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HomeMy WebLinkAbout09-2560R u GOLDBECK McCAFFERTY & McKEEVER 'RV. MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866)413-2311 W W W.GOLDBECKLAW.COM SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagors and Record Owners 34 Liberty Drive Mount Holly Springs, PA 17065 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE UlViL AC i'IO 1 VJ D) V TGAGE ? ? ©g, aid 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 NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL 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 hLtp://www.nhfa.org/consumers/homeowners/real.Mx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: bq://www.t)hiladelphiafed.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 homeretentionCamoldbecklaw.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 80437FC. 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 SECRETARY OF VETERANS AFFAIRS, 7105 Corporate Drive, PTX C 35 Plano, TX 75024. 2. The names and addresses of the Defendants are PATRICIA L. MCALISTER, 34 Liberty Drive, Mount Holly Springs, PA 17065 and MARK W. MCALISTER, 34 Liberty Drive, Mount Holly Springs, PA 17065, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On August 07, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONICS REGISTRATION SYSTEMS, INC., AS NOMINEE FOR MORTGAGE INVESTORS CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 730 Page 2123. The mortgage has been assigned to: SECRETARY OF VETERANS AFFAIRS by assignment of Mortgage July 25, 2007 and recorded on September 06, 2007 as Instrument # 200734741. 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 May 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 ..................................................................................$147,621.01 Interest from 04/01/2008 through 03/24/2009 at 4.2500% .......................$6,150.43 Per Diem interest rate at $17.18 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$7,381.05 Late Charges from 05/01/2008 to 03/24/2009 ..........................................$1,301.19 Monthly late charge amount at $118.29 Costs of suit and Title Search ......................................................................$900.00 Escrow Balance ...........................................................................................$511.41 Fees ..............................................................................................................$150.00 Monthly Escrow amount $203.36 $164,015.09 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 Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have 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 Defendants 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 date of the postmark on the Notice was the same as the date of the Notice. The Defendants had the required face to face meeting within the required time and Plaintiff has been advised that the Defendants filed an application for mortgage assistance with the Pennsylvania Housing Finance Agency, the Plaintiff has been advised by the Pennsylvania Housing Finance Agency that the Defendants' application has been rejected. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $164,015.09, together with interest at the rate of $17.18, 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: /)/? /),/) cj GOLDBECK McCAFF/ERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Kathy Repka, Asst. Secrr / _, 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: AN 13 2009 INN11a. 11 At, ?r..d '(I it It W-VU Kath ep a, Asst. Secretary #80437FC - PATRICIA L. MCALISTER and MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 ExhibitA Exhibit "A" Legal Description All that certain parcel of land situate in the Borough of Holy Springs, County of Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the Southernmost dedicated right of way line of Liberty Drive, a 50 foot wide street, said pin marking the common point of adjoiner of Lots #30 and 031 on the hereafter mentioned plan of subdivision; thence extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an arc of curve to the left having a radius of 213.89 feet, a chord of 110.68 feet on a bearing North 62 degrees 27 minutes 41 seconds East for an arc distance of 111.93 feet to an Iron pin on said dedicated right of way line at Lot 057; thence departkV from the liberty Drive right of way and extending along Lot #57, South 46 degrees 11 minutes 23 seconds East for a distance of 468.51 feet t0 a steel pin; thence South 62 degrees 1 minute 50 seconds West, for a distance of 206.28 feet to a steel pin at Lot 030; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the Southernmost dedicated right of way line of Liberty Drive, said point marking the place of beginning. Containing 1.4180 acres, and being designated as Lot #31 on a final plan of subdivision of Liberty Woods prepared for Liberty Associates by Walter N. Heine Associates, Inc. dated December 8, 1989 and recorded in the OfNce of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 64, at Page 90A. Tax ID: 2345-2316-074 910529-1 BKi857PG3944 niMF/?nn9 9-11-nn AM CUMBERLAND COUNTY lnst.# 200409868 -Page 17 or 23 ?hifiit B ®c0l1,nr- HOME LOANS PO Box 9048 Temecula, CA 92589-9048 Send Payments To: PO Box 660694 Dallas, TX 75266-0694 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 2210025560 Patricia L McAlister 34 LIBERTY DR MOUNT HOLLY SPRINGS, PA 17065-1022 000702-7 BLUPA1 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1054-10 0 CGunhywide NOME LOANS P.O. Box 660694 Dallas, TX 75266-0694 Patricia L McAlister 34 LIBERTY DR MOUNT HOLLY SPRINGS, PA 17065-1022 Send Payments to: PO Box 660694 Dallas, TX 75266-0694 07/02/2008 Account No.: 75894612 Property Address: 34 Liberty Drive Mount Holly, PA 17065-1022 Current Servicon Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal Information. H you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney In your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SOMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRI=STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Patricia L McAlister PROPERTY ADDRESS: 34 Lt6orty Drtva LOAN ACCT. NO.: 75894612 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Countrywide Home Loans. Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE MOLE FOR FMLaNCIA< ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MA UT KE FURE MORTGAGE PAYMENTS • comieke ivIlr wider [oansb res • Write yyoauur account number on yy??11ff clwdk or money order • Wlits in 8 a rrplO11N emoums yodarle f ff= i?5000, plm sefnd calMkd check) • ?Deoyn't't eal?tsch your check to the • Don't indkdecorrespondence • Don't send cash Sr`• Please write your account number on all checks and correspondence. We may charge you a lee for any payment returned or rejected by your financial irnthufon, subject to applicable law. Account Number: 75894812.3 Patricia L McAlister Balance Due br charges listed above: $3,066.47 as of 7IL2008. 34 Liberty Drive Please update e-mail iraormadon on the reverse side of this capon. SLOPAI Additional Pnncpal Countrywide Additional Escrow PO BOX 660894 Dallas, TX 75266-0694 Ilr.rlrlrlr.rl.I,Ilr.rllr.llrrrrli.,lrlrrrirrllrlkr,l.kl..l.lllk..l Check Total 075894612300000306647000 306647 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 OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCC Ili-WITHIN THE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty-five (35) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county In which the property is located are set forth at the end of this Notice. It Is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your Intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is In default for the reasons set forth later in this Notice (see following pages for specific Information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty-five (35) days of your face-to-face meeting YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (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.