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Home My WebLink About09-1664..A GOLDBECK 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX Mortgagors and Record Owners 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Defendants OF CUMBERLAND COUNTY Term el V l No. lllj1 t CI I IL A Fa AC71t?1;?'GAGE ,,LO'S E 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 m y proceed without you and a judgment may be entered against you by the Court without further notice for an money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money r 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 THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT H] IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEI QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE 1 DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVI' NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA COR IN THE COURT OF COMMON PLEAS ACTION - LAW ACTION OF MORTGAGE FORECLOSURE C_E SET FORTH BELOW. A LAWYER. Y BE ABLE TO PROVIDE L SERVICES TO ELIGIBLE 1DERSE CONTRA LAS ,ED RESPONDA DENTRO PARA DEFENDERSE ES 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 P,UEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, IN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA C N TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE UE USTED PUEDA PERDER D1NERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUI A. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA A UI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OF CINA PUEDE PROVEERE 1NFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERV CIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O G TIS. CUMBERLAND COUNTY BAR ASSOCIATId 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 ACT NOW! Even though your lender (and our client) has filed an Action of Mortgaged Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 0. Call an attorney. For referrals to a qualified attorney call either of thel following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facin 4). Pennsylvania Housing Finance Agency also offers other loan prograr in default. Please See the PHFA website http://www.phfa.orWconsumers/homeo, 5). Call the Plaintiff (your lender) at and ask to speak to someone about Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.or,-/forecle 7). Call or contact our office to request the amount to bring the account c or request a Loan Workout / Home Retention Package. Call our toll free number at homeretention&goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825• package you requested will be mailed to the address that you request or faxed if 3 information. The attorney in charge of our firm's Homeowner Retention Departn can be reached at 215-825-6311 or Fax: 215-825-6411. Please reference our Atto ree counseling. the Loss of Their Homes. > that may assist homeowners Mitigation or Home rent, or payoff the mortgage 1-866-413-2311 or via email 29. The figure and/or i leave a message with that it is Courtenay Dunn who ;y File Number of 7833917C. 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION, 3451 Hammond Avenue, Waterloo, IA 50702. 2. The names and addresses of the Defendants are ROBERT L. LAMORE UX, 850 Yverdon Drive, Camp Hill, PA 17011 and LOUISE M. LAMOREAUX, 850 Yverdon Drive, Camp Hill, PA 17011, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. Defendant, THE UNITED STATES OF AMERICA, is named a Defend nt pursuant to 28 U.S.C. Section 2410, and Plaintiff requests that a judicial sale be held of the Pr perty. 4. On January 14, 1999 mortgagors made, executed and delivered a mortg ge upon the Property hereinafter described to ALTERNATIVE LENDING MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1515, Page 133. The mortgage has been assigned to: GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION by assignment of Mortgage June 26, 2001 as Book 679, Page 46. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accord ce with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its oblig tion to attach documents to pleadings if those documents are matters of public record. 5. The Property subject to the Mortgage is more fully described in the lega? description set forth as Exhibit "A„ ("Property„) 6. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 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 balanc and all interest due and other charges are due and collectible. 7. The following amounts are due to Plaintiff on the Mortgage: ................................................................................II Principal Balance 'i.$101,943.88 Interest from 09/01/2008 through 02/28/2009 at 6.7500% .................1.....$3,411.85 Per Diem interest rate at $18.85 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ..............1.....$5,097.19 Late Charges from 10/01/2008 to 02/28/2009 ............................................. $194.54 Monthly late charge amount at $38.91 Costs of suit and Title Search ..................................................................... $900.00 Monthly Escrow amount $360.29 8. