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Home My WebLink About09-1505GOLDBECK BY: MICHAEL T. MCKEE1 ATTORNEY I.D. #56129 SUITE 5000 - MELLON INE 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 W W W.GOLDBECKLAW.COD HSBC BANK USA, NAT TRUSTEE FOR ACE SE( EQUITY LOAN TRUST, 4708 Mercantile Drive Na Fort Worth, TX 76137 VS. DAVID A. WAIT FAITH E. WAIT Mortgagors and Record Ow 1103 Bridge Street New Cumberland, PA 17070 You have been sued! you must take action within appearance personally or by claims set forth against you. judgment may be entered ag of for any other claim or reli important to you. YOU SHOULD TAI LAWYER OR CANNOT A THIS OFFICE CAN PROV. IF YOU CANNOT) YOU WITH INFORMATIC PERSONS AT A REDUCE.' TY & McKEEVER CENTER AL ASSOCIATION, AS TTIES CORP. HOME IN THE COURT OF COMMON PLEAS ;IES 2006-NCI OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ' ?l 0?- /SG5 iers Term CIVIL AC Icm M69TOAGE Defendants ??OftCL URE NOTICE in court. If you wish to defend against the claims set rth in the following pages, twenty (20) days after the Complaint and notice are s ed, by a e, a written attorney and filing in writing with the court your defenses or obi', ctions to the O oceed w( out you and a You are warned that if you fail to do so the case mayr .nst you by the Court without further notice for any money claim in the Complaint f requested by the Plaintiff. You may lose money or property of other rights THIS PAPER TO YOUR LAWYER AT ONCE. It YOU 1)4 NOT HAVE A FORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. [ E YOU WITH INFORMATION ABOUT HIRING A LAWYE FORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE. ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle PA 17013 LE HAN DEMANDA] QUEJAS PERESENTADAS, DE 20 DIAS DESPUES DE S. NECESSARIO QUE USTED, PUNTO DE VISTA DE USTI DEMANDA. RECUERDE: SI UST', 717-243-9400 AVISO A USTED EN LA CORTE. SI DESEA DEFEND RSECONTRA LAS ABSOLUTAMENTE NECESSARIO QUE USTE RESPO DENTRO SERVIDO CON ESTA DEMANDA Y AVISO. P DEJDA NDERSE ES SU ABOGADO, REGISTRE CON LA CORTE E FORMA SCRITA, EL Y CUALQUIER OBJECCION CONTRA LAS QU JAS EN STA NO REPONDE A ESTA DEMANDA, SE PUEDE IPROSEGUIR CON EL -- - - - - ~InN RNTrYMrRQ T A rrynT "rl ,.T T, -- FAVOR DEL DEMAND DE ESTA DEMANDA ANTE Y REQUERIRA QUE USTED CUMPLA C R . DINERO, PROPIEDAD O RAZON DE ESA DECISION, ES POSSIBLE OTROS DERECHOS IMPORTANTES. USTED DEBE LL ABOGADO, VAYA O L L VAR ESTE PAPEL A SU ABOGADO ENSEGU AME POR TELEFONO LA OFICINA FIJADA PUEDE PROVEERE CO A INFORMACION DE COMO CONSEUIR UN A; SI USTED N INFORMACION ACE PUEDE PAGARLE A UN ABOGADO, ESTA O] CA AGENCIAS QUE PUEDAN OFRECER SE I E R LIGIBLE AQ UN HONORARIO REDUCIDO O ( CUMBERLAND COUNTY BAR ASSOCIATI 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Resources available for Homeowners in Foreclosure ACT NOW! Even though your le der (and our client) has filed an Action of Mortgage F still may be able to SAVE Y UR HOME FROM FORECLOSURE. 1). Call an attorney. or referrals to a qualified attorney call either of the 243-9400. 2). Call the Consum 3). Visit HUD'S we] 4). Pennsylvania Ho in default. Please See the PH 5). Call the Plaintiff or Home Retention options. 6). Foreclosure Reso 7). Call or contact ou or request a Loan Workout / at homeretentionna oldbeckl; package you requested will b information. The attorney in can be reached at 215-825-63 Para infonmcion en 'Credit Counseling Agency at 1-800-989-2227 for ft site www.hud aov for Help for Homeowners Facing 1 sing Finance Agency also offers other loan programs A website httn:/twww nhfa or /consumers/homeowr (our lender) at 888-325-3502 and ask to speak to son rce Center: httn://www nhiladelphiafed org/foreclosw Office to request the amount to bring the account can ome Retention Package. Call our toll free number at K.