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE YOU MUST TAKE ACTION TO SAYE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 34 Liberty Drive Mount Holly, PA 17065-1022 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: Late Charges: 05/01/2008 05/01/2008 Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: E-maN use: Providing your a-mail address below NMI allow us to send you information on your account Account Number: 7?0 2 Patricia L McAlister E-roes address $2,957.61 $78.86 $0.00 $30.00 ($0.00) $3,066.47 beacceliptedb lloapaymaweMS dPOprincipal M YO-al andIntent plaints e: NMI All app ed the longest outsterndirng instOmau der, unless otherwise v preset' prohbltW or Wnksd by low. 9 you submit an amount In addition to your scheduled monthly amount, we will apply you payments as fafi- (i) to outstanding monthly Payments Of pmcpal and Interest, (d) escrow deficiencies, (ii) late charges and other amounts you owe in connection with your loon and (W) to reduce the out tending piincpN balance of your bon. Please spsciry it you went an edditiornal Snout applied to future payments, rather then principal reduction. POetaosea OFnedrK Counnywide's Policy Is m not atxept pMdeted checks, unless specifically agreed to by a ben counselor or technician. 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-FIVE (35) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,066.47, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-FIVE (35) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. if not applicable) IF YOU DO NOT CUR THE DEFAULT - If you do not cure the default within THIRTY-FIVE (35) DAYS of the date of this Notice, the lender Intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past duels not made within THIRTY-FIVE (35) DAYS, the lender also intends to Instruct its attorneys to start legal action to foreclose upon your mortgaged properly IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default wthin the THIRTY-FIVE (351 DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY-FIVE (35) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will Increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans, Inc. Address: P. O. Box 660694 Dallas, 7X 75288-0894 Phone Number: 1-800-889-0102 Fax Number: 1-805-577-3432 Contact Person: MS PTX-36 Atfendon: Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the 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 sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. M 2210025560 TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR,) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an Inspection are to (1) observe the physical condition of your property, (ii) verify that the property Is occupied and/or (Iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before August 6, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: e Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 'A of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure akemative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what Is owed on it. • Deed-In-Lieu: Or, If your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are Interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by August 6, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Adams Canty Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Unglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. Maranatha PHFA 2320 North 5th Street 43 Philadelphia Avenue 211 North Front Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17110 717.232.2207 717.762.3285 717.780.3940 800.342.2397 E COu ptl'y11 ode- HOME LOANS PO Box 9048 Tememda, CA 92589-9048 Send Payments To: PO Box 660694 Dallas, TX 75266-0694 Send Coneapondonce to: PO Box 5170, MS SV314B Simi Valley, CA 93065 22111025559 Mark W McAlister 34 LIBERTY DR MOUNT HOLLY SPRINGS, PA 17065-1022 080702-7 BLOPAI PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1054-10 s S Coundywide HOME LOANS P.O. Box 660694 Dabs, TX 75266-0694 Mark W McAlister 34 LIBERTY DR MOUNT HOLLY SPRINGS, PA 17065-1022 Send Payments to: PO Box 660694 Dallas, TX 75266-0694 0 710 2/20 0 8 Account No.: 75894612 Property Address: 34 Liberty Drive Mount Holly, PA 1 70 65-1 022 Current Servicer. Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains Important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SOMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. 81 NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO E8TA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRISA. PUEDE 8ER ELEGiBLE PARA UN PR9STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Mark W McAlister PROPERTY ADDRESS: 34 Liberty Drive Mount Holly. PA 17065-1022 LOAN ACCT. NO.: 75894612 ORIGINAL LENDER: CURRENT LENDERISERVICER: Countrywide Home Loans, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY Be EDIBLE FOR FINANCIAL ASSISTANCE WHICH CA N SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MO RTGAGE PAYMENTS Please write pour account number on all checks and correspondenm we may charge you a tee for arty paymenl returned or rejected by your financial institution, subject to applicable law. Account Number: 758946123 y b • Malmtr ?ur ch a ane psLosns Mark W McAlister Balance Due for diarges listed above: $3,066.47 as of 7/2/2008. y . Write vciuraccount nurtberon 34 Liberty Drive your or money alder i Unit i l d Please update a-mad information on the nperse aide oft is coupon. • n 8 a e dit ona amounts y0U ire (/ low b -itional mote Ilan 5 , please aeryd Principal COMW check) SLOW • Dent ellach your dtleck to the xpeyymmaentt coupon AdditlonaI c °RA O"den? Do Escrow a„ D n'tsendce Countrywide PO BOX 6OW94 a Dallas, TX 75288-0694 II...I,I.1.r.I.I.il.r.11..11.r.rll.rl.lrrrlr.ll.l...1,.1.,1.111...1 Check Total 075894612300000306647000306647 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 OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face!' meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST occttR wrrulu TLYC ucvr CONSUMER CREDIT COUNSELING AGENC= - 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. addresses and telephone numbers of designated consumer credit counseling agencies for the unto in which the orooerty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (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.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUES- TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 34 Liberty Drive Mount Holly, PA 17065-1022 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 05/01/2008 Late Charges: 05/01/2008 Other Late Charges Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: E-mad use: ProAclk?p yyn? e-mail address below will allow us to send you iMommoon on your accoul Akxant Number: 7daiMt2 Merle W McAlister E-may address $2,957.61 $78.86 $0.00 $30.00 ($0.00) ;3,066.47 Mow ors pest yoalru Pdn~ft Al aocapted Payments d principand interestwill be applied b the longest outstanding Instdment due, unless otherMss enpressly prohibited or limited by law. If you submit an amount In addition to your scheduled monthly amoral, are will apply your payrnents as follows: (i) to outstanding monthly Payment of principal and interest. (d) escrow detic lendas, (dl) late charges and other amounts you owe W connection with your loan and (Iv) to reduce the aulstandng principal balance or your loan. Please specify P you want an additional amount applied to future payments, rather than principal reduction. t'onasNa Chad- Countrywide's policy is to not accept postdated checks, unless specifically agreed to by a loan counselor or technician. 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 $3,066.47, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure arrv other default by tak'na the follcwino action within THIRTY (30) DAYS of the date of this letter, (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also Intends to instruct Its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attomeys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attomey'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. H you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as N you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will Increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans, Inc. Address: P. O. Box 660694 Dallas, TX 75266--0694 Phone Number: 1-800-669-0102 Fax Number: 1-805477-3432 Contact Person: MS PTX-36 Affendon: Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live In the property after the 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 sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. R 2210025559 TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's Interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before August 1, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 'A of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home In order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance. Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of Its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter Into a written agreement by August 1, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions conceming this notice, please contact Loan Counseling Center immediately at 1-800-6 69-0 1 02. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Adams County Interfaith CCCS of Western PA Community Action Commissior Housing Authority 2000 Unglestown Road or Captial Region 40 E High Street Harrisburg, PA 17102 1514 Derry Street Gettysburg, PA 17325 888.511.2227 Harrisburg, PA 17104 717.334.1518 717.232.9757 Laweship, Inc- Maranathe PHFA 2320 North 5th Street 43 Philadelphia Avenue 211 North Front Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17110 717.232.2207 717.762.3285 717.780.3940 800.342.2397 (1) L D4T HE r ^?'t rtl? F 2009 APR 23 M H: 3 9 PENIN'SY 1.,/&, 4114 Sheriffs Office of Cumberland County R Thomas Kline 416011r of cumbr414# Edward L Schorpp Sheri. Solicitor Ronny R Anderson' Jody S Smith Chief Deputy OFPCE c` 7?X RIP: Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/2912009 12:39 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 29, 2009 at 1239 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Patricia L. McAlister, by making known unto Patricia L. McAlister personally, at 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania, 17065 its contents and at the same time handing to her personally the said true and correct copy of the same. 04/29/2009 12:39 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 29, 2009 at 1239 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mark W. McAlister, by making known unto Patricia L. McAliste, wife of defendant, at 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania, 17065 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $50.30 April 30, 2009 2009-2560 Secretary of Veterans Affairs v Patricia McAlister SO ANSWERS, I R THOMAS KLINE, SHERIFF J n V% Ain NJ kA I De uty SNhie!V111 Oy 4 N -a M i .,j o In the Court of Common Pleas of Cumberland County SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagor(s) and Record Owner(s)) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-2560 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 PATRICIA L. MCALISTER and MARK W. MCALISTER by default for want of an Answer. Assess damages as follows: Debt Interest from 06/05/2009 to Date of Sale per diem at $17.18 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM) I certify that written notice of the intention to file this praecipe was mailed or delivered is to be entered and to his attorney of record, if any, after the default occurred and at le, filing of this praecipe. A copy of the notice is attached. R.C,P. 237.1 1 Michael . McKeeve' Attornfor Plaintiff I.D. 6129 LINTS ALLEGED TO COMPLAINT. against whom judgment prior to the date of the AND NOW a409 -/ , Judgment is entered in favor of SECRETARY OF VETERANS AFFAIRS and against PATRICIA L. MCALISTER and MARK W. MCALISTER by default for want of an Answer and damages assessed in the sum of $166,217. 0 as per the abov rtification. "PorMtho-notary $166,217.00 ;, 80437FC 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 20, 2009 TO: PATRICIA L. MCALISTER MCALISTER, PATRICIA L. 34 Liberty Drive Mount Holly Springs, PA 17065 In the Court of SECRETARY OF VETERANS AFFAIRS Common Pleas 7105 Corporate Drive of Cumberland County PTX C 35 Plano, TX 75024 CIVIL ACTION - LAW Plaintiff vs. Action of PATRICIA L. MCALISTER Mortgage Foreclosure MARK W. MCALISTER (Mortgagor(s) and Record Owner(s)) Term 34 Liberty Drive No. 09-2560 Mount Holly Springs, PA 17065 Defendant(s) TO: PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC b Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 80437FC 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 20, 2009 TO: MARK W. MCALISTER MCALISTER, MARK W. 34 Liberty Drive Mount Holly Springs, PA 17065 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagor(s) and Record Owner(s)) 34 Liberty Drive Mount Holly Springs, PA 17065 TO: MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure Term No. 09-2560 Defendant(s) 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever_ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PATRICIA L. MCALISTER, is about unknown years of age, that Defendant's last known residence is 34 LibertyAve Mount Holly Springs, PA 17065, and is engaged in the unknown business located at 2. That Defendant is not in the Military or N Allies, or otherwise within the provisions of the So Congress of 1940 and its Amendments. address. Service of the United States or its ' and Sailors' Civil Relief Action of Date: 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, MARK W. MCALISTER, is about unknown years of age, that Defendant's last known residence is 34 Liberty Drive Mount Holly Springs, PA 17065, and is engaged in the unknown business located at 2. That Defendant is not in the Military or Naval Allies, or otherwise within the provisions of the So Congress of 1940 and its Amendments. S. of the United States or its Sailors' Civil Relief Action of Date: GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive IN THE COURT OF COMMON PLEAS PTXC35 Plano, TX 75024 of Cumberland County Plaintiff VS. CIVIL ACTION LAW PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagor(s) and Record owner(s)) ACTION OF MORTGAGE FORECLOSURE 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) No. 09-2560 ORDER FOR JUDGMENT Please enter Judgment in favor of SECRETARY OF VETERANS AFFA , a against PATRICIA L. MCALISTER and MARK W. MCALISTER for failure to file an Answer in the a ve ction within (20) days (or sixty (60) days if defendant is the United States of America) from the date of se is of the Complaint, in the sum of $166,217.00. Michael T. Mc ever f Attorney for aintiff I hereby certify that the above names are correct and that t e precise residence ess of the judgment creditor is SECRETARY OF VETERANS AFFAIRS 7105 Corp rate Drive PTX C lano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are PATRICIA L. LISTER, 34 Liberty Drive Mount Holly Springs, PA 17065 and MARK W. MCALISTER, 34 Liberty Driv ount Holly Springs, PA 17065; GOLDBEC cCAFFERTY & McKEEVER BY: Mich 1 T. McKeever Attorne for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 04/01/2008 through 06/04/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 3 X $203.36 Escrow Balance Fees $147,621.01 $7,387.39 $7,381.05 $1,656.06 $900.00 $610.08 $511.41 $150.00 $166,217.00 GOLDBECK MLe' FE Y & BY: Michael T. cKeever Attorney for P mtiff AND NOW, this 5tk day of ? UM 2009 damages are assessed as above. - /121"6 o Prothy Sheriffs Office of Cumberland County R Thomas Kline kj%1V ai ctrmbe", Edward L Schorpp Sheri 9* Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE $w,?LRIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/29/2009 12:39 PM - Amanda Cobaugh, Deputy Sheriff, who being duly swom according to law, states that on April 29, 2009 at 1239 hours, she served a true copy of the witttin Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Patricia L. McAlister, by makiAg known unto Patricia L. McAlister personally, at 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania, 17065 its contents and at the same time handing to her personally the said true and correct copy of the same. 04129/2009 12:39 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 29, 2009 at 1239 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mark W. McAlister, by making known unto Patricia L. McAliste, wife of defendant, at 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania, 17065 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $50.30 SO ANSWERS, April 30, 2009 R THOMAS KLINE, SHERIFF y S Delbu 2009-2560 Secretary of Veterans Affairs v Patricia McAlister RLED- MME OF THE PROTHG'WTARY 2N9 JUN -5 PM 1: 07 OACER r iw C CITY PENNMVANIA Ci:?" Wggs I aaV 3o8 ?? . ?"j Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagors and Record Owner(s)) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) No. 09-2560 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: If you have any questions concerning the above, please contact: Michael T. McKeever 1-15/07 Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTXC35 Plano, TX 75024 VS. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-2560 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 06/05/2009 to Date of Sale per diem at $17.18 (Costs to be added) $166,217.00 GOLDBE McCAFFERTY & McKEEVER BY: Mic el T. McKeever Attorne for Plaintiff .