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Home My WebLink About09-2364GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 W W W.GOLDBECKLA W.COM ATTORNEY FOR PLAINTIFF JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND Mortgagor and Record Owner 1220 Pine Road Carlisle, PA 17013 Defendant Term No. Dq-aN q 6vil - em CIVIL ACTION: MORTGAGE Fopr?71 ^qt !Rr NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE N£CESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website ho://www.phfa.orZ/consumers/homeowners/ realaspx. 5). Call the Plaintiff (your lender) at 866-926-8937 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at 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 80432FC. 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 Plaintiff is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY, 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendant is LORIE L. YOST a/k/a LORIE L. ROLAND, 1220 Pine Road, Carlisle, PA 17013, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On January 31, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to LONG BEACH MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1896 Page 57. The mortgage has been assigned to: JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY by assignment of Mortgage July 09, 2007 as Book 738, Page 1868. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for 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 balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$129,118.93 Interest from 09/01/2008 through 03/31/2009 at 8.8750% .......................$6,656.79 Per Diem interest rate at $31.40 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,455.95 Late Charges from 10/01/2008 to 03/31/2009 .............................................$380.57 Monthly late charge amount at $63.43 Costs of suit and Title Search ......................................................................$900.00 Fees ................................................................................................................$32.55 NSF Charges ..................................................................................................$25.00 Monthly Escrow amount $647.90 $143,569.79 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in person am" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $143,569.79, together with interest at the rate of $31.40, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: lhaTz GOLDB CK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Clady Rowland , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: JPMORGAN CHASE BANK, N.A., SUCCESSOR IN INTEREST FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION, AS RECEIVER FOR WASHINGTON MUTUAL BANK #80432FC - LORIE L. YOST a/k/a LORIE L. ROLAND 1220 Pine Road Carlisle, PA 17013 ExhibitA SCHEDULE A CONIMM ALL that certain house and lot of ground situate m Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center lime of Pine Road, also known a Legislative Rout 21008; thence along lands of Luther R Nevius and Teleta A. Nevius, his wife, South 11 degrees 06 minum 51 seconds East 331.96 feet to a point; thence along lands now or formerly of Vernon Dye, South 56 degrees 14 minutes 57 seconds Went 89.79 feet to a stalm; thence by other lands of the said Larry L. Warner and Joruette E. Warner, his wife, North 13 degrees 37 minules 02 seconds West 325.51 feet to a point in the center line of the aforesaid Pine Road; thence along said center line, North 55 degrees 49 minutes 56 seconds East 105.52 feet to a point, the Place of BEGINNING. CONTAINING 0.685 acres. SAID premises having thereon erected a ranch style dwelling house. SAID premises are described according to a Subdivision Plan of Larry V. Neid>mger, P.E., at Lot No. 3, recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 25, Page 148. The prendses are conveyed subject to an uitirnate right of way line existing 25 feet southwardly f wn the center line of said Pine Road as the some appears on said Plan. UNDER AND SUBJECT, NEVERTHELESS to the following restrictions: 1. That no mobile home or trailers shall be placed on the premises herein conveyed. BEING the same property with Oris H. Swvison and Imelda N. Stevison, his wife, granted and conveyed to Stephen N. Martin and Susan B. Martin, his wife, by deed dated August 26, IM and recorded on August 26, 1983 in the Office of the Recorder of Deeds for Cumberland County in Deed Book "r', Volume 30, Page 773. Schedak "A" C*0thW d - Cam nt No. 13417.1 I Certify this to be recorded In Cumberland County 0 DO 8K I 896PGo064 ?hi6it B Washington Mutual Mail Stop: JAXA2031 P.O. Box 44090 Jacksonville, FL 32231-4090 January 13, 2009 #BWNCLNN# #0906669779990594# LORIE L YOST 1220 PINE RD CARLISLE PA 17015 001002 /Pc 0666779905 M Washington Mutual HOME LOANS Your house is your home We want to keep it that way. We need to talk -- call 1-866 26-89 7 today You are going through tough times - we can help. In fact, we believe your home loan may be eligible for a loan modification program - we may be able to change the term of your loan, the interest rate, and maybe even the principal due date, to reduce the monthly payment to an amount you can afford. Call us today at 