-com. Call Seth at 215-825-6329 or fax 215-825-64 mailed to the address that you request or faxed if you large of our firm's Homeowner Retention Departmen 1 or Fax: 215-825-6411. Please reference our Attornp puede communicarse con Loretta al 215-825-63 TODAS LAS PROVISIONES E USTED PUEDA PERDER SI USTED NO TIENE UN ABAJO. ESTA OFICINA IOTA PUEDDE PROVEERE OS LEGAL A PERSONAS TIS. against you, you numbers: or 717- counseling. Loss of Their Homes. at may assist homeowners about Loss Mitigation W, or payoff the mortgage -866-413-2311 or via email 9. The figure and/or eave a message with that is Courtenay Dunn who File Number of 69231 FC. This Action of Mort age Foreclosure will continue unless you to a action to stop it. OMPLAINT IN MORTGAGE FORECLO: 1. Plaintiff is HSBC BANK USA, NATIONAL ASSOCIATION, AS TR CORP. HOME EQU TY LOAN TRUST, SERIES 2006-NC1, 4708 M Worth, TX 76137. FOR ACE SECURITIES Drive North, Fort 2. The names and addr sses of the Defendants are DAVID A. WAIT, 1103 Bridge Street, New Cumberland, PA 17 70 and FAITH E. WAIT, 1103 Bridge Street, New Cumberland, PA 17070, who are the mortgagors d record owners of the mortgaged premises hereinafter described. 3. On August 26, 2005 described to NEW C Office of the Record been assigned to: H' SECURITIES CORI Mortgage. Plaintiff i obligation from the I be lodged for record and assignment(s) ai Pennsylvania Rule o attach documents to iortgagors made, executed and delivered a mortgage NTURY MORTGAGE CORPORATION, which me r of Deeds of Cumberland County as Book 1924, Pag BC BANK USA, NATIONAL ASSOCIATION, AS HOME EQUITY LOAN TRUST, SERIES 2006-NC the real party in interest pursuant to a purchase or tra A record holder and an Assignment of Mortgage to P ig with the Recorder of Deeds in the ordinary course matters of public record and are incorporated by this Civil Procedure 1019(g); which Rule relieves the Pla leadings if those documents are matters of public reo ion the Property hereinafter gage is recorded in the 914. The mortgage has [,USTEE' FOR ACE by assignment of ;fer of the mortgage intiff has been and/or will 'business. The Mortgage ,ference in accordance with .tiff from its obligation to 4. The Property subj "A" ("Property"). 5. The mortgage is in for October 01, 200 payments for a peril charges are due and 6. The following to the Mortgage is more fully described in the legal set forth as Exhibit ;fault because the monthly payments of principal and i terest are due and unpaid and each month thereafter and by the terms of the Mortgage, upon default in such l of one month or more, the entire principal balance and all interest due and other are due to Plaintiff on the Mortgage: Principal Balanc ..................................................................................$114,070.91 Interest from 09/ 1/2008 through 02/28/2009 at 7.5000% ...................... $4,240.82 Per Diem int est rate at $23.43 Reasonable Atto ey's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................. $5,703.55 Late Charges from 10/01/2008 to 02/28/2009 ............................................$287.98 Monthly late charge amount at $41.14 Costs of suit and Title Search .....................................................................$900.00 Fees ............................................................................................................$129.25 Unapplied Funds ......................................................................................... ($41.14) Monthly Es ow amount $233.91 7. If the Mortgage is r nstated prior to a Sheriff's Sale, the Attorney's Fees s t forth above may be less than the amount derr anded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled t collect Attorney's fees of up to 5% of the rem ' g principal balance in the event the Property is sold t a third party purchaser at Sheriff's Sale or if a complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seek.i Defendants in this A right exists. If Defe proceeding, this Act liability that was dis pursuant to Pennsyl, a judgment of personal liability (or an "in personam on but reserves its right to bring a separate Action tc ants have received a discharge of their personal liabi r of Mortgage Foreclosure is, in no way, an attempt t urged in Bankruptcy, but only to foreclose the Mortg Lia law. judgment) against the establish that