-- y O ?u PA Ln CA as O W c'o NU W > Qtr) ca U d uo? P E=°o ? a3^? a ? ? ao o d F Q ?M?, ? o bin OU ¢ o U L7 cr W W a '?, ? W F W a 4 9 r. --- i CO car /" 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 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagor(s) and Record Owner(s)) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-2560 SECRETARY OF VETERANS AFFAIRS, 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: 34 Liberty Drive Mount Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 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 GMAC MORTGAGE CORPORATION 500 Enterprise Road Suite 150 Horsham, PA 19044 GMAC MORTGAGE CORPORATION C/O Francis S. Hallman 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 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: THE SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA 1240 East Ninth Street Cleveland, OH 44199 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 34 Liberty Drive Mount Holly Springs, PA 17065 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the be of y personal knowledge or information and belief. I understand that false statements herein are made subject to e p alties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: June 4, 2009 GOLDBEC cCAF TY & McKEEVER BY: Mich T. McKeever, Esq. Attorne or Plaintiff N RLB rFIC E OF THE PROTHONOTARY 2089 JUN --5 PM 1: d 7 CL)W&ua'-J Diu WUN Y PeOISYI.VWA Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 09-2560 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of r I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has Act. i Michael T. M ee, Attorney for lainti he Plaintiff in this action, and with all the provisions of the FILED r CE t F THE PRMMQTARY 2919 Jill -5 PM 1: 0 7 Mt&.Lig-i b COUNTY PERN'SYLVA* , 09-2560 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 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s Term No. 09-2560 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: MCALISTER, PATRICIA L. PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS 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: 09-2560 1. The sale will be cancelled if you pay to SECRETARY OF VETERANS AFFAIRS, 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: htip://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-2560 09-2560 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.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(i?goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80437FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 09-2560 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 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 ACTION OF MORTGAGE FORECLOSURE Defendant(s; Term No. 09-2560 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: MCALISTER, MARK W. MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS 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: 09-2560 1. The sale will be cancelled if you pay to SECRETARY OF VETERANS AFFAIRS, 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; htip://www.philadelphiafed.org/foreclosure YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-2560 09-2560 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 8043717C. Para information en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2560 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SECRETARY OF VETERANS AFFAIRS, Plaintiff (s) From PATRICIA L. MCALISTER and MARK W. MCALISTER (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 $166,217.00 L.L. $.50 Interest from 6/05/09 to Date of Sale per diem at $17.18 Atty's Comm % Due Prothy $2.00 Atty Paid $169.30 Other Costs to be added Plaintiff Paid Date: 6/05/09 Curtis 4-Pro otary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 ,~. ,, . GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215)627-1322 ATTORNEY FOR PLAINTIFF ~, ~ ~~~ VARY 10IQ P3~1R 19 p~ 3~ C~3 '- tR :, ' ~.. E SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-2560 PRAECIPE TO CORRECT SCRIVENER'S ERROR Kindly correct the action to reflect the correct scrivener information. The incorrect Mortgage Book 730 Page 2123 was referenced in paragraph #3 of the complaint. Please correct to Dated 03/12/2004 Book 1857, Page 3928. Respectfully submitted, GOLDBECK, McCAFFERTY & McKEEVER By: (~`~ Michael T. M Keever, Esquire Attorney for Plaintiff l • SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson '-- Sheriff _ ~'f Jody S Smith „r , ~ ~ ~ - „ Chief Deputy _ cu ~ i:; [~ ~ _f ;:.. , • z Edward L Schorpp ~ R __~ . Solicitor _ - l,,.i•,°: {_ Secretary of Veterans Affairs vs. Case Number Patricia L McAlister (et al.) 2009-2560 SHERIFF'S RETURN OF SERVICE 09/30/2009 06:45 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on 09-30-09 at 1835 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mark W. McAlister & Patricia L. McAlister, located at 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 10/01/2009 01:15 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-01-09 at 1300 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Mark W. McAlister, by making known unto, Patricia L. McAlister, adult in charge, at 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 10/01/2009 01:15 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-01-09 at 1300 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Patricia L. McAlister, by making known unto, Patricia L. McAlister, personally, at 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 10/23/2009 Property sale postponed to 3/3/2010. 03/02/2010 Property sale postponed to 4/7/2010. 04/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Michael McKeever on 4/6/10 SHERIFF COST: $786.32 April 07, 2010 SO ANSWERS, t~ . RON R ANDERSON, SHERIFF ~2.so~~~ end yszaq ~avos'c~ Goldbeck McCatfe`rty & M.eKeever I3Y: iVlichael "f. McKeever Attorney I.D. #56129 Suite X000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C' 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagor(s) and Record Owner(s)) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 09-2560 AFFIDAVIT PURSUANT TO RULE 3129 SECRETARY OF VETERANS AFFAIRS, 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. 34 Liberty Drive Mount Holly Springs, PA 17065 I .Name and address of Owner(s) or Reputed Owner(s): PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: GMAC MORTGAGE CORPORATION X00 Enterprise Road 09-2560 GOLIJBECK NIcCAFFERTY & McKEEVER BY: Michael T. McKee~~er Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-2560 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEiVIP'TING 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: MCALISTER, MARK W. MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FI_ Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 09-2560 1. The sale ~~~ill be cancelled if you pay to SECRETARY OF V"E"I-ERANS AFFAIRS, the back payments, late charges, costs and reasonable attorney's fees due. "I~o 17nd out how mach you must pay call our office at 215-825-6329 or 1-866-413-231 I. 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 amowit due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, die 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 (I O) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http~//www philadelphiafed orp/foreclosure/ YOU SHOULD TAKE THIS PAPER T'O 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. CUMBEKLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-?560 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 inay 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 7l 7-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_ov_ for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(cr~goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80437FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 09-2500 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Atton~ey I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendants of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-2560 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: MCALISTER, NATRICIA L. PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 09-2500 I . The sale will be cancelled if you pay to SECRETARY OF VETERANS AFF:IIRS. the back payments, late charges, costs and reasonable attorney's fees due. To find out ho~~~ much you must pay call our office at 215-825-6329 or 1-866-413-231 1. 