWEVER to such easements, restrictions and conditions that may apply to the afore-described tact of land, recorded or unrecorded. Parce129-15-1252-047 PROPERTY ADDRESS: 35 PARTRIDGE CIRCLE, CARLISLE PA 17013 Being the same premises which Jeffrey Snyder and Lisa Snyder, husband and wife, by deed dated 02/28/08 and recorded 03/01/02 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 250 Page 3008, granted and conveyed unto Michael Calaman. 1 ` Goldbeck McCafferty & McKeever BY: Michael,T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. MICHAEL T. CALAMAN (Mortgagor(s) and Record Owner(s)) 35 Partridge Circle Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 09-1174 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS SERVICING, L.P., 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: 35 Partridge Circle Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): MICHAEL T. CALAMAN 35 Partridge Circle Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: MICHAEL T. CALAMAN 35 Partridge Circle Cazlisle, PA 17013 3. Name and last known. address of every judgment creditor whose judgment is a record lien on the property to be sold: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX-C-35 Plano, TX 75024 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 3300 South-West 34th Avenue Suite 101 Ocala, FL 34474 t .~ 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. PO Box 20261 4318 Miller Road Flint, MI 48501-2026 4. Name and address of the last recorded holder of every mortgage of record: AMERICA'S WHOLESALE LENDER 4500 Park Granada, MSN# SVB-314 Calabasas, CA 91302 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 35 Partridge Circle Carlisle, PA 17013 MIDDLETON ESTATES COMMUNITY ASSOCIATION, INC. 41 Partridge Circle Carlisle, PA 17013 (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 aze made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 15, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONV(/EALTH OF PENNSYLVANIA) NO 09-1174 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff (s) From MICHAEL T. CALAMAN (1) You are directed to lery 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 prop~ty 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 $98,859.08 L.L. Interest from 4/4/09 to Date of Sale per diem at $15.82 -- To Be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $954.41 Other Costs Plaintiff Paid Date: 12/16/09 (Seal) REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Deputy On March Z2, 2010 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered, 35 Partridge Circle, Carlisle more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: G~`- Rea Estate Coarainator 9 t ~ ~ d ~- ~ X30 6001 G' ~ ~, , . ~~:~ ~~'~~3N1 ~;~r ,; J .~ ~. ~, ,;;\\ :..~~~~ 1' ~~ 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 Cazlisle 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 regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, Apri123, and Apri130, 2010 Affiant fiu ther 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 chazacter of publication are true. Writ lro. 2009-1174 Civil Countrywide Home Loans Servicing LP vs. Michael T. Calaman Atty: Michael McKeever ALL THAT CERTAIN tact of land with the improvements thereon erected, situate in the Township of North Middleton, Cumberland County, Pennsylvania, bounded and described, as follows: BEGINNING at a point on the northern right of way line of Partridge Circle at the southwest corner of Lot No. 3C; thence along said right of way line North 59 degrees 24 minutes 23 seconds Weat 18.00 feet to a point be- ing the southeast corner of Lot 30A; thence along Lot No. 3-A and partly through a partition wall and through a 10 feet emergency easement and through a 40 feet pipeline easement and through a 50 feet pipeline ease- ment North 30 degrees 35 minutes 37 ser_onda F'~xt 242_ f rt ton -. ~- Lis Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 30 da of April. 2010 Notary NOTARIAL SEl1t _~ DEBORAH A COLLINS Notary Public ARLI8LE BOROUGH, CUMBERLAND COUNTY My Comml:aloe Expires Apr 28, 2014 ~h„The Patriot-NevKS Co,• 2020 Technology Pkwy Suite 300 IVlechanicsb~rg, Pl4 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c~he ~latriot Netus Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on 1:he date(s) shown below: Writ No. 2009-1174 Civil Term 04/16/10 Countrywide Home Loans Servicing LP ; ' -~'- 04/23/10 v8. ~ ~,.. "` MtchaeiTCaiaman c- `"- 04/30/90 Atty: Michael McKeever ~ ~ , ~~ ~~~~~ ~~ ALL THAT CERTAIN tact of land with the • 1y • ... . improvements thereon erected, situate in the Township of North Middleton, Cumberland County, Pennsylvania, bounded and described; Sworn to and subscribed before me this '~8'dey of May, 2010 A. D. as follows: ~~` ~- BEGINNING at a point on the northern right `'~ ~,. ~ ~ ; ~ -"' ~ ~ of way line of Partridge Circle at the southwest ~~ ' ~' ~`" ~! ~"~" _--~ ~'L-- ~`_ _^Y_ corner of Lot No. 3C; thence along said right of Notary PUbIIC way line North 59 degrees 24 minutes 23 seconds West 18.00 feet .to a point being the southeast COMMONWEA~ThI OF PENNSYLVANIA comer of Lot 30A; thence along Lot No. 3-A and Notarial Seal partly through a partition wall and through a 10 $herHe L KKtter, Notary Publk feet emergency easement and through a 40 feet . Lower PaMOn Twp., Dauphin County pipeline easement and through a 50 feet pipeline My eommisslort Expires Nov 2G. 2011 easement North 30 degrees 35 minutes 37 seconds Member, Pennsylvania gssoclatlon of Notaries East 242.95 feet to,a point at line of ]ands now of formerly of George Shatto and Susan Burger, Deed Book 31-0, Page 568; thence along said lands South 68 degrees 55 minutes 58 seconds East 18.16 feet to a point Being the northwest COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } 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 :;old to said grantee on the 4th day of Au ust A.D., 2010, under and by virtue of a writ Execution issued on the 16th day of December, A.D., 2009, out of the Court of Common Pleas of said County as of Civil. Term, 2009 Number 1174, at the suit of Countrywide Home Loans Servicing L P against Michael T Calaman is duly recorded as Instrument Number 201029364. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~~ day of ~YY U ~ Recorder of Deeds Reoorderdbe~ds, d~a-~dt~ou~ty; Cede, lyy My Commission Ex~iree a,e Frst Monday, of ,Ian, 2014