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fee than the amount demanded based on work actually performed. The Attol conformity with the Mortgage and Pennsylvania law. Plaintiff is entitle4 to 5% of the remaining principal balance in the event the Property is soli Sheriff's Sale or if the complexity of the action requires additional fees i demanded in the Action. $111,547.46 set forth above may be less ney's Fees requested are in l to collect Attorney's fees of up l to a third party purchaser at n excess of the amount 9. Plaintiff is not seeking a judgment of personal liability (or an "in pers, Defendants in this Action but reserves its right to bring a separate Act right exists. If Defendants have received a discharge of their personal proceeding, this Action of Mortgage Foreclosure is, in no way, an atte liability that was discharged in Bankruptcy, but only to foreclose the D pursuant to Pennsylvania law. _"judgment) against the to establish that right, if such bility in a Bankruptcy t to re-establish the personal tgage and sell the Property 9. Plaintiff is not seeking a judgment of personal liability (or an "in ers Defendants in this Action but reserves its right to bring a separate Act right exists. If Defendants have received a discharge of their personal proceeding, this Action of Mortgage Foreclosure is, in no way, an atte liability that was discharged in Bankruptcy, but only to foreclose the D pursuant to Pennsylvania law. 10. Notice of Intention to Foreclose and a Notice of Homeowners' Emerge] been sent to Defendants by certified and regular mail, as required by Ac Commonwealth of Pennsylvania, on the date(s) set forth in the true and attached hereto as Exhibit "B". The Defendants have not had the requii the required time and Plaintiff has no knowledge of any such meeting b through the Plaintiff, the Pennsylvania Housing Finance Agency, or an3 Counseling Agency. 11. THE UNITED STATES OF AMERICA, the above named Defendant, in Exhibit' C ' which is attached and made part of this Complaint. n" judgment) against the to establish that right, if such )ility in a Bankruptcy to re-establish the personal gage and sell the Property cy Mortgage Assistance has 160 of 1998 of the :orrect copy of such notice(s) d face-to-face meeting within ing requested by the Defendants appropriate Consumer Credit a lien filed of record, set forth WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $111,547.46, together with interest at the rate of $18.85, per day and other expenses, costs an 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. 7, BY GOLDBECK McCAFFERTY & BY: MICHAEL T. MCKEEVER, ESQL ATTORNEY FOR PLAINTIFF VERIFICATION MEWS"hem Iamited Signing Officer as the representative of I, within named do hereby verify that I am authorized to and do make this v, plaintiff corporation and the facts set forth in the foregoing Complaint best of my knowledge, information and belief. I understand that false st subject to the penalties of 18 Pa. C.S. 4904 relating to unworn Date:_______i_ A Plaintiff corporation ation on behalf of the true and correct to the therein are made to authorities. CORPORATION Officer #78339FC ROBERT L. LAMOREAUX and LOUISE M. 850 Yverdon Drive Camp Hill, PA 17011 Ex,hibit A ALL THAT CERTAIN place or parpl of brrtd SUM In the Smug" of tArormMy County of C nd and Corttaionwwph of Paw+aYh+aNa, more parfkaUory bounded and 41101 d, to wit BEOINmwe at t pWnt on ffie Wn of Y-mon Drive pdiM la 110 hat BauF offt Sou ihefatit e1a1111aold fNtl ohsl dd Ptak alOnOdMAdNM Wt Nos. b and ! "C". ?? d ? in ea e.m r.. ..... da0taaa 58 mYa4ae a a daarJlen ffi tN. a pow. 60 oNOi of rEO?I'FII?fO. ?v ,. ?... ?r? ?r e.arwe u r mnu1N CMt.a dlwn00 Ot i00 t to EEING Lot No. B. Block "C" Plan of RNarMru Weak which pin 4 rooetd" Ift 00 Ct'Ike of the Recorder of Deeds in and for Cur ftftnd Count', pannrylwnta, In Pbm gook 10, page 28. P VINO 7HERMN ERECTED a dwefllnp house proven and munmrad as 850 YwMon Drive, Camp mill, nsyhrania. BEING THE SAME PREMISES vA t Lois H. Muwasnan, wtdww, by peed 4WAd and mwrded AprY t1 ?3 n 110 OtM» of" Reoordar of DOW! In and for CumbOhnd County b Deed SM& P'- Vee e,. M a... L until ":;;a of P-nnsylvenfd 1 CarauyatCumberiand 8t3 x rued tp the office for the r nil of Ossds r r ' n•• and e?gypiberlandCoa "4R r.? wil Carl) PA L scil5i5m A39 Eo.?hibit (13 GMAC Mortgage, LLC 3451 Hammond Avenue Waterloo I IA 50702 Date: 12/02/08 ACT 91 NOTICE TAKE ACTION TO SA YOUR HOME FROM FORECLOSURE home This Notice explains how the uroeram works. Notice with you when you meet with the Counseline Agency. This Notice contains important legal information. If you have any questions, repres Counseling Agency may be able to help explain it. You may also want to contact an bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AF CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENI NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLJ AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO I LLAMADO HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE P PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR c HOMEOWNER S NAME(S): ADDRESS: LOAN ACCOUNT NUMBER: ORIGINAL LENDER: CURRENT LENDER/SERVICER: at the Consumer Credit in your area. The local :TA SU DERECHO A ) DE ESTA [ANDO ESTA L NUMERO R EL PROGRAMA )GRAM, EL CURL HIPOTECA. LOUISE LAMOREA X 850 YVERDON R CAMP HILL PA 17011 0307094456 GMAC Mortgage, HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE THE PROVISIONS OF THE IF YOU COLY WITH ` MORTGAGE FOR EM THE ACT ), YOU MAY BE ELIGIBLE ACT OF ASSISTANCE RGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEY OND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PA YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISH D BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temp ary stay of foreclosure on your mortgage for