1-866-926-8937 so we can help you turn things around. We'll discuss your current situation (outlined in the enclosed letter) and the options available to you. But we cannot stress enough that the longer you delay calling us, the fewer chances you may have to keep your home. It will only take a few minutes on the phone - one of our Loan Specialists will work with you to determine the option that best fits your needs. There are several options available - call us now and let us see which one will work best for you. We are committed to working with you to find a way to help you keep your home, but you must call us immediately at 1-866-926-8937 - the longer you delay, the fewer options you may have. Homeowner's Assistance Department Washington Mutual 1-866-926-8937 P. S. The enclosed legal letter outlines in detail, your current situation and the consequences that will occur unless we receive the required financial information from you and can approve you for a modification. Once you call us with the information needed, then we can work together to determine the option that will work best for you. We cannot guarantee that you will be approved, but your only chance of saving your home is by contacting us immediately. Please don't delay - call us now at 1.866-926-8937. Washington Mutual PO Box 44118 Jacksonville, FL 32231-4118 January 13, 2009 LORIE L YOST 1220 PINE RD CARLISLE PA 17015 ® Washington Mutual HOME LOANS 001002 PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0666779905 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mor rage on yourhome is in default nd the lend r 'n en ac to foreclose, Sn. cific information about the nature of the default is provided in th atrac hed paw The HOMEOWNER'S EMERGENCY MORT =AE ASSISTANCE PROGRAM (HEMAPI_ may be able to help to save y ur home. This Notice explains how the prr M wor . . To see if HEMAP can heln_ you must MEET WITH A CONSUM- ER CREDIT O 1NSFi N AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take his Notice with you when you meet with the ou celing Agency. The name address and phone number of Co sump redit (nnn?l,±ng ?ge+...;oe a ., ng your County are 1 ted a the Purr of this Notice. If you have any auestlonc you MU call the Penn sylva is Housing Fin a= Agee toll free F 1-800-342-2397- (Persons with impaired hearing can call (717) 780-1869)- This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENM DE ESTA NOTI ICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBI PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. SPM HOMEOWNER'S NAME(S): Lorie L. Yost PROPERTY ADDRESS: 1220 Pine Rd Carlisle PA 17013 LOAN ACCT. NUMBER; 0666779905 ORIGINAL LENDER: Lbm CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY O FORECLIWIJRE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS lA N MIST OCCUR iN THIRTY-THREE (33) DAY OF = DA OF .4 NOTICE, IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE-YOU MUST BRIM YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE C IED "HOW TO CURE YOUR MORTGAGE DEFA LT". EXPLAIN HOW TO BRING YOUR MORT A E UP TO DATE. CONS MM EDIT CO MLULIN AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addr ecec and telephone numberc f d c;? Area r?nsumer credit rerun ling?eenc;es for the enunl; m which the property is located are se forth a the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender imm_edite1v of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To stop the lender from filing a foreclosure action your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEM" APPLICATION AS SOON AS PO IB .F_ IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AM FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RI UT TO EM E A H MAP APPLICATION EVEN BEYOND Effm 77]I/F P MDR A LAZE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY 77ME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED By THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION 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.) 001002/SP999 HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date). NATURE OF THE DEFAUI T - The MORTGAGE debt held by the above lender on your property located at: 1220 Pine Rd Carlisle PA 17013 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 10/01/2008 $1332.70 11/01/2008 $1332.70 12/01/2008 $1332.70 01/01/2009 $1332.70 Other charges (explainlitemize): Uncollected Late Charges $190.29 Uncollected Fees: $35.85 Corporate advances: $0.00 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $5556.94 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5556.94, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PPay=nts must be made either by cash. cashier's check certified check or money order made pgyable and cent to Washington Mutual Cash Processing PO Box 41275 Jacksonville, FL 32203 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURET F DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to omrcl Its rights to myclerate the mo rtagge de.,.. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortg"W Rrmdy •IF THE MORTGAGE is FORECLOSE UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THUtTY (30) DAY period you will not to n=hed to pffy attorney's fees - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. SP999 RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFFS SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anv time up to one hour before the Sheriff' le. You mgy do so ]a gang the total amount then year due l1,s a= late or othp charges then due reasonable attorney's fees and costs connected with the foreclosure cat and ally other coats connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortaaec Curinj your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: Email: Washington Mutual 7255 Baymeadows Way Jacksonville, FL 32256 1-866-926-8937 1-904-281-3914 Collection Department www.Wamuhomeloans.com EFFECTS OF SHERIFF'S SALE: - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SPM 0 FILED=t--j,,E OF THE P,;:?--f,?ntOTARY 2009 APR 14 PM 4 5 4'7$.50 pp *TTY cl.'# 3rngaB ei* a wlas Sheriffs Office of Cumberland County R Thomas Kline ?t?titr dt C11+nb"r,Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/04/2009 07:38 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 4, 2009 at 1938 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Lorie I. Yost a/k/a Lorie L. Roland, by making known unto Lorie I. Yost a/k/a Lorie L. Roland personally, at 25 E. North Street, Carlisle, Cumberland County, Pennsylvania, 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 May 05, 2009 Docket No. 2009-2364 JP Morgan Chase v Lorie I. Yost SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy"SheriffZ/ C C d %A -n _ 1 O ll? 'C . In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-2364 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO CO: OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against LORIE L. YOST a/k/a LORIE L. of an Answer. Assess damages as follows: Debt Interest from 6/10/2009 to Date of Sale per diem at $31.40 Total T A DEBT THE PURPOSE by default for want (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party aga' st whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior o the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 l Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW NUnP_ In x009 , Judgment is entered in favor of JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF 'WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/KJA WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGA E COMPANY and against LORIE L. YOST a/k/a LORIE L. ROLAND by default for want of an Answer and damages ass ssed in the sum of $147,901.78 as per the above certification. w, ^ 80432FC 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. TO: LORIE L. YOST a/k/a LORIE L. ROLAND YOST, LORIE L. a/k/a LORIE L. ROLAND 1220 Pine Road Carlisle, PA 17013 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) TO: LORIE L. YOST aWa LORIE L. ROLAND 1220 Pine Road Carlisle, PA 17013 DATE OF THIS NOTICE: May 27, 2009 II I In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Te No. 09-2374 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEAR OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS N( MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PRI IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y( LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN P: INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, T: ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SEF PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeel GOLDBECK McCAFFERTY BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-8: ONCE PERSONALLY FO THE CLAIMS SET TICE, A JUDGMENT )PERTY OR OTHER U DO NOT HAVE A :OVIDE YOU WITH IIS OFFICE MAY BE VICES TO ELIGIBLE McKEEVER 18 80432FC 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: May 27, 2009 TO: LORIE L. YOST a/k/a LORIE L. ROLAND YOST, LORIE L. a/k/a LORIE L. ROLAND 25 East North Street Carlisle, PA 17013 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN- INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) TO: LORIE L. YOST a/k/a LORIE L. ROLAND 25 East North Street Carlisle, PA 17013 In the C urt of Commo Pleas of Cumberlal d County CIVIL ACTION - LAW Action of Mortgage Foreclosure Te No.09-23 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEAR OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS' FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS N( MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PRl IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YC LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN P] INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, T] ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SEF 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 GOLDBECK MCCAFFERTY BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-8: CE PERSONALLY THE CLAIMS SET CE, A JUDGMENT ERTY OR OTHER DO NOT HAVE A VIDE YOU WITH i OFFICE MAY BE CES TO ELIGIBLE McKEEVER 18 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation wi hereby verify that I am authorized to make this verification on behalf of the Plair and that the facts set forth in the foregoing verification of Non-Military Servi correct to the best of my knowledge, information and belief. I understand that therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn authorities. n named do f corporation are true and e statements Isification to 1. That the