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 belo~~ 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 ~~ithin 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. K. You may contact the Foreclosure Resource Center: http:Uwww.phi(adebhiafed org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR. LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 0)-2560 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 maybe 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 httn://www.phfa.or~/consumers/homeowners/real aux. 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 hailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firnl's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80437FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain parcel of land situate in the Borough of Holly Springs, County of Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the Southernmost dedicated right of way line of Liberty Drive, a 50 foot wide street said pin marking the common point of adjoiner of Lots #30 and #31 on the hereinafter mentioned plan of subdivision; thence extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an arc of curve to the left having a radius of 213.89 feel. a chord of 1 10.66 feet on a bearing North 62 degrees 27 minutes 41 seconds East for an arc distance of 111.93 feet to an iron pin on said dedicated right of way line at Lot #57; thence departing from the liberty Drive right of way and extending along Lot #57, South 46 degrees 11 minutes 23 seconds East for a distance of 468.51 feet to a steel pin; thence South 62 degrees 1 minute 50 seconds West, for a distance of 206.28 feet to a steel pin at Lot #30; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the Southernmost dedicated right of way line of Liberty Drive, said point marking the place of beginning. Containing 1.4180 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods prepared for Liberty Associates by Walter N. Heine Associates, Inc. dated December 8, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 64, at Page 90A. Tax ID: 23-35-2316-074 BEING KNOWN AS 34 LIBERTY DRIVE, MOUNT HOLLY SPRINGS PA 17065 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-2560 Civil • COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SECRETARY OF VETERANS AFFAIRS, Plaintiff (s) From PATRICIA L. MCALISTER and MARK W. MCALISTER (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 $166,217.00 L.L. $.50 Interest from 6/05/09 to Date of Sale per diem at $17.18 Atty's Comm % Due Prothy $2.00 Atty Paid $169.30 Other Costs to be added Plaintiff Paid Date: 6/05/09 Curtis R. L of not y (Seal) By; Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: (GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale # On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Mount Holly Springs, Cumberland County, PA Known and numbered as, 34 Liberty Drive, Mount Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 By: C„ - ~ ^ , ._.._ Real Estate Coordinator~~~~ ~~ R~ ,f~~~' ~,.~~~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 23, October 30 and November 6, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coma! Editor SWCSRN TO AND SU)~CRIBED before me this 6 day of November. 2009 Notary NOTARIAL SEAL DEBORAIi A COLLINS Notary Public CARLISLE 80R0, CUM1lBERLAND COUNTY rwy Commission Expires Apr 28, 2010 writ No. 2009-2560 Civil Secretary of Veterans Affairs vs. Patricia L. McCalister Mazk W. McAlister Atty: Michael T. McKeever All that certain pazcel of land situ- ate in the Borough of Holly Springs, County of Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the Southernmost dedicated right of way line of Liberty Drive, a 50 foot wide street said pin mazking the common point of adjoiner of Lots #30 and #31 on the hereinafter mentioned plan of subdivision; thence extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an arc of curve to the left having a radius of 213.89 feel, a chord of 110.66 feet on a bearing North 62 degrees 27 minutes 41 seconds East for an arc distance of 111.93 feet to an iron pin on said dedicated right of way line at Lot #57; thence departing from the liberty Drive right of way and extending along Lot #57, South 46 degrees 11 minutes 23 seconds East for a distance of 468.51 feet to a steel pin; thence South 62 degrees 1 minute SO seconds West, fora dis- tance of 206.28 feet to a steel pin at Lot #30; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the South- ernmost dedicated right of way line of Liberty Drive, said point marking the place of beginning. Containing 1 .4180 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods prepared for Liberty Associ- ates by Walter N. Heine Associates, Inc. dated December 8, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania. in Plan Book 64, at Page 90A. Tax ID:23-35-2316-074 BEING KNOWN AS 34 LIBERTY DRIVE, MOUNT HOLLY SPRfNGS PA 17065. Tie Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c~he ~latriot News NOw you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Leslie Kramer, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/23/09 10/30/09 11 /06/09 Sworn to and/subscribed before 1 ~ c° ~ ~_F Notary Public 16 y gf!November, 2009 A.D. ~.. ~ _-_, __ COMMONWE~~TH _O>= PENNSYLVANIA Not~~ai $aai Sherrie L. i<isner, Notary Public City Of Harn$buti-~, 9]auphin County My Cammissior, iExpire:~ Nov. 26, 2011 Member. Pennsylv~;nia Association of Notaries Writ No. 20'09-~ CN117erm SoCa'etary of Wlsntns AtMirs Ys Mlt~bla L MaCafletsr Mark W IkcAllster Atty: Mlchesi T. McKeever All that certain panxl of land, situate in the Borough of }lolly .Springs, County of Cumberland; and State of Pennsylvania, being known and designated. as follows:.. Begp~ng at an iron pin set on the Southernmost dedicated fight: of way line of. Liberty Drive, a 50 foot wide strcet said pin marking the common point of adjoiner of Lots #30 end #31 on the hereinafter mec~tioned plan of subdivision; thoace extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an arc of curve tq the lefr having a radius pf 213.89 feet, a chord of 110.66 feet on a bearing North b2 degteea 27 minutes 41 seconds East fox as arc ~statrce of 111.93 feet to an iron pia on said dadusted right of way line at cot #57; three dapa<tingfronaihe h~erty Drive right of way and extendiing along Lot #57, South 46 degrees t 1 minutes 23 seconds Easi for a distance of 468.51 feet-to a,satel pin; thence Sonth 61 degrees l minute S0 seconds West; .for a distance of 2U6.28 fern to a steel'pin at Lot~lk~; t"~ctetuiiog along Lnt #30, Noah 29 degrees 48 mie~'39 seconds~West for a disianee of 432.21'.feet to a'steeppia set on the SaitAetnntost tkdicated tight of vtayliae of Liberty'Drive, said point marking the place of beginning. Containing 1 .4184 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods pnpaned-for Liberty Associates by .WaFter N. Iieine `Associates, .Inc. dated December 8,.1989 and recorded in the Office of the Rocxnaa of Deeds in and for Cumberland County, Pennsylvatda, in Plan Book 64, ai Page 90A. Tax ID: 23-8.5-4316-074 , BIRNCi Hf~iO~R'Id AS 34 LIB0CT1f DRIVE, FiRXINT HOLLY SFRQVEiis PA 17t16S 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 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 09-2560 PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: O ~`f. 00 AA A1"~y/ 7 ~. ,~~ cotes ,B F ,, s IY-D~ ~ ,~,y. ~ ~< <, a y~~,, 1 ~ ~~~ a~ r ~'1-.00 awe ~o, Amount Due Interest from 6/5/2009 to Date of Sale per diem at $17.18 (Costs to be added) C ° ~ ~~ _ ~ ~ ~ :.A , ~ r Sit c - ~ , ~ ~' C _t ,~ J t'y'rt $166,217.00 By: GOLDBE K MCCAFFE TY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ~Havid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff C~.'~ 5a 44~ ~,~ a~~ z o a a ~ ~ ~ ~ a ; O ~ o v ~u N ~ woo ~ ~ ~ ; ~ ~x1 o ~ Q ~ j o .~ 0.' Gz, ~ a~i ~ o~j ~ ~ ° rl N~ W d~ vQ ~ ~ c x a .