thirty-three (33) 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 agenciTes listed at the end of this Notice. THIS MEETING MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES If you meet with one of the con, agencies listed at the end of this notice, the lender may NOT take action against you for thirty-tl this meeting. The names addresses and telephone numbers of designated consumer credit comb in which the property is located are set forth at the end of this Notice. It is only necessary to scl meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for this Notice (see following pages for specific information about the nature of your default.) If yp resolve this problem with the lender, you have the right to apply for financial assistance from tl" Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeow Program Application with one of the designated consumer credit counseling agencies listed at t consumer credit counseling agencies have applications for the program and they will assist you application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or (33) days of your face-to-face meeting. er credit counseling (33) days after the date of one face-to-face e reasons set forth later in have tried and are unable to Homeowner s Emergency r s Emergency Assistance end of this Notice. Only 1 submitting a complete )stmarked within thirty-three YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO D SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING 01 ? A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFO ATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it u to date). NATURE OF THE DEFAULT The MORTGAGE debt held by the above lender is on your property located at 850 YVERDON DR CAMP HILL PA 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following amounts are now past due: 10/01/08 through 12/01/08. See attached Exhibit for f Monthly Payments $ 3408.76 Late Charges $ 77.82 NSF $ 0.00 Inspections $ 0.00 Other (Default Expenses and Fees) $ 0.00 Optional Insurance $ 0.00 Suspense $ 0.00 TOTAL AMOUNT PAST DUE: $ 3486.58 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ag months and the breakdown. HOW TO CURE THE DEFAULT You may cure the default within THIRTY-THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, RICH IS $ 3486.58, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-THREE (33) DAY PERIOD. Pa ments must be made either b cash cashier s check or certified check made payable and sent to: GMAC Mortgage, LLC ATTN: Payment Processing 3451 Hammond Avenue Waterloo I IA 50702 You can cure any other default by taking the following action within THIRTY-THREE (33) AYS of the date of this letter: (Do not use if not applicable.) Not Applicable IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within THIRTY-THREE (33) DAYS of the date of this Notice, the lender intends to exercise its ri hts to accelerate the mort a e bt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose th chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIR FY-THREE (33) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose u n our mor gaged Drowrty. IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sod by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney s fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney s fees actually incurred by the lender even if they exceed $50.00. Any attorney s fees will be added to the amoo nt you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY HREE 33 DAYS period you will not be required to pay attorney s fees. OTHER LENDER REMEDIES The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF S SALE If you have not cured the default within the THIRTY-THREE (33) DAY period and foreclosure proceedings have begun, you still have t e right to cure the default under the mortease. Curing your default in the manner set forth in this notice will restore y our mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF S SALE DATE It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately six (6) months from the date o 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 needs to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: GMAC Mortgage, LLC ATTN: Loss Mitigation Address: 2711 North Haskell Ave. Suite 900 Dallas, TX 75204 Phone Number: 800-850-4622 Fax Number: 866-709-4744 Contact Person: Collection Department EFFECT OF SHERIFF S SALE You should realize that a Sheriff s Sale will end your o ership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s S le, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTAGE You MAY or MAY NOT sell or transfer your home t a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorne' s fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ONI YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAV 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 LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER Appl that 1 If yo at 8C this i Coll, Loaf 503 ;d for itely ming EXHIBIT 10/01 /08 through 12/01/08 Mo. Pmt. Amt. $ 11 8.61 ACT 91 NOTICE DATE OF NOTICE: Februa TAKE ACTION TO SAV HOME FROM FORE THIS LAW CL FIRM IS A DEBT COLLECTOR AND WE ARE ATTE? DEBT OWED TO OUR CLIENT. ANy INFORMATION OBTAINIE USED FOR THE PURPOSE OF COLLECTING TE "M.