right, if such ity in a Bankruptcy ? re-establish the personal rge and sell the Property 9. Notice of Intention t Foreclose and .a Notice of Homeowners' Emergency been sent to Defendants by certified and regular mail, as required by Act 1 i Commonwealth of Pennsylvania, on the date(s) set forth in the true and cot attached hereto as Exhibit "B". The Defendants have not had the required the required time an Plaintiff has no knowledge of any such meeting beinj through the Plaintiff, the Pennsylvania Housing Finance Agency, or any ap Counseling Agency. WHEREFORE, Plaintiff der together with interest at the i Plaintiff which are properly until the Mortgage is paid in Assistance has of 1998 of the ect copy of such notice(s) ice-to-face meeting within requested by the Defendants ronriate Consumer Credit riands a de terns judgment in mortgage foreclosure in a sum of $125,291.37, -ate of $23.43, per day and other expenses, costs and charges incurred by the -hargeable in accordance with the terms of the Mortgage and Pennsylvania law full, and for the foreclosure of the Mortgage and Sheti ff s Sale of the Property. By: / / / l,?? / • / i / i GOLDBECK McCAFFERTY & BY: MICHAEL T. MCKEEVER, ESQt ATTORNEY FOR PLAINTIFF VERIFICATION Regina c Alexander as the r r tat; f +11 within named do her Plaintiff corporation best of my knowled; subject to the penalti #69231 FC DAVID ? 1103 Bridge Street N ep esen ve o % y verify that I am authorized to and do make this verifi id the facts set forth in the foregoing Complaint are I information and belief. I understand that false stater of 18 Pa. C.S. 4904 relating to unworn falsification to '?, ZZS WAIT v Cumberland, PA 17070 Plaintiff corporation ation on behalf of the ue and correct to the ,nts therein are made Exhibit.A NUM T "," LIN" UMM JILL IM piece or Pascal of IMW sitaate is MW C?rbss , OwOwland C mtr, I wylvania, bow desaxibed follow, to wit: a a point on the eastwlr Liao of asid point is ! and deists-ais a?-tea (40. 01 the tbMWW iT camas of 234wath (11th) and ZZAA "M e"teslr line of ft"" at"", zft? zdaates 00 *e1t, t and f (39.34) to a point at sootheslT uAs of land no Charles ; thea0a along s Smth 70 dsge 3f 6e009de !aa caw bandsed tsa 4" forty-"a OEM-kma feet to a ' t an the aaast ezU line of a t va (10) l4 along sane smith 19 dsgrass 27 sLaufts ftot; th t and swo oa.- +.ierrkAiL. (30.00) eam and niaw 70 dsgs+aes 32 atilaotes 00 aeoam r whst, booftedtbs (105.09) lest to a point, tb, .1103 ?e Ldp! 3'! I a -A-2'140W Loose being ? t, 11r Caebesiaud, 1?asrivania. Ulm 2" NOM: 20-23-0541-294 2MM the busbuA sad 9 is"0 Wh"a C1a mu" a. aaia sad M , by dead dat" J,r 16, 2h9 sad srq to" in land Crcastr in Dead >aek volti 444 at 9CSated sad and vife. ?rsTad onto David A. lhit and faith a. I T Certify this to be recorded In Cumberland County PA Recorder of Deeds M-4924 093 ! aemugh of I and most, shicb hat North of 0 ateme"; 27 30 ear or lato of adsoatoM 00 WMe (110.46) Ot MUM public 0 200004M ?t to a point; 0 huNt lad five Phan of andmed as P. , dss9t :'", 9, ms9band ?hifiit B ACT 91 NOTICE DA TE OF NOTICE: 01/20 /2009 TAK E ACTION TO SAVE YOUR HO ME FROM FORECL ? SURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMP ING TO COLLECT A DEBT OWED T OUR CLIENT. ANY INFORMATION OBTAINED F ROM YOU WILL BE U ED FOR THE PURPOSE OF COLLECTING THE D EBT. This is an official notice that the mortgage on our hom is in default and the lender intends to fo reclose. S ecific information about the nature of th e default is rovided in the attached pages. The HOME OWNERS MORTGAGE ASSISTANCE -D A M HEMAP ma be able to hel to save -your home. This Notice explains how the ro am orks. To see if COUNSELING A MAP can hel you must MEET WITH A C ENCY WITHIN 33 DAYS OF THE DATE OF THI NSUME R CREDIT S NOTICE Notice with ou w en-you meet with the Counseling Agency. . Take this The name a ddress and hone number of Consumer Credit Counse ling Agencies servin our County are lis ted at the end of this Notice. If ou have anuest ons ou ma call the Pennsylvania Hous ing Finance A enc toll free at 1-800-342-2397. ersons with