above named Defendant, LORIE L. YOST a/k/a LORIE L.I ROLAND, is about unknown years of age, that Defendant's last known residence is 25 East North Street Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the Unite 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: 4 ?, ?9/'o I 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 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COM70N PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE F RECLOSUI No. 09-2364 CIVIL ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK, N.A., AS ACQUIR ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERA INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUA SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY, and against l a/k/a LORIE L. ROLAND for failure to file an Answer in the above action within (20) days ( defendant is the United States of America) from the date of service of the Complaint, in the si Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address creditor is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS ANI WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORP( ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-11 LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 a and last known address(es) of the Defendant(s) is/are LORIE L. YOST a/k/a LORIE L. ROLAi Street Carlisle, PA 17013; [C OF CERTAIN DEPOSIT BANK, AS )RIE L. YOST sixty (60) days if a of $147,901.78. if the judgment LIABILITIES OF [CATION TER.EST TO d that the name(s) D. 25 East North GOLDBECK McCAFFERTY & BY: Michael T. McKeever Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 09/01/2008 through 06/09/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 3 X $647.90 Fees NSF Charges $129,118.93 $8,854.79 $6,455.95 $570.86 $900.00 $1,943.70 $32.55 $25.00 $147,901.78 GOLDBECK McCAFFERTY & BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 104k day of %lUne , 2009 damages are assessed as above. RLFD-40+':F10 OF THE P"TI'? WY 2009 JUN 10 P141 3: 14 414. 00 Pp ATrV Gy385143 ?s# as c? ssy lJUk.?, µa?l..?! Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff No. 09-2364 CIVIL VS. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagors and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLL? OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Protho By !,i II A DEBT FOR THE If you have any questions concerning the above, please contact: I Michael T. McKeever Goldbeck McCafferty & McKeever (v?ll?lo? Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 ? r b • 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 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. LORIE L. YOST a/k/a LORIE L. ROLAND Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE F6RECLOSUI No. 09-2364 CIVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 6/10/2009 to Date of Sale per diem at $31.40 (Costs to be added) $147,901.78 GOLDBECK McCAFFERTY & BY: Michael T. McKeever Attorney for Plaintiff LLI --) J-) LL a e.+ U 4 ? Q o 0 (f) 8 0? g r _ z o°HW WxW`??? x rxxOR u¢W Q a u Q z p? Q ? Owy 4 a Q?OwF??ppd. WO -g M > U?,E-O U o0 u° z?x d z?U °?¢ HOzw ;ba z? W wO ? O 0 U U W UW?¢p .a c x zz? w3? w0 F ¢d??dw w'7 ... 4 p0 wCOO U z 0 D Wy W .° O? o W i a? Oa w? W U a 8 ,9- cn 'a z Oho M i L 9 ul 4v ?U a? U ? O cc N v O a ? O .C ,QQ? O L7 CA Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR- IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. LORIE L. YOST a/k/a LORIE L. ROLAND Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 09-2364 CIVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plai?tiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Michael T. McKeever Attorney for plaintiff RLED-f:);-FtCE OF THE Pa`?'?C) I-10 OTARY 2099 JUN 10 PM 3: 14 b ,- PENNSYLVANIA 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 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-2364 CIVIL JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATIO14 ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG E'EACH MORTGAGE COMPANY, 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: 1220 Pine Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): LORIE L. YOST a/k/a LORIE L. ROLAND 25 East North Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: LORIE L. YOST a/k/a LORIE L. ROLAND 25 East North Street Carlisle, PA 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the prop?rty 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street Harrisburg, PA 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 1220 Pine Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: June 9, 2009 GOLDBE K McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff FILED-OFFICE OF TFE PR711 ONOTAAY 2009 JUN 10 Pil 3: 14 ?,.1 ! fA r h F''EM,,4IS f i.