-:- __ -.I- • - _ ftlheci ,pages Noti ce with you when o - - y" + v; l n? LH, Ym,et with the Counseling A encv. h ? can. call 717 78 -1 9. This Notice contains important legal information. If yo representatives at the Consumer Credit Counseling Agency may be You may also want to contact any attorney in your area. The local bar to help you find a lawyer. La notification en adjunto es de suma importancia, pues afecta viviendo en su casa. Si no comprende el contenido de esta notification immediatamente llamanda esta agencia (Pennsylvania Housing Finano numero mencionada arriba. Puedes ser elegible pars un prestamp p( "Homeowner's Emergency Mortgage Assistance Program" el coal pue perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax(215)627-7734 y 9, 2009 YOUR SURE FING TO COLLECT A FROM YOU WILL BE DEBT. have any questions, le to help explain it. sociation may be able su derecho a continuar obtenga una traduccion Agency) sin cargos al r el programa llamado Ie salvar su casa de la Date: February 9, 2009 TO: ROBERT L. LAMOREAUX ; Homeowners Name: ROBERT L. LAMOREAUX and LOUISE M. I Property Address: 850 Yverdon Drive, Camp Hill, PA 17011 Loan Account No.: 0307094456 Original Lender: ALTERNATIVE- LENDING MORTGAGE CORP. Current Lender/Servicer: GMAC MORTGAGE CORPORATION HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE M0 TGAG . PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOM EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "A ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMST. CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY ' QUMMENTS PENNSYLVANIA HOUSING FINANCE AGENCY. YOU MAY BE CES BEYOND YOUR TO PAY YOUR ABLISHED BY THE TEMPORARY STAY OF FORFCI,OSURE _ Under the A foreclosure on your mortgage You are enti led to a temporary for thirty (30) days from the date of this Notic'e (plus three (3) days forof mailing). During that time you must arrange and attend a "face-to-face" m ing with one of the designated consumer credit counseling agencies listed at the end of this Noti _ D- A '. CONSUMER CREDIT COUNSELING AGENC - Consumer credit counseling agencies listed at the end of this notice, the lendeif th r may NO take acti ta gaemst yo for u (30) days after the date of this meeting. The names, addrmgM A„,1 + -?h_ _.? 2 forth at he end of this No 'c'?, It is only necessary to schedule one face- lender immediately of your intentions. A-?-P?N FOR MORTGAGE ASSISTANCE - Your mo reasons set forth later in this Notice (see following pages for specific infoi your default.) You have the right to apply for financial assistance from th Mortgage Assistance Program. To do so, you must fill out, sign and file a Emergency Assistance Program Application with one of the designated co agencies listed at the end of this Notice. Only consumer credit counseling for the program and they will assist you in submitting a complete Housing Finance Agency. To temporarily stop the lender from filinapplicati, g a for application MUST be filed or postmarked within thirty (30) days of your f counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON A HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATIt WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WH PREVENTED FROM STARTING A.FORECLOSURE AGAINST Ya EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY FORECLOSURE." meeting. Advise your :gage is in default for the nation about the nature of Homeowner's Emergency .ompleted Homeowner's sumer credit counseling .genies have applications n to the Pennsylvania closure action, your t-to-face meeting with the POSSIBLE. IF YOU AYS OF THE i WITH PHFA BE TEMPORARILY R PROPERTY, AS TAY OF YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION FROM STARTING A FORECLOSURE ACTION, BUT F YOUR P LICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage ass' tance are very limited. They will be disbursed by the Agency under the eligibility criteria establish by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decisio after it receives your application. During that time, no foreclosure proceedings will be the time requirements set forth above. You will be notified direct the p t you if you have met Finance Agency of its decision on your directly Y ylvania Housing application. ME- L URRENTLY -- - _ •,,,, , j •lu?. v r t? Yl+j'1"!'PION UPTCY,, THE FOLLOWING PART '?F T$S NOTICE I R PION PURPOSES ONLY AND SHOULD N.OT BL CONS TO COLLECT THE. DEBT RED AS AN : Of you have filed bankruptcy you can still apply for Eme n Mo a Aasice. 3 NATURE pF THE I?FFd;iTrT _ The MORTGAGE debt held by the ab located at: 850 Yverdon Drty Camp ?.. , PA 17011 IS SERIOUSLY ove lender on our Y property DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENT and the following amounts ar for the followin mon g the e now past due: (a) Monthly payment from 10/01/2008 thru 2/9/2009 (5 mos. at $1,138.61/month) $5 693 05 , . (b) Late charges from 10/01/2008 thru 2/9/2009 $194 55 . (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTA L AMOUNT REQUIRED AS OF THIS DATE: $5,887.60 HOW TO CURE THE DEFAULT -You may cure the default within date of this notice BY PAYING THE TOT ( DAYS of the AL AMOUNT PAST DUE T IS M A7.60, PLUS ANY MORTGAGE PAYMENTS AND LATE CHA D LE THE DB OM H UE DURING THE THIRTY (30) DAYPERIOD P GES WHICH C E . en must be certified check or money 0-.J- c able and sent to: e ?' b cashier's chec GMAC MORTGAGE, LLC LOSS MITIGATION DEPARTMENT 3451 Hammond Avenue Waterloo, IA 50702 IF YOU DO NOT CC?F THE DEFAULT - If you do not cure the defaul within THIRTY (30) DAYS of the date of this Noti ce, 1 This means that the entire outstanding bah considered due immediately and you may lose the ch t of this debt will be ance o If full payment of the total amount past due is not made wit in THIRTY (30 int d Din mothly e in AY n a en s to instruct its attorneys to start legal action to foreelns? .