im aired hearing can call 71 7 780-1869. This Notice contains important legal information. If you have any questions representatives at t he Consumer Credit Counseling Agency may be a , le to help explain it. You may also want to contact any attorney in your area. The local bar as sociation may be able to help you find a la wyer. La notificaci n en adjunto es de suma importancia, pues afecta s derecho a continuer viviendo en su casa Si no comprende el contenido de esta notification o tenga una traduccion immediatamente 11 anda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al iumero mencionad arriba. Puedes ser elegible para un prestamo por el programa llamado 'Homeowner's Em gency Mortgage Assistance Program" el cual pued salvar su casa de la >erdida del derecho redimir su hipoteca. 'repared by: GOLD ECK McCAFFERTY & McKEEVER Suite 5 00 - Mellon Independence Center. 701 Ma rket Street Philade lphia, PA 19106 Fax (21 5) 627-7734 1 Date: 01/20/20091 Homeowners Nam : DAVID A. WAIT and FAITH E. WAIT Property Address: 103 Bridge Street, New Cumberland, PA 17070 Loan Account No.: 2000153561 Original Lender: S ON MORTGAGE SERVICES INC. Current Lender/Se ricer: SAXON MORTGAGE SERVICES INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE YOU MAY BE ELIGIBLE FOR FINANCIAL MORTGAGE PAYMENTS IF YOU CO LY WITH THE PROVISIONS OF THE HOl EMERGENCY M RTGAGE ASSISTANCE ACT OF 1983 (THE " ELIGIBLE FOR E RGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMST. CONTROL, * IF YOU TINE A REASONABLE PROSPECT OF BEING MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ES PENNSYLVANIA OUSING FINANCE AGENCY. YOU MAY BE BEYOND YOUR ,E TO PAY YOUR BY THE - -_ --_•• m _ 01 z yr r uMMULUS URE - Under the Act, you are entitled to a temporary foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three days f rof mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. DATE. %_UUrnaALI NG AGENCIES -If you meet wi one of the consumer credit counseling agen ies listed at the end of this notice, the lender may NOT ' e action against you f] thirty (30) days aft the date of or this meeting. The names, addresses and tel hone numhem nf 2 forth at the end of L Notice. It is only necessary to schedule one lender . imm ediatel of your intentions. -- - ""• Al "r l jvici %YALVAL ASSISTANCE - Your mortg reasons set forth lat r in this Notice (see following pages for specific infbr ? Your default.) You ve the right to apply for financial assistance from the IH Mortgage Assistan Program. To do so, you must fill out, sign and file a ca Emergency Assistai ce Program Application with one of the designated consi agencies listed at the end of this Notice. Only consumer credit counseling ag' for the program and they will assist you in submitting a complete application' Housing Finance Agency. To temporarily stop the lender from filing a forecl? application MUST be filed or postmarked within thirty (30) days of your fact counseling agency. YOU SHO LD FILE A HEMAP APPLICATION AS SOON AS I HAVE A MEETIN WITH A COUNSELING AGENCY WITHIN 33 Di POSTMARK DAT OF THIS NOTICE AND FILE AN APPLICATION WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL PREVENTED FROM STARTING A FORECLOSURE AGAINST YOU] EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY S1 FORECLOSURE." meeting. Advise your is in default for the )n about the nature of 2eowner's Emergency deted Homeowner's er credit counseling ties have applications the Pennsylvania are action, your -face meeting with the USNIBLE. IF YOU YS OF THE WITH PHFA 1E TEMPORARILY , PROPERTY, AS AY OF YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION E N BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREV) T THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPL CATION IS EVENTUALLY "PROVED AT ANY TIME BEFORE A SHERIFF'S $ E, THE FORECLOSURE LL BE STOPPED. A%-bNUY ACTION - Available funds for emergency mortgage assistai ice are very limited. They will be disburse by the Agency under the eligibility criteria established b the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During t 