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U / GULD$ECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. RICHARD D. ALBERTSON ANNE M. ALBERTSON Mortgagors and Record Owners 132 Briar Patch Drive Carlisle, PA 17013 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term avi No. #1-,;,?771 CIVIL ACTION; MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT ANY INFORMATION 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: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website bgp://www.phfa.orp-/consumers/homeowners/real.gpx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretentionagoldbecklaw.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 80269FC. 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 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P., 7105 Corporate Drive, PTX C 35 Plano, TX 75024. 2. The names and addresses of the Defendants are RICHARD D. ALBERTSON, 132 Briar Patch Drive, Carlisle, PA 17015 and ANNE M. ALBERTSON, 132 Briar Patch Drive, Carlisle, PA 17015, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On June 28, 2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR QUICKEN LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1764 Page 3535. The mortgage has been assigned to: BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for November 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 ..................................................................................$123,097.89 Interest from 10/01/2008 through 03/18/2009 at 6.2500% .......................$3,590.16 Per Diem interest rate at $21.37 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,154.89 Late Charges from 11/01/2008 to 03/18/2009 .............................................$385.85 Monthly late charge amount at $77.17 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $321.74 $134,128.79 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in 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 Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $134,128.79, together with interest at the rate of $21.37, 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 Sheriffs Sale of the Property. By: %1 r Azut,? GOLDBECK WCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 1, Kathy Repka _ 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 unswom falsification to authorities. Date: 9) Am r)la" Kathy Repka, As tant Secretary #80269FC - RICHARD D. ALBERTSON and ANNE M. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 Prepared By and Return To: Beth Gradel GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 GMM File Number: 80269FC Parcel ID#: 21-05-0433-287 ASSIGNMENT OF MORTGAGE COUNTRYWIDE HOME LOANS INC. (Assignor), for and in consideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to COUNTRYWIDE HOME LOANS SERVICING, L.P. COUNTRYWIDE HOME LOANS SERVICING, L.P. (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed RICHARD D. ALBERTSON and ANNE M. ALBERTSON , Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR QUICKEN LOANS INC. Bearing date of. June 28,2M; Amount Secured: $180,®00.00; Recorded on July 10, 2002; in Book 1764 Page 3535; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 132 Briar Patch Drive, Carlisle,PA 17013 AS FURTHER DESCRIBED IN EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate corporate officers, has executed and sealed with its corporate seal this Assignment of Mortgage on this day of ?QR ® 3 X009. (Affix Corporate Seal) COUNTRYWIDE HOME LOANS INC. Ak?-' (SEAL) Name: MtQl1f198l1linap1l IT Title: 1/7 Name: Title: ss: STATE OF ) COUNTY OF 0Q[1'11f BE IT REMEMBERED, that on this day of APR 0 3 7009 , 2009, before me, the subscriber, a Notary Public personally appeared KCdftChfTW DO PiRs ME officers of Assignor, who I am satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary act and deed of such corporation made by virtue of a Resolution of its Board of Directors. Pu c . %commission expires: MAY 0 5 20;0 I hereby certify the address of the Assignee is: 7 OS Corporate Drive, PTX C 35, P1ano,TX Case #: 80269FC 75024 kiy "'r E.rthibitA KKMBIT A -- Leo Description Deal Number: 11- 00 25415 0 7uL Mr. 11-00893283 REV. NO. Tax ID No. 21-05-0433-287 Land situated in Cmabsrlaad County, Pemsylvani.s All that certain lot or. tract of land situate in Middlesex Township, Cumberland county, Pennsylvania, as described in accordance with the Final Subdivision Plan for the Meadows IV, Phases 1-C and 3-C, prepared by Hartman and Associates, Inc., Engineers and Surveyors, dated November 8, 1993 and revised December 30, 1993, more particularly bounded and described as follows, to wit: Beginning at a point on the Western line of Bria Patch Drive, a 50 foot right of way, at the dividing line of Lot #82 `arid81 on the aforementioned