¦.,..?.....,._ S the I? der lso __..__ _ _ . I MORTGAGE TV 1''n?-ECLOSED UPON -The mortgaged Sheriff to pay off the mortgage debt. If the lender refers your cate to its propery wi so by the alto eys,lbut yon cure e delinquency before the lender brings legal proceedings against attorney's fees that were actually incurrep to $50.00. Howevll it ill e be to gal required i pay the ngs started against you, you will have to pay all reasonable attorney's fees actually incurred by?l derma even if they exceed $50.00. Any attorney's fees will be added to the amount ou owe the lender, which may also include other reasonable costs. If mom- you M AI not cure the d t th EY 30 Y be reaulred to a uttorne 'fees. QTHE$ II&Du RMr, DIES -The lender may also sue you balance and all other sums due under the mortgage. Y personally f the unpaid principal G O CURE? P AULT P R S 'S SALE - If you have not cured the default within the THIRTY' (30) DAY period and foreclosure proceedings have begun, you still have the ri t to cure the default and ni-P t tt,o oa?e _ _ _ _ o under the mortga e. burin "u"" ° ° irements ----? g your default in the manner set forth In this notice win restore your mortgage to the same position as if you had never defaulted. EAR IL EST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a bheritFs Sale of the mortgaged property could be held would be approximately months from the date of this Notice. A notice of the actual date of the S eriffs four(4) beesent to you before the sale. Of course, the amount needed to cure the default will crease the longer you wait. You may find out at any time exactly what the required payment or action ll by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: __GMAC. MORTGAGE, LLC Address: 1451 Hammond Avenue Waterloo, IA 50702 Phone Number: 800-850-4622 Fax Number: 319-236-7437 Contact: Loss Mitigation Department E CT F IS SALE - You should realize that a Sheriffs Sale ill end your ownership of the mortgaged property and your right to occupy it. If you continue to live it i the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belon ' property after the the lender at any time. gs could be started by OPTION OF MORTG GE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding and costs are paid prior to or at the sale and that the other payments, c urges and attorney's fees requirements of the mortgage are satisfied. YOU MAY ALSO HAVE TAT RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY FF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HA_ VE THIS DEFAULT CURED BY ANY THIRD P BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SA? DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOW HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THR] CALENDAR YEAR) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IT PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER Tj DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE Yi ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BAM Contact: Loss Mitigation Department Phone Number:'800-850-4622 TY ACTING ON YOUR POSITION AS IF NO 'ER, YOU DO NOT TIMES IN ANY ANY FORECLOSURE E MORTGAGE MAY HAVE TO SUCH RUPTCY LAW. 6 HEMAP Consumer Credit Counseling Agencies Report last Wdakrd: 12123R0081:0*1 PM Lysom.Ck* Co Comm to Comm Action 2138 Lincoln Steel P.O. Box 3588 MarrWort, PA 17703 570.326.0587 COLUAAUTA County 2 2 Bar A*44 reNm i ting Nucopeck, PA 15636 886.466.8847 CCCS of Nortiresetern PA 401 Laurel Skeet Pktft% PA 18640 570,602,2227 800.822.9537 CIlAWFOM County Bodes T. W Wik*on Center 1720 HoMrrd Street Erie, PA 16503 814A53.5744 CCCS of Western PA 4402 Peach Street Erb. PA 16609 888.511.2227 &d 108 888.511.2227 011 108 Center for Family servlcea, Ins. 213 Center Street Meadville, PA 18335 814.337.8460 8 rsdw Ede CommunIty Action Committee 18 YMnt 8TH Street Erie, PA 16501 814ABOA581 Shanarylo Halley tlrosn LaiWe, Inc. 601 krd om Avenue Farrell, PA 18121 724.981.5310 irk ft"M Center 1701 Parade Street Erie, PA law 814.482.6113 CUMBERLAND Cou Adana County ietet%hh Notslng Audnrly 40 E High Skeet OaBysburg, PA 17328 717334.1518 CCCS of Western PA 2000 lkrgissbwn Road Harrbbory, PA 17102 888.5112227 888.5112227 Community Action Commks 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Lovaehiy, k% 2320 North 5th Meet HaMsburg, PA 17110 717.232.2207 Mamnatira 43 Phledetphia Avenue YVIRrmboro, PA 17288 717.7523285 PHFA 211 North Frwd Street Hanbbung, PA 17110 717.780.3940 800.3422367 DAUPHIN County CCCS of Western PA 2000 Lingbeiow Road Harrisburg, PA 17102 888.511.2227 888.511.2227 CommueMy Action Cwmmtpion 1514 Derry stow Harrisburg, PA 17104 717.232.9757 Loveshlp, lm. 2320 North 5th Street Hanis&M PA 17110 717.2322M07 Opportunity inc. 301 East Market Skeet York, PA 17403 717.424.3845 PIRA 211 North Front Street HanMxft, PA 17110 717.780 3940 800.3422397 DELAWARE County Acorn Housing Cerimaese 848 North Broad Street PABadelphia, PA 19130 215.785.1221 Page 7 of 19 of Captial Raub" 615E Department of the Treasury - Internal Revenue Servibe form 668 (Y)(c) I WE . _e ?L•_ a___r e•__. a t_.. Mov. February 20041 II%WNLW WI 111'CgC[pa I Q^ RAWIN I. Area: Serial Number For O tl nal Uxo by Recording Office SMALL Lien Unit ss 29.3AX8D AREA #z Phone: ( (aoo)600) 3253903 Lien 406828007 ? -. 