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 Pe ylvania Housing Finance Agency of its decision on your.application. NOTE: IF YOU CURRENTLY PROTECTED BY THE FILING OF PET IN BANKRUPTCY, M) rRE FOLLOWING PART OF THIS NOTICE IS FO INFORMATION PU RPOSES ONLY AND SHOULD NOT BE CONSIDE ATTEMPT TO COL AS AN LECT THE DEBT. f you have flied bankruptcy you can still apply for located at: 1103 because: A. YOU HAVE 1 and the following (a) Monthly paymei (4 mos. at $1 (b) Late charges fro (c) Other charges; f (d) Other provision: (e) TOTAL AMOU ;FAULT - The MORTGAGE debt held by the above lender on your property Street, New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT r MADE MONTHLY MORTGAGE PAYMENTS foi ounts are now past due: t from 10/01/2008 thru 01/20/2009 015.75/month) $4,063.00 n 10/01/2008 thruOl/20/2009 (4 mos. at $41.14/month)I >crow, Inspec., NSF Checks of the mortgage obligation, if any 1T REQUIRED AS OF THIS DATE: $4,227.56 HOW TO CURE T E DEFAULT - You may cure the default within THIN Y (30) DAYS of the date of this notice BI PAYING THE TOTAL AMOUNT PAST DUE TO HE LENDER WHICH IS 227.56 PLUS kNY MORTGAGE PAYMENTS AND LATE CHARGS WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made khe:r_by cashier's check. within THIRTY (30) considered due imme If full payment of the intends to instruct its Sheriff to pay off the delinquency before tl reasonable attorney's started against you, y even if they exceed $ may also include oft av, vauva aausuv l."7 RV1V aalu Own I.V. SAXON MORTGAGE SERVICES INC. 4708 Mercantile Drive North Fort Worth, TX 76137 M THE DEFAULT - If you do not cure the default DAYS of the date of this Notice, the lender intends to e debt. This means that the entire outstanding balance liately and you may lose the chance to pay the mortgage, i total amount past due is not made within THIRTY (30) attorneys to start legal action to foreclose upon your mdi the following months 164.56 of this debt will be n monthly installments. AYS, the lender also E IS FORECLOSED UPON - The mortgaged property will be sold by the ?ortgage debt. If the lender refers your case to its attorneys, but you cure the lender brings legal proceedings against you, you will ski be required to pay the :es that were actually incurred, up to $50.00. However, f legal proceedings are i will have to pay all reasonable attorney's fees actually',' curred by the lender ).W. Any attorney's fees will be added to the amount y owe the lender, which reasonable costs. If you cure the default within the TV (An) nsV 4 v 11MK LENDE REMEDIES -The lender may also sue you personally f?r the unpaid principal balance and all oth sums due under the mortgage. RIGHT T C THE DEFAULT PRIOR O SHERIFF'S SALE - If u have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings ha a begun, you still have .vv++uvv?vu with the Sheriffs Sale asspecified in writing b the lender and b rformin gny other re uirements 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 approximate y _four (4 to six O months from the date of this Notice. A notice of the actual date of the Shea s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will in ase the longer you wait. You may find out at y time exactly what the required payment or action wi?l by contacting the lender. SAXON MORTGAGE SERVICES INC. Address: the mortgaged p, Sheriffs Sale, a ] the lender at any will assume the m and costs are paid * TO DEBT OR TO BC THIS DEBT. 4708 Mercantile Drive North Fort Worth, TX 76137 r: 888-325-3502 n: Loss Mitigation Department FF'S SALE - You should realize that a Sheriffs Sale wil and your right to occupy it. If you continue to live in 0 t to remove you and your furnishings and other belongiih [ORTGAGE - You may sell or transfer your home to i I ge debt, provided that all the outstanding payments, ch* to or at the sale and that the other requirements of the m end your ownership of property after the s could be started by r or transferee who and attorney's fees ale are satisfied. YOU MAY ALSO HAVE THE RIGHT: THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE I MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF 5 * TO H AVE THIS DEFAULT CURED BY ANY THIRD PAR ACTING ON YOUR BEHALF. * TO VE THE MORTGAGE RESTORED TO THE SAME OSITION AS IF NO DEFAULT HAD CURRED, IF YOU CURE THE DEFAULT. (HOWEVE R, YOU DO NOT HAVE THIS RIG TO CURE YOUR DEFAULT MORE THAN THREE MES IN ANY CALENDAR YEAR .) * TO A SSERT THE NONEXISTENCE OF A DEFAULT IN AN Y FORECLOSURE PROCEEDING OR . OTHER LAWSUIT INSTITUTED UNDER THE ORTGAGE DOCUMENTS. * TO A SSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE ENDER. * TO S EEK PROTECTION UNDER THE FEDERAL BANKRU PTCY LAW. Contact: Loss Mitigation Department Phone Number: 888-325-3502 III 6 .i HEMAP Consui Report lad updated:12nWOW Lycom.Clntn Co Comm to Comm 2138 Lincoln Street P.O. Box 3888 WMamsport, PA 17703 570328.0587 COLUMBIA County Ar WICI n Credit Counselling Ins! 212 Berwick-Hm"On Hwy Neeoopeck, PA 18635 888A68.8847 CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 570.22227 800.922.9537 CRAWFORD County Booker T. Washington Center 1720 Hound Street Erb, PA 16503 814A53.5744 CCCS of Western PA 4402 Peach Street Erb, PA 16509 888.5112227 at 108 888.5112227 ext 108 Center for Fatuity SOMICea, inc. 213 Center Street Meadvlle, PA 16335 814.337.8450 Greater Erb Community Action 18 West 9TH Street Erb, PA 18501 814A59A581 Shenango Valley Urban Leag, 601 Indbna Ave" Fwrgk PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erb, PA 18503 814A52.8113 CUMBERLAND Coun?l Adnma County Interfaith None 40 E High Street Gettysburg, PA 17325 717.334.1518 Credit Counseling Agencies 1 PM Committee I, Inc. CCCS of Western PA 2000 Lingiestown Road Harrbburg, PA 17102 888.5112227 888.5112227 Community Action Commission of 1514 Deny Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.2322207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 Community 1514 Derry Street Harrisburg, PA 17104 717.232.9757 ACtian Commission Capital Region PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.3422397 DAUPHIN County CCCS of Western PA 2000 Lingbetown Road Harrisburg, PA 17102 888.5112227 888.5112227 ioreship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.2322207 opportunity inc. 301 East Markel Street York, PA 17403 717.424.3645 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.3422397 ng Autho@y DELAWARE County Amm Housing Corporation 848 North Broad Street Philadelphia, PA 19130 215.765.1221 page 7 of 19 ?t V -yak \a w It 7 ? Q7 ( . .a Sheriffs Office of Cumberland County R Thomas Kline ?slovp M cuftp Lawara L bcnorpp Solicitor Sheri 'r7 Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE "RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/14/2009 09:44 AM - Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on March 14, 2009 at 0944 hours, he served a true copy of the within Complaint in Mortgatge Foreclosure, upon the within named defendant, to wit: David A. Wait, by making known unto himself personally, defendant at 1103 Bridge Street New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/14/2009 09:44 AM - Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on March 14, 2009 at 0944 hours, he served a true copy of the within Complaint in Mortgatge Foreclosure, upon the within named defendant, to wit: Faith E. Wait, by making known unto herself personally, defendant at 110; Bridge Street New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $59.30 (PAID) SO ANS RS, March 16, 2009 2009-1505 HSBC Bank USA VS David A. & Faith E. Wait R THOMAS KLINE, SHERIFF By Deputy Sheriff ra C (70 t f. _ "TI 0 l7. Co .4.... r.w --"r 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 HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR ACE SECURITIES CORP. HOME EQUITY LOAN TRUST, SERIES 2006-NCI 4708 Mercantile Drive North Fort Worth, TX 76137 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. No. 09-1505 DAVID A. WAIT FAITH E. WAIT 1103 Bridge Street New Cumberland, PA 17070 Defendants PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. Michael T. McKeever, Esquire Attorney for Plaintiff R ED- O!,-rl E OF T""" ," " ?T#Y 2009 APR 24 AM 11: 16 Cufk"NTY