`'rit A 09-2364 CIVIL GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. LORIE L. YOST a/k/a LORIE L. ROLAND Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 Defendant(s) Term No. 09-2364 CIVIL 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: YOST, LORIE L. a/k/a LORIE L. ROLAND LORIE L. YOST a/k/a LORIE L. ROLAND 1220 Pine Road Carlisle, PA 17013 Your house at 1220 Pine Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthi enforce the court judgment of $147,901.78 obtained by JPMORGAN CHASE BANK, N.A., A ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL B,? THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH M COMPANY 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 i CIVIL ACTION - LAVA ACTION OF MORTGAGE FORECLOSURE on to FROM To prevent this Sheriffs Sale you must take immediate action: 09-2364 CIVIL 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON' MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you mast pay call: 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 udgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for goo 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). 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. Yoju 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 07om 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 yolu act immediately after the sale. 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 HERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-2364 CIVIL 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 FROMI FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http:1/www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 866-926-8937 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 f Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklawacom. 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 Retenti n Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80432FC. 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 09-2364 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., as Aquirier of Certain Assets and Liabilities of WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER f/k/a WASHINGTON i MUTUAL BANK, as Successor-in-interest to LONG BEACH MORTGAGE COMPANYi, Plaintiff (s) From LORIE L. YOST a/k/a LORIE L. ROLAND (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjie oined from paying any debt to or for the account of the defendant (s) and from delivering any property of t 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 $147,901.78 L.L. $.50 Interest from 6/10/09 to Date of Sale per diem at $31.40 Atty's Comm % Due Prothy $2.00 Atty Paid $156.00 Plaintiff Paid Date: 6/10/09 (Seal) REQUESTING PARTY: Other Costs to be added Curtis R. Lon , oth no By: Deputy Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Goldbeck, McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS ,SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 Defendant(s) {I M TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 06/10/2009 to Date of Y CK Sale per diem at 37.00 - CBF $31.40 tog -86 - 178.60 14. oo M. 00 $ a4(o. 35 (Costs to be added) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-2364 CIVIL -v r - -4 r- r >:> c-j PRAECIPE FOR WRIT OF EXECUTION - Pc. Ao,, -*a.oo N-eCo e? s'?Sa?9 tom- ??rQo81 By: $147,901.78 GOLD B=McK: C FERTY & MCKEEVER McCall Pa. ID 42386 /Kristina ael v Pa. ID 56129 Lee Pa. ID 78020 Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff p4?! aWcnU "? eQ < W ?QAranZ? a o a v3addQz a du"?0?02 Ad d H 'A vo zd?z ? Mw Zd.,'?,HO?.,¢ oa' WAZ,wo?? °' z v x 50 H ¢QQZ,dU .U A O O w° W d ?o G vs ??pa? cQ 0 in H ?N ` ?r y O W ? a? v .? O P• N d i H U y y M a o ?o ?•?aN O ? O G?+ O Y ALL that certain home and lot of ground situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Pine Road, also known a Legislative Rout 21008; thence along lands of Luther R Nevius and Teleta A. Nevius, his wife, South 11 degrees 06 minutes 51 seconds East 331.96 feet to a point; thence along lands now or formerly of Vernon Dye, South 56 degrees 14 minutes 57 seconds West 89.79 feet to a stake; thence by other lands of the said Larry L. Warner and Jonietta E. Warner, his wife, North 13 degrees 37 minutes 02 seconds West 325.51 feet to a point in the center line of the aforesaid Pine Road; thence along said center line, North 55 degrees 49 minutes 56 seconds East 105.52 feet to a point, the Place of BEGINNING. CONTAINING 0.685 acres. SAID premises having thereon erected a ranch style dwelling house. SAID premises are described according to a Subdivision Plan of Larry V. Neidlinger, P. E., at Lot No. 3, recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 25, Page 148. The premises are conveyed subject to an ultimate right of way line existing 25 feet southwardly from the center line of said Pine Road as the same appears on said Plan. UNDER AND SUBJECT, NEVERTHELESS to the following restrictions: 1. That no mobile home or trailers shall be placed on the premises herein conveyed. BEING the same premises which Stephen N. Martin and Susan G. Martin, husband and wife, by Special Warranty Deed dated 1/31/2005 and recorded 2/1/2005 in Book 267 Page 1919 Instrument #2005-003765 granted and conveyed unto Lorie L. Yost, single person. Property Address: 1220 Pine Road, Carlisle, PA 17013 Parcel No: 08-12-0334-082 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 191016-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, A$ SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Wily Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/4 LORIE L. ROLAND (Mortgagor(s) and Record Owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-2364 CIVIL JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1220 Pine Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): LORIE