73?T ! J "y As PtOVM d by secdon 6321, 6322, and 6323 of the IntenW Rtvenm lti C k h k A e" K"W 1 L38/S awast and pena es) e that taxes ( ode, We are EMM A aat tdw hm (rave beam asnod apainst the &UgWk t n=Wd taa8tOW. We have made - ^1C a demand for PWMM of tMs Nabilty, bat It realms unpaid. 'therefore, # 14 • ?? r 010 there its a llen In favor of the ti*W Stater on alt property and ridrts to a of chese taxes, a>1td to d " me ` k a ar'7' y y me rat pt , lnt» and ccom that Name o Taxpayer ROBERT L LAMOREAUX Residence 850 XVERDON DR CAMP HILL, PA 17011-1850 E EE 011 TAXT RERFASE MF0;7MONs Far each assessment listed below, s notice of the lien 19 refiled by the date given in column (o), this notice shag, F e day following such dpta, operate as a certificate of release as defitled in C 6325(a). Ta>< Perlod pate of test Par for Un"M ealettt'.e Kind of Tax EROM Uked ylntt Dhm Mr At:sewebtt R of ASOGOMW a b c d e 1040 12/31/2005 XXX-SCR-9801 05/22/2006 06/21/2016 6334.63 C-) c,- 4 Place of Filing Prothonotary Cumberland County Total $ 6334.63 Carlisle, PA, 17013 This notico was prepared and signed at DETROIT, MI , on this, the 29th day of November 2007 5lgnature R for REGINA OWENS AC3 (800) 829-3903 22-00-acos v Low to Wks aeWiedgment is rat easettt si to the valloky Notloe of Fedmef Tex een Rev. Rul. 71-466,1971 - 2 C.B. 4091 P- t -10lpr BY Raratdrat Office rm "GM(c) tRov. 2-20041 CAT. NO 60025X ZrI w Sheriffs Office of Cumberland County R Thomas Kline 019 of acaa?b?r Edward L Schorpp Sheri 40 q Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE skERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/18/2009 06:01 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on March 18, 2009 at 1801 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert L. Lamoreaux, by making known unto Robert L. Lamoreaux personally, at 850 Yverdon Drive, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing tc him personally the said true and correct copy of the same. 03/18/2009 06:01 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on March 18, 2009 at 1801 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Louise M. Lamoreaux, by making known unto Robert L. Lamoreaux, husband of defendant, at 850 Yverdon Drive, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $57.50 (PAID) SO ANSWERS, March 19, 2009 R THOMAS KLINE, SHERIFF Docket No. 2009-1664 DeputySheriff/ GMAC Mortgage v Robert L. Lamoreaux and Louise M. Lamoreaux f -71 ? ul In the Court of Common Pleas of Cumberland Cumberland County GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX (Mortgagor(s) and Record Owner(s)) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Defendant(s) PRAECIPE FOR JUDGMENT No. 09-1664 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 ROBERT L. LAMOREAUX and LOUISE M. LAMOREAUX and THE UNITED STATES OF AMERICA by default for want of an Answer. Assess damages as follows: Debt Interest from 04/28/2009 to Date of Sale per diem at $18.85 Total (Assessment of Damages attached) $113,439.16 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ?? A, 1?-hJ? ?? I??ll ! Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW 4.4 m au a=9 , Judgment is entered in favor of GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION and against ROBERT L. LAMOREAUX and LOUISE M. LAMOREAUX and THE UNITED STATES OF AMERICA by default for want of an Answer and damages assessed in the sum of $113,439.16 as per the above certification. nn'!!? ?,??-' ??i ?. %rothonotary -14 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY V. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX AND UNITED STATES OF AMERICA Defendants STIPULATION CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-1664 It is hereby stipulated and agreed by and between GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION, plaintiff, and the defendant, United States of America, as follows: 1. That the premises referred to in the Plaintiffs Complaint is owned by the defendant(s), ROBERT L. LAMOREAUX and LOUISE M. LAMOREAUX. 2. The plaintiff filed an action in mortgage foreclosure to the above number and term, and named as defendant(s), ROBERT L. LAMOREAUX and LOUISE M. LAMOREAUX. 3. The parties hereby agree that the United States of America shall, and hereby is, named as a party in the above action, in accordance with 28 U.S.C. § 2410 et sea. 4. The United States of America hereby accepts service of the complaint and waives its right to file an answer or other responsive pleading thereto, and waives any objection it may have to the judgment entered against the defendant(s). :P? 5. The United States of America has 1 tax lien(s) against the property which is/are subject to the action of mortgage foreclosure dated December 7, 2007, 2007-07387, totaling $6,334.63, both entered in the Prothonotary's office of Cumberland County Pennsylvania. 6. That the Federal Tax Liens described in Exhibit "A" to this Stipulation are junior in time to the Plaintiffs mortgage set forth in paragraph three (3) of plaintiffs Complaint. 7. That the Defendant, United States of America, agrees to the entry in this action of a judgment in favor of the Plaintiff and against the United States of America for foreclosure and sale of the mortgaged property. 8. That the defendant, United States of America, is not indebted to the plaintiff. 9. That the aforesaid premises shall be sold at a judicial sale, notice of which was served on the defendant, United States of America. 