~.n"'a`~ a o w ~ a 3 ~ ' " ~ a~ '' + N w ~ U ° E.,, zx ~ .. a ~ ¢x~~a ~ x ~, ~ ~ c v, ~ ~ :~,~ ~ ~ ~¢~"'x oo ~ o ~~o~N 0 U ¢ ~'~ t`~i a W~ ¢ ~ ~ ° W W o Q o ~ ~ o i b° a F U a ~ W o ~, ~ ~ ~ ci All that certain parcel of land situate in the Borough of Holly Springs, County of Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the Southernmost dedicated right of way line of Liberty Drive, a 50 foot wide street said pin marking the common point of adjoiner of Lots #30 and #31 on the hereinafter mentioned plan of subdivision; thence extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an arc of curve to the left having a radius of 213.89 feel. a chord of 110.66 feet on a bearing North 62 degrees 27 minutes 41 seconds East for an arc distance of 111.93 feet to an iron pin on said dedicated right of way line at Lot #57; thence departing from the liberty Drive right of way and extending along Lot #57, South 46 degrees 11 minutes 23 seconds East for a distance of 468.51 feet to a steel pin; thence South 62 degrees 1 minute 50 seconds West, for a distance of 206.28 feet to a steel pin at Lot #30; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the Southernmost dedicated right of way line of Liberty Drive, said point marking the place of beginning. Containing 1.4180 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods prepared for Liberty Associates by Walter N. Heine Associates, Inc. dated December 8, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 64, at Page 90A. BEING KNOWN AS 34 LIBERTY DRIVE, MOUNT HOLLY SPRINGS PA 17065 IMPROVEMENTS consist of a residential dwelling. BOROUGH OF HOLLY SPRINGS BEING PREMISES: 34 Liberty Drive Mount Holly Springs, PA 17065 SOLD as the property of PATRICIA L. MCALISTER and MARK W. MCALISTER TAX PARCEL #23-35-2316-074 BEING the same premises which Liberty Associates, by Deed dated 8/22/1998 and recorded 9/2/1998 in Book 184 Page 901 Instrument #1998-030233 granted and conveyed unto Mark W. McAlister and Patricia L. McAlister. GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215)627-1322 ATTORNEY FOR PLAINTIFF F1L'i ICS 2014 MAY i3 PM I~ ~~ CUM~~•~~-,~~u `~fJUMY r~PdMSYI.`dfi~~fi/~ SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) Term No. 09-2560 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: GOLDBEC McCAFFER Y & McKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff r}~ ~~~ ~ ~ ~ ~'^`~~`JTARY ZOi~MAY t3 PM I= t~ PEi Ji'~S`(LV~~+k SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagor(s) and Record Owner(s)) 34 Liberty Drive Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 09-2560 AFFIDAVIT PURSUANT TO RULE 3129 SECRETARY OF VETERANS AFFAIRS, 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: 34 Liberty Drive Mount Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 r 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: GMAC MORTGAGE CORPORATION 500 Enterprise Road Suite 150 Horsham, PA 19044 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 GMAC MORTGAGE CORPORATION C/O Francis S. Hallinan, Esquire 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: 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 34 Liberty Drive Mount Holly Springs, PA 17065 (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: May 11, 2010 ~ GOLDBECK McCAFFE TY cKEEVER BY: Barb Hand 09-2560 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Mazket Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff ~~~. 29(1fMAY I3 PM I= tQ F'ENP~;~YLV~!`~tr SECRETARY OF VETERANS AFFAIlZS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-2560 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE LS 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: MCALLSTER, PATRICIA L. PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 09-2560 1. The sale will be cancelled if you pay to SECRETARY OF VETERANS AFFAIRS, 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: http•//www philadelphiafed.orglforeclosure/ 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 09-2560 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 maybe 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.~ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http•//www phfa org/consumers homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@~oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80437FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 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 ,ice ~A1.~D-~t'~ T~? 2010~Ay !3 P~1 f: ip CUfirtc,~ ` ~ .., FC"y~V~~l~pi~~'%~ ' VY 1r ~- 09-2560 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendants; CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-2560 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: MCALISTER, MARK W. MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Heazing Rm 2nd FL Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS 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 To prevent this Sheriffs Sale you must take immediate action: .` 09-2560 1. The sale will be cancelled if you pay to SECRETARY OF VETERANS AFFAIRS, 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: htt~//www.philadel~hiafed.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 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. 09-2560 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.g_ov_ 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 httn://www.phfa.org/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @ ~oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80437FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-2560 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SECRETARY OF VETERANS AFFAIRS Plaintiff (s) From Patricia L. McAlister and Mark W. McAlister (I) 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$166,217.00 L.L. Interest FROM 6/5/2009 TO DATE OF SALE PER DIEM AT $17.18 Atty's Comm Atty Paid $977.11 Plaintiff Paid Date: MAY 13, 2010 (Seal) Due Prothy $2.00 Other CostsTO BE ADDED Da .Buell, Prothonotary By: Deputy REQUESTING PARTY: Name David Fein, Esquire Address: Goldbeck McCafferty & McKeever, Suite 5000- Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 82628 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.456129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia. PA 19106-1532 215-627-1322 intiff FILEEXr, ,. -, ?,^?s,APC1 OF ?Nv- k;2I ?? 3: 4b 80437FC CF: 04/23/2009 SD: 09/08/2010 $166,217.00 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano_ TX 75024 Plaintiff vs. PATRICIA L. MCA.LISTER MARK W. MCALISTER Mortgagor(s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 09-2560 Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/ eWm-ad- (copy of return attached). ( ) Certified- mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T_ McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Keith C. Hall]] Legal Secretary IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE, FORECLOSURE - ------- ?"tag ? ° :5 ° C) o U Z S _ - 5.2 dco 0 0 o.c (n ? Z 0 o ° G Q a ° E ? Z > - o -? ) a I Q J C U o C7 (. l CL n m a m ? I Z 1 Lu O 5? O G + ! LPL Q Q V) r, Q ! r a V c , O LL O 5 I ° O Z t E 0 W -0 z Q Vm C= Q Ir rn w n T m ! F CE w p i O n cc a a- G () O (NJ F-- i C7 O 9 U coJI W Y ?? Q m 20.5 `0 000 j C3 Ln Ln = I Q O D- ' f I 'm i E c c W z ? to W< ° _ <j U r N Q 7 (' ?`.LCD Wtl.c\J w ? a; 10 < 0 , E C) < (01 ?O??zrn? ,r ci C? cn r` ? ,- W Q Q ? O 3: E U o l , 2 X00 Lr Oa- O0 v m C W to 11 L) C[ W T v LL p o o O OL w e (5 co G 7 LL 0 ? C) N rn O 6 ca <o? mecca B a g [ 0 •-- a- m2 dS 06 a C7 v ILo i j N N 7 m 0 C 41 i N .r U I Q i I ? U - - - l ---- - I---- - (7 4) II N 4) m I C i { a L m Y? Y C I I ' S. ` m M I + a ? F ° T 9? d O U p ti- O f m ¢i w f-- i6 ? m' w D J c Q U I r I cu Cl) 1 Y y? C ? 6-C Q C37 C) c CC <> o w f a? o F- ? J a D U U Li ?. co c: 4i U U e r_ E _C 0 ° z? co n Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Secretary of Veterans Affairs vs. Patricia L McAlister (et al_) 4 4? V 4t 4?c???Iep?,r }fib ?(\ tv, Case Number 2009-2560 SHERIFF'S RETURN OF SERVICE 06/24/2010 Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 6-24-2010 at 1140 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Patricia L. McAlister & Mark W. McAlister, located at, 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 06/2512010 11:50 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 6-25-2010 at 1230 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Mark W. McAlister, by making known unto, Patricia L. McAlister, wife of defendant, at, 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/25/2010 12:37 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 6-25-2010 at 1230 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Patricia L. McAlister, by making known unto, Patricia L. McAlister, personally, at, 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $908.42 July 02, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF c; C=,'ySuite Sheriff, TeeosaR, Inc. GOLDBECK WCAFFERTY & McKEEVER BY. Michael T. McKeever Attorney 1.