L. YOST a/k/a LORIE L. ROLAND rn - 25 East North Street A C 3, Carlisle, PA 17013 2. Name and address of befendant(s) in the judgment: C 3 C :)C,) LORIE L. YOST a/k/a LORIE L. ROLAND - a 25 East North Street ` Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street Harrisburg, PA PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 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 stile: 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 1220 Pine Road Carlisle, PA 17013 (attach separated sheet if more space is needed) I verify that they 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: September 2A, 2010 Jjf?a ?bo GOLDBECK McCAFFERTY & McKEEVER BY: TINAMARIE BOSCHETTI 09-2364 CIVIL 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 JPMORGA CHASE BANK, N.A., AS ACQUIRI OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Bayme4dows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND Mortgagor(s) and Record Owner(s) 1220 Pine Road Carlisle, PA 17013 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 09-2364 CIVIL r rl Ca :;e- M cD Fes: ? . ti,a rta n CD r-? -v s w -c- r -n "v m ?rn C>n ?rn x;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: YOST, LORIE L. a/k/a LORIE L. ROLAND LORI L. YOST a/k/a LORIE L. ROLAND 25 East North Street Carlisle; PA 17013 Your h use 1220 Pine Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, Maz h 0at 2, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgme t of $147,901.78 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY against you. IN THE COURT OF COMMON PLEAS NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 09-2364 CIVIL To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SOCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY, the back payments, lat 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. 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). 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 halve a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.pHadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR C NNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT =RE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue 09-2364 CIVIL Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-2364 CIVIL Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosur against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website 5). Call the Plaintiff (your lender) at 866-926-8937 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 wi?l be mailed to the address that you request or faxed if you leave a message with that inf rmation. The attorney in charge of our firm's Homeowner Retention Department i David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please refere ?ce our Attorney File Number of 80432FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-2364 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisf? the debt, interest and costs due JPMORGAN CHASE BANK, N.A., as Aquirer of certain assets and liabilities of WASHINGTON MUTUAL BANK from THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECIEVER Vk/a WASHINGTON MUTUAL BANK, as SuccessoOn-interest to LONG BEACH MORTGAGE COMPANY, Plaintiff (s) From LORIE L. YOST a/k/a LORIE L. ROLAND (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 otherwisje disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone othep 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 $147,901.78 L.L. Interest from 4/10/09 to Date of Sale per diem at $31.40 Atty's Comm % Due Prothy $2.00 Atty Paid $24$.35 Other Costs Plaintiff Paid Date: 10/1/10 (Seal) REQUESTING PARTY: Name: KRISTINA MURTHA, ESQUIRE Dav' D. Buell, Prothonotary By: Deputy Address: GOLDBECK, McCAFFERTY & McKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLiAINTIFF Telephone: 215-?27-1322 Supreme Court Ib No. 61858 KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff q '20 t AN 10: i t' ` 0 +BEtil. ANO COUN 1-11 I'DINSYf VANlA JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County No. 09-2364 CIVIL PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. By: KML GROUP, C. Mich el McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff e? ?rqii? KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record owner(s)) 1220 Pine Road Carlisle, PA 17013 Defendant(s) i I C3C C`.. t, Is 1 L.Yl°?. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 09-2364 CIVIL PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER Jay- hael Mc ever Pa. ID 56129 E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff r KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, AS SUCCESSOR-IN-INTEREST TO LONG BEACH MORTGAGE COMPANY Plaintiff vs. LORIE L. YOST a/k/a LORIE L. ROLAND (Mortgagor(s) and Record Owner(s)) Defendant(s) CERTIFICATE OF SERVICE No. 09-2364 CIVIL Jessica Doebley, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on --!a] 2, ?z LORIE L. YOST a/k/a LORIE L. ROLAND LORIE L. YOST a/k/a LORIE L. ROLAND 1220 Pine Road 25 East North Street Carlisle, PA 17013 Carlisle, PA 17013 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: ? Jessica Doebley, Legal Assistant j doebley@kml lawgroup. com 215-825-6327 (Direct Phone) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE '"` '?*=