10. That the judicial sale of said property shall discharge the Federal Tax Lien described in Exhibit "A". 11. That the proceeds of sale shall be divided and distributed as the parties may be entitled and any funds due the United States shall be sent to the Internal Revenue Service, PO Box 1267, Harrisburg, PA 17108-1267.. The check shall be made payable to "United States Treasury" and shall include the name and social security number of the taxpayer. 12. That the defendant, United States of America, preserves its right of redemption as provided in Title 28 United States Code, Section 2410 (c). 13. The parties to this Stipulation shall bear their own respective costs in this proceeding. Dated: March 24, 2009 -? 10 010 By: 11401, ?r,•w Michael T. McKeever, Esquire Attorney for Plaintiff Martin C. Carlson Acting United States Attorney Dated: `? S 0 BY: f ?,A 0? Melissa Swauger Assistant U.S. Attorney 78339FC 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: April 13, 2009 TO: ROBERT L. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff VS. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX (Mortgagor(s) and Record Owner(s)) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Defendant(s) TO: ROBERT L. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-1664 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 hvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. Mg&Mlr GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 78339FC 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: April 13, 2009 TO: LOUISE M. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX {Mortgagor(s) and Record Owner(s)) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Defendant(s) TO: LOUISE M. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-1664 IMPORTA 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 Raw Cerlisk, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Cadisk. PA 17013 Michad T. McKeever - -- GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. That the above named Defendant, ROBERT L. LAMOREAUX, is about unknown years of age, that Defendant's last known residence is 850 Yverdon Drive Camp Hill, PA 17011, 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: "\I--[ \0 1UM I, ?- ? llY fl Uto - 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, LOUISE M. LAMOREAUX, is about unknown years of age, that Defendant's last known residence is 850 Yverdon Drive Camp Hill, PA 17011, 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: AJ109 \).1tA \ ' au U / 1 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff VS. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX (Mortgagor(s) and Record owner(s)) 850 Yverdon Drive Camp Hill, PA 17011 Defendant(s) THE UNITED STATES OF AMERICA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-1664 ORDER FOR JUDGMENT Please enter Judgment in favor of GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION, and against ROBERT L. LAMOREAUX and LOUISE M. LAMOREAUX 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 $113,439.16. utwu A - 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 and that the name(s) and last known address(es) of the Defendant(s) is/are ROBERT L. LAMOREAUX, 850 Yverdon Drive Camp Hill, PA 17011 and LOUISE M. LAMOREAUX, 850 Yverdon Drive Camp Hill, PA 17011; ulmu 1- UC, Wz ,4 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 $101,943.88 Interest from 09/01/2008 through $4,505.15 04/27/2009 Reasonable Attorney's Fee $5,097.19 Late Charges $272.36 Costs of Suit and Title Search $900.00 Escrow Payments Due 2 X $360.29 $720.58 $113,439.16 GOLDBECK M cCAFFERTY ?McKEEVER rA BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 44 day of /-'wf , 2009 damages are assessed as above. 0, 44- P. " o Prothy LlCB u 2 9rt i-?? 03 A I-r4 A9, 4 LOOS coca. ?%°.? Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX (Mortgagors and Record Owner(s)) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA VS. No. 09-1664 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: ?P. COIL ..3..11 aIK4 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 y 4 4 N 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff VS. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX Mortgagor(s) and Record Owner(s) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-1664 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 04/28/2009 to Date of Sale per diem at $18.85 (Costs to be added) $113,439.16 UA&LA _ V k 1w y--4 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff l . ?. U a o? p w>v?a ? A ? A n M 4 C M rLg e 0) C. -406. Sul V ?d n oo p yy r ? y r xe ? ? r a riy °CD O>? ? y a O z i a cr ? -G G? n o y p? ? o V r y° c 00 z? ? z y G? r c _ -n r ?« ri 4 ? r 7F Goldbe& McCafferty & McKeever BVM' ichael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX (Mortgagor(s) and Record Owner(s)) 850 Yverdon Drive Camp Hill, PA 17011 ACTION OF MORTGAGE FORECLOSURE Defendant(s) THE UNITED STATES OF AMERICA AFFIDAVIT PURSUANT TO RULE 3129 No. 09-1664 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 850 Yverdon Drive Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): ROBERT L. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 LOUISE M. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: ROBERT L. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 LOUISE M. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Suite 220, Federal Building 228 Walnut Street Harrisburg, PA 17108 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North Sioux Falls, SD DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 HSBC BANK USA 3476 Stateview Boulevard Fort Mill, SC 29715 4. Name and address of the last recorded holder of every mortgage of record: HSBC BANK USA, AS TRUSTEE IN TRUST FOR CITIGROUP MORTGAGE LOAN TRUST, INC. ASSET BACKED PASS-THROUGH CERTIFICATES SERIES 2003-HE3 150 Allegheny Center Mall Pittsburgh, PA 15212 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 850 Yverdon Drive Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 27, 2009 u GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff ALED-01-FIG`S OF THE RY 2999 MAY °4 Aid 1 f * 014 Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX Mortgagor(s) and Record Owner(s) 850 Yverdon Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 09-1664 THE UNITED STATES OF AMERICA CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Michael T. McKeever Attorney for plaintiff T7JALED- !v OF -TAR. 2009 ' - b. At,I I I : 0 4 09-1664 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX Mortgagor(s) and Record Owner(s) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA ACTION OF MORTGAGE FORECLOSURE Defendant( Term No. 09-1664 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: LAMOREAUX, ROBERT L. ROBERT L LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 Your house at 850 Yverdon Drive, Camp Hill, PA 17011 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 $113,439.16 obtained by GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: i N 09-1664 1. The sale will be cancelled if you pay to GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311. 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 STH.L 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 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. You may contact the Foreclosure Resource Center: ho://www.philadelRhiafed.orp-/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 ' 09-1664 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 bgp://www.phfa.or-a/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 Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825- 6411. Please reference our Attorney File Number of 78339FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. r 09-1664 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX Mortgagor(s) and Record Owner(s) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA Defendant(s, Term No. 09-1664 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: LAMOREAUX, LOUISE M. LOUISE M. LAMOREAUX 850 Yverdon Drive Camp Hill, PA 17011 Your house at 850 Yverdon Drive, Camp Hill, PA 17011 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 $113,439.16 obtained by GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 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: 09-1664 1. The sale will be cancelled if you pay to GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 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. 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 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. You may contact the Foreclosure Resource Center: hM://www.12hiladelphiafed.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 09-1664 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. 3). Visit HUD'S website www.hud.aov 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 homeretentionO-goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825- 6411. Please reference our Attorney File Number of 78339FC. 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. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 09-1664 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 GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. ROBERT L. LAMOREAUX LOUISE M. LAMOREAUX Mortgagor(s) and Record Owner(s) 850 Yverdon Drive Camp Hill, PA 17011 THE UNITED STATES OF AMERICA ACTION OF MORTGAGE FORECLOSURE Defendants; Term No. 09-1664 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: THE UNITED STATES OF AMERICA Suite 220, Federal Building 228 Walnut Street Harrisburg, PA 17108 Your house at 850 Yverdon Drive, Camp Hill, PA 17011 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 $113,439.16 obtained by GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 09-1664 1. The sale will be cancelled if you pay to GMAC MORTGAGE, LLC SBM GMAC MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 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 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: hM://www.12hiladelphiafed.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 09-1664 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 hqp://www.phfa.org/consumers/homeowners/real.4Vx. 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@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825- 6411. Please reference our Attorney File Number of 78339FC. 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 09-1664 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE LLC, SBM GMAC MORTGAGE CORPORATION, Plaintiff (s) From ROBERT L. LAMOREAUX and LOUISE M. LAMOREAUX and '1119 0t4WW "Tts OF AMERICA (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 $113,439.16 L.L. $.50 Interest from 4/28/09 to Date of Sale per diem at $18.85 Atty's Comm % Due Prothy $2.00 Atty Paid $176.50 Other Costs to be Determined Plaintiff Paid Date: 5/04/09 d-2 fanrle= Curtis R. Ogg,Prothon tary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON IDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129