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff SECRETARY OF VETERAI 7105 Corporate Drive PTX C 35 Plano_ TX 75024 M THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor(s) and Record 34 Liberty Drive Mount Holly Springs, PA I7( Defendant(s) ACTION OF MORTGAGE FORECLOSURE Tenn No. 09-2560 AFFIDAVIT PURSUANT TO RULE 3129 SECRETARY OF VETERANS AFFAIRS, 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 al: 34 Liberty Drive Mount Holly Springs, PA 17065 I.Name and address of Owner(s) or Reputed Owner(s): PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 I:iberty Drive Mount Holly Springs. PA 17065 2. Name and address of Defendant(s) in the judgment: PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: GMAC MORTGAGE CORPORATION 500 Enterprise Road Suite 150 Horsham, PA 19044 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARF, - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 GMAC MORTGAGE CORPORATION C/O Francis S. Hallinan, Esquire 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: 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 mav° be affected by the sale. TENANTS/OCCUPANTS 34 Liberty Drive Mount Holly Springs, PA 17065 (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 relatma to unsworn falsification to authorities. DATED: August 25, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHEf~IF~~'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~tis>,iv ~t 4iurt~F~,i~~~ { ~ ri. 4 {T`~. .j_ CSF'F ~;~ ^ F'r,G S~ERt~F ~+k~ t iiL f 1Ytt 1 ~E„1~~{!~ k~~aY*i 2Jf0 Q~T 14 ~ii~ f~~ f `~ GJ:"3~ERLAi~J CJl~r~TY PEi~~~SYE~jANlA Jody S Smith Chief Deputy Richard W Stewart Solicitor Secretary of Veterans Affairs vs. Patricia L McAlister (et al.) Case Number 2009-2560 SHERIFF'S RETURN OF SERVICE 06/24/2010 Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 6-24-2010 at 1140 hours, h2 posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Patricia L. McAlister & Mark W. McAlister, located at, 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 06/25/2010 11:50 AM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 6-25-2010 at 1230 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Mark W. McAlister, by making known unto, Patricia L. McAlister, wife of defendant, at, 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/25/2010 12:37 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 6-25-2010 at 1230 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Patricia L. McAlister, by making known unto, Patricia L. McAlister, personally, at, 34 Liberty Drive, Mount Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1 the same. 09/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever on behalf of Secretary of Veterans Affairs, 2375 N. Glenville Drive, Building B, Mail Code TX2-983-01-01, Richardson, TX 75082, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1,011.07 SHERIFF COST: $1,011.07 SO ANSWERS, October 11, 2010 RON R ANDERSON, SHERIFF ~~~'1~~~~/f ~'yr (oj GountySuite She:nff, Teleasnft, Inc. ~ o[ `7 ~O ~ / Goldbeck McC~fferty & McKeever BY: Michael T. McKeever . Attorney LD. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW PATRICIA L. MCALISTER MARK W. MCALISTER (Mortgagor(s) and Record Owner(s)) 34 Liberty Drive Mount Holly Springs, PA 17065 ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-2560 SECRETARY OF VETERANS AFFAIRS, 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: 34 Liberty Drive Mount Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 • D , 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: ' GMAC MORTGAGE CORPORATION 500 Enterprise Road Suite 150 Horsham, PA 19044 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfaze Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 GMAC MORTGAGE CORPORATION GO Francis S. Hallman, Esquire 1617 JFK Boulevazd Suite 1400 Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: 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 34 Liberty Drive Mount Holly Springs, PA 17065 (attach sepazate 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: May 11, 2010 GOLDBECK McCAFFE TY cKEEVER BY: Barb Hand .~ 09-2560 GOLDBEC~ 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 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW vs. ACTION OF MORTGAGE FORECLOSURE PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagors} and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 Term No. 09-2560 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: MCALLSTER, PATRICIA L. PATRICIA L. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: j o9-2s6o 1. The sale will be cancelled if you pay to SECRETARY OF VETERANS AFFAIRS, 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 tbe 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 TARE 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 tight 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 Iegal 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 wiIl 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.pln'ladelvhiafed.orgJforeclosure/ 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 r 09-2560 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 maybe 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 htty-//www~hfa orb,/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@ ~oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80437FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain parcel of land situate in the Borough of Holly Springs, County of Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the Southernmost dedicated right of way line of Liberty Drive, a 50 foot wide street said pin marking the common point of adjoiner of Lots #30 and #31 on the hereinafter mentioned plan of subdivision; thence extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an azc of curve to the left having a radius of 213.89 feel. a chord of 110.66 feet on a bearing North 62 degrees 27 minutes 41 seconds East for an azc distance of 111.93 feet to an iron pin on said dedicated right of way line at Lot #57; thence departing from the liberty Drive right of way and extending along Lot #57, South 46 degrees 11 minutes 23 seconds East for a distance of 468.51 feet to a steel pin; thence South 62 degrees 1 minute 50 seconds West, for a distance of 206.28 feet to a steel pin at Lot #30; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the Southernmost dedicated right of way line of Liberty Drive, said point mazking the place of beginning. Containing 1.4180 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods prepared for Liberty Associates by Walter N. Heine Associates, Inc. dated December 8, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 64, at Page 90A. - BEING KNOWN AS 34 LIBERTY DRIVE, MOUNT HOLLY SPRINGS PA 17065 IlVIPROVEMENTS consist of a residential dwelling. BOROUGH OF HOLLY SPRINGS BEING PREMISES: 34 Liberty Drive Mount Holly Springs, PA 17065 SOLD as the property of PATRICIA L. MCALISTER and MARK W. MCALISTER TAX PARCEL #23-35-2316-074 BEING the same premises which Liberty Associates, by Deed dated 8/22/1998 and recorded 9/2/1998 in Book 184 Page 901 Instrtunent #1998-030233 granted and conveyed unto Mark W. McAlister and Patricia L. McAlister. 0.9-2560 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 SECRETARY OF VETERANS AFFAIRS 7105 Corporate Drive PTX C 35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION -LAW vs. PATRICIA L. MCALISTER MARK W. MCALISTER Mortgagor{s) and Record Owner(s) 34 Liberty Drive Mount Holly Springs, PA 17065 ACTION OF MORTGAGE FORECLOSURE Term No. 09-2560 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: McaLrs~x, Maxi w. MARK W. MCALISTER 34 Liberty Drive Mount Holly Springs, PA 17065 Your house at 34 Liberty Drive, Mount Holly. Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $166,217.00 obtained by SECRETARY OF VETERANS AFFAIRS 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: ~, 09-2560 1. The sale will be cancelled if you pay to SECRETARY OF VETERANS AFFAIRS, 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 tbe 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: http://www.philadelphiafed.or~Jforeclosure/ 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 ti 09-2560 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 maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.ors/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@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80437FC. Para information en espanol puede communicarse con Loretta a1215-825-6344. L All that certain parcel of land situate in the Borough of Holly Springs, County of Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the Southernmost dedicated right of way line of Liberty Drive, a SO foot wide street said pin marking the common point of adjoiner of Lots #30 and #31 on the hereinafter mentioned plan of subdivision; thence extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an arc of curve to the left having a radius of 213.89 feel. a chord of 110,6b feet on a bearing North 62 degrees 27 minutes 41 seconds East for an arc distance of 111.93 feet to an iron pin on said dedicated right of way line at Lot #57; thence departing from the liberty Drive right of way and extending along Lot #57, South 46 degrees 11 minutes 23 seconds East for a distance of 468.51 feet to a steel pin; thence South 62 degrees 1 minute 50 seconds West, for a distance of 206.28 feet to a steel pin at Lot #30; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the Southernmost dedicated right of way line of Liberty Drive, said point marking the place of beginning. Containing 1.4180 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods prepared for Liberty Associates by Walter N. Heine Associates, Inc. dated December 8, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 64, at Page 90A. BEING KNOWN AS 34 LIBERTY DRIVE, MOUNT HOLLY SPRINGS PA 17065 IMPROVEMENTS consist of a residential dwelling. BOROUGH OF HOLLY SPRINGS BEING PREMISES: 34 Liberty Drive Mount Holly Springs, PA 17065 SOLD as the property of PATRICIA L. MCALISTER and MARK W. MCALISTER TAX PARCEL #23-35-2316-074 BEING the same premises which Liberty Associates, by Deed dated 8!22/1998 and recorded 9!2/1998 in Book 184 Page 901 Instrument #1998-030233 granted and conveyed unto Mark W. McAlister and Patricia L. McAlister. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N009-2560 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY; To satisfy the debt, interest and costs due SECRETARY OF VETERANS AFFAIRS Plaintiff (s) From Patricia L. McAlister and Mark W. McAlister (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$166,217.00 L.L. Interest FROM 6/5/2009 TO DATE OF SALE PER DIEM AT $17.18 Atty's Comm Atty Paid $9?7.~2 Plaintiff Paid Date: MAY 13, 2010 (Seal) Due Prothy $2.00 Other CostsTO BE ADDED David D. Buell, P othonotary By: Deputy REQUESTING PARTY: Name David Fein, Esquire Address: Goldbeck McCafferty & McKeever, Suite 5000- Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 82628 ' L!/ On June 14, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Mount Holly Springs Borough, Cumberland County, PA, Known and numbered as, 34 Liberty Drive, Mount Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: ~.-~, Real Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Curr~berland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal; a-legal periodical published in the Borough of Carlisle in the County and.State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1452, been regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 2010 Avant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 30 day of July, 2010 Notary NOTARIAL SEAL DEBORAH A COLUNS NoUry PubUc CARL18lE BOROUtiH, CUMBERLAND COUNTY My CommNNon Expint Apr 28.2014 writ itt.. ao~-~ t~ru Secretary of Veterans Affairs vs. Patricia L. McAlister Mark W. McAlister Atty.: Michael McKeever All that certain parcel of land situ- ate in the Borough of Holly Springs, County of Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the Southernmost dedicated right of way line of Liberty Drive, a 50 foot wide street said pin marking the common point of adjoiner of Lota #30 and #31 on the hereinafter mentioned plan of subdivision; thence extending in and along the Southernmost dedicated right of way line of Liberty Drive, by an arc of curve to the left having a radius of 213.89 feel. a chord of 110.66 feet on a bearing North 62 degrees 27 minutes 41 seconds East for an arc distance of 111.93 feet to an iron pin on said dedicated right of way line at Lot #57; thence departing from the liberty Drive right of way and extending along Lot #57, South 46 degrees 11 minutes l3 seconds East for a distance of 468.51 feet to a steel pin; thence South 62 degrees 1 minute 50 seconds West, fora dis- tance of 206.28 feet to a steel pin at Lot #30; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the South- ernmost dedicated right of way line of Liberty Drive, said point marking the place of beginning. Containing 1.4180 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods prepared for Liberty Associ- ates by Walter N. Heine Associates, Inc. dated December 8, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 64, at Page 90A. BEING KNOWN AS 34 LIBERTY DRIVE, MOUNT HOLLY SPRINGS PA 17065. IMPROVEMENTS consist of a residential dwelling. BOROUGH OF HOLLY SPRINGS. BEING PREMISES: 34 Liberty Drive, Mount Holly Springs, PA 17065. SOLD as the property of PATRI- CIA L. MCALISTER and MARK W. MCALISTER. TAX PARCEL #23-35-2316-074. BEING the same premises which Liberty Associates, by Deed dated 8/22/1998 and recorded 9/2/1998 .. . . . . ... ... . . _ . in Book 184 Page 901 Instrument ;,,;,,.,.j #1998-030233 granted and conveyed `~,..1ii.1 ~ ; tAR unto Mark W. McAlister and Patricia ~,!E#lir' i1sS+~L. McAlister. ~___ ;1'Ni10:1 OI~F~.!i~'181v1(;:- ,itii`1UORflz :i.i't.i?1~1:)k C~t0~ ,3S utt~ .ay~4x3 notzaimma,) YM .. _.~_Y...,.,,.~..~.,.r.~.,~........~..:,~~...,,m.v,. The Patriot-News Co. 1'b20 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ~latriot-Neu~s NoW you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and c~xisting under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and Septc~mber 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and ennpowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on t:he date(s) shown below: 07/09/10 07/16/10 07/23/10 Sworn Wand subscribed before me this05~y of,August, 2010 A.D. ~~ ~ ~ ~ -_. -_-._ Notary Public° COMMONWEALTH OF PENNSYLVANL4 Notarial Seal Sherrie L. Klsner, Notary Public Lower Paxtan Twp., Dauphin County My Commission Expires Nov, 26, 2011 M~'tni'oraivanla Association of Notaries Writ No. 2009-2560 CIvilTerm Secretary of Veterans Affairs Vs Patricia L McAlister Mark W McAlister Arty: Michael McKeever All that certain parcel of land situate in the Borough of Holly Springs, County o1 Cumberland, and State of Pennsylvania, being known and designated as follows: Beginning at an iron pin set on the 5oudternmosl dedicated right of way line of Liberty Drive, a SC foot wide street said pin marking the common point of adjoiner of Lots #30 and #31 on the hereinafter mentioned plan of subdivision: thence extending in and along the Southermnosl dedicated right of way line of Liberty Drive: by an azc of curve to the left having a radius o1 213.89 feel. a chord of 110.66 feet on a bearing North62 degrees 27 minutes 41 seconds East fog an arc distance of 111.93 feet to an iron pin on said dedicated tight of way line at Lot #57; thence departing from the liberty Drive right of way and extending aiong Lot #57, South 46 degrees 11 minutes 23 seconds Fast for a distance of 468.51 feet to a steel pin; thence South b2 degrees 1 minute 50 seconds West, for a distance of 206.28 feet to asteel pin at Lot #30; thence extending along Lot #30, North 29 degrees 48 minutes 39 seconds West for a distance of 432.21 feet to a steel pin set on the Southemmosi dedicated right of way line of Liberty Drive, said point mazking the place of beginning.' Containing 1.4180 acres, and being designated as Lot #31 on a final plan of subdivision of liberty Woods prepared for Liberty Associates by Walter N. Heine Associates, Inc. dated December 8, 19$9 and recorded in the Office of the Recorder of Deeds in and for. Cumberland County. Pennsylvania, in Plan Book 64, at Page 90A. BEING KNOWN AS 34 LIBERTY DRIVE. MOUNT HOLLY SPRINGS PA 17065 IMPROVEMENTS consist of a residential dwelling. BOROUGH OF HOLLY SPRINGS BEING PREMISES: 34 Liberty Drive Mount Holly Springs, PA 17065 SOLD as the property of PATRICIA L. MCALISTER and MARK W. MCALISTER TAX PARCEL #23-35-2316-074 BEING the same premises which Liberty Associates, by Deed dated 8!22!1998 and recorded 912(1998 in Book 184 Page 901 Instrument #1998-030233 granted and conveyed unto Mazk W. McAlister and Patricia L. McAlister. COMMONWEALTH OF PENNSYLVAMA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Veterans Affairs Secretary is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 13th day of May, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 2560, at the suit of Veterans Affairs Secretary against Patricia L & Mark W McAlister is duly recorded as Instrument Number 201029355. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this >~`~ _ _day of of Deeds ReoordetdD~ Cu~Ardtbu~t ~~M My caa~ion 6~ b RgtMaW~ 1f i~.~