plan; thence along the Western line of Briar Patch. Drive, along a curve to the right with a radius of 675.00 feet, a distance of 96.11 feet to a point; thence continuing along the Western line of Briar Patch Drive, South 25 degrees 29 minutes 18 seconds East a distance of 56.89 feet to a point at the dividing line of Lot #81 and #80; thence along the Northern line'of Lot #80, South 81 degrees 12 minutes 39 seconds West, a distance of 156.00 feet to a point at the dividing line of Lot #81 and Lot #69 on plan of residual of Phase 3-A; thence along the Eastern line of Lot #69 North 25 degrees 29 minutes IS seconds West a distance of 13.89 feet to a point; thence continuing along the Eastern line of Lot #69, along a curve to the left with a radius of 725.00 feet a distance of 79.63 feet to a point at the dividing line of Lots #81 and #82; thence along the Southeastern line of Lot No. 82 North 58 degrees 13 minutes 06 seconds East, a distance of 150.00 feet to a point and place of beginning. Being known as Lot #81, Phases 1-C and 3-C, The Meadows IV recorded in Cumberland County, Plan Book 68, Page 2. Commonly known as: 132 Briar Patch Drive I Certify this to be recorded In Cumberland County PA OK I I64K355 Ex,hibit B ALBERTSON, RICHARD D. RICHARD D. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17015 File #: 80269FC IC (ACT) Sale date: County: Cumberland Property. 132 Briar Patch Drive Carlisle, PA 17013 Filet 80269FC JC (ACT) Sale date: County: Cumberland Property: 132 Briar Patch Drive Carlisle, PA 17013 ACT 91 NOTICE DATE OF NOTICE: 03/24/2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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. This is an official notice that the mortgage on Your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Age_ncv . The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. if you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notiricacion en adjunto es de soma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos a] numero mencionada arriba. Puedes ser elegible para un prestamo por el programa ilamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com Date: 03/24/2009 Homeowners Name: RICHARD D. ALBERTSON and ANNE M. ALBERTSON Property Address: 132 Briar Patch Drive, Carlisle, PA 17013 Loan Account No.: 1114840 Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR QUICKEN LOANS INC. :...Current Lender/Servicer: COUNTRYWIDE HOME LOANS SERVICING; L.P. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE . MORTGAGE PAYMENTS 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 (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOJI MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. 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 (30) 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.) 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 completes[ Homeowner's Emergency Assistance Prograrn Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your. application. During that time, no foreclosure proceedings will be pursued against you -if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING.PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it uo to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 132 Briar Patch Drive, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 11/01/2008 thru 03/24/2009 (5 mos. at $1,865.11/month) $9,325.55 (b) Late charges from 11/01/2008 thru 03/24/2009 (5 mos. at $77.17/tnonth) $385.85 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $9,711.40 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 9 711.4 , 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: Attention: Act Letter Department COUNTRYWIDE HOME LOANS INC. c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 Ho meRetenti on(c,)go ldbeckl aw. coin 866-413-2311 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 ri¢hts to accelerate the mortame 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 mort eggd 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 attorneys, but you cure the delinquency before the lender brings 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 he default within the THIRTY 30 DAY Period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun. You still have the right to cure the default and prevent the sale at any tune up to one hour before the Sheriffs Sale You may do so by pa Ling 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 mortgaged property could be held would be approximately fur 4) to 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 anytime exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: , COUNTRYWIDE HOME LOANS, INC: Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 972-526-2354 Fax Number: 817-230-6811 Contact Person: Nicole Graves] 3 Email: PHFA-Prograi-n@country%yide.com 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 Sheriffs 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 attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO.OBTAiN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. BEHALF. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR 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. Contact Person: Nicole Graves] 3 Phone Number: 972-526-2354 HEMAP Consumer Credit Counseling Agencies Report lest updated: 12/23120081:52:41 PM Lycotn.Cinhr Cc Comm ra Comm Actlors 2138 Lincoln Street P.O. Box 3568 Williamsport PA 17703 570.326.0587 CCCS or Western PA 2000 Linglesfown Road Harrisburg. PA 17102 888.511.2227 888.511.2227 COLUMBIA County Anwrican Credit Counseling lnstbuts 212 Berwick-Hazaltnn Hwy Nescopeck, PA 18635 888.468.8847 CCCS of Northasstora PA 401 Laurel Street PktslDn, PA 18640 570.802.2227 800.922.9537 CRAWFORD County Booker T. Washl nWn Canter 1720 Holland Street Erie, PA 16503 814A53.5744 CCCS of Wosterr, PA 4402 Peach Street Erie, PA 16509 888.5112227 ext 108 888.511.2227 ext 108 Center for Family Services, Int. 213 Center Street Meadville, PA 16335 814.337.8450 Greater Eris Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459A581 Shenarngo Vallsy th-han league, Inc. 601 lndkm Avenue Ferrety, PA 16121 724.961.5310 SL IAartir. Center 1701 Parade Street Erie, PA 16503 814.452.8113 CULttIBERLAND County Adorns County Intrrfalth Housing Author@y 40 E High Street Gettysburg, PA 17325 717334.1518 Community Action: Commission of Captiat Region 1514 Derry Street Harrisburg, PA 17104 717237.9757 Loveship,Inc. 2320 North 5th Street Harrisburg, PA 17110 717.2322207 Warsnetha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 60D342.2397 DAUPHIN County CCCS of Westem PA 2000 Linglestown Road Harrisburg, PA 17102 888.5112227 888.5112227 Communfty Action Conrmi"lon of Csptlal Raglan 1514 Derry Street Harrisburg, PA 17104 717232.9757 Loveship, inc. 2320 North 5th Street Harrisburg, PA 17110 717.2322207 Opportunity Inc. 301 East Market Street York, PA 17403 717.424.3645 PHFA 211 North Front Sintet Harrisburg, PA 17110 717.7803940 800.3422397 DELAWARE County Acorn Housing Corporation 846 North Broad Street Phibdalptrie, PA 19130 215.765.1221 Paps 7 of 19 Ri L - ? 0 t. t: F THE P"I'71h "T 2699 MAY -4 Aid I I: G 4 G 4T' fy ## Id m ykg,00 P# xwt,161d Sheriffs Office of Cumberland County R Thomas Kline 0-0 of cumb'p Edward L Schorpp SheriffSolicitor ?k Ronny R Anderson Jody S Smith Chief Deputy OFFJ0E OF 7 HE SKRIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/14/2009 04:15 P 2009 at within n at the s; 05/14/2009 04:15 P 2009 at within n of defer and at t SHERIFF COST: May 15, 2009 - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 615 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the red defendant, to wit: Richard D. Albertson, by making known unto Richard D. Albertson y, at 132 Briar Patch Drive, Carlisle, Cumberland County, Pennsylvania, 17013 its contents and ne time handing to him personally the said true and correct copy of the same. I - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 615 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the med defendant, to wit: Anne M. Albertson, by making known unto Richard D. Albertson husband lant, at 132 Briar Patch Drive, Carlisle, Cumberland County, Pennsylvania, 17013 its contents e same time handing to him personally the said true and correct copy of the same. SO ANSWERS R THOMAS KLINE, SHERIFF Deputy/-Sheriff 2009-2771 BAC Home v Richard Albertson C") +v ?" (V ` ? fTt r? { J GOLDBECK McCAFFERTY & McKEEVER Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 80269FC CF: 05/04/2009 SD: 02/02/2011 $151,636.81 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTXC35 Plano, TX 75024 Plaintiff vs. RICHARD D. ALBERTSON ANNE M. ALBERTSON Mortgagor(s) and Record Owner(s) 132 Briar Patch Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FOR?;CLWUVV, c Term co _10:r N i il 27 09 ° C= C:) ? =a -n v - o. c - ? (r , -urn ov Cry --ia o?*? n ZCO o r*t CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Keith C. Halili, an employee of Goldbeck McCafferty & McKeever, counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) Personal Service by the Sheriffs Office /ce?ni?e-nt-adult (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. Respect fu ly submi ed BY: Keith C. Halili Legal Secretary J _. i ? ?l 9 ?{ry u CJ ??.?1l59! i n t; r. ? C O • C O w - ? ---- vn Q 03 > N m C d Z ? m CD O m`m m .a ? C Z QS I- Z m Eo ?'m aw6r. ?$ ' yarn CO ON ?'?? OQr - -- E D mm?w m°C ?!7 ` q m " 0 OOOD m 0- o J- m `s 0 o' [r N O? j. a- o a. 1. U - U)Z X Z C - - m ?o m W {O O dm U_) Zcy - c a ° d FW-?U m c m i c c m o W `m m -E z Z D g ¢ -r o [J 8 m Q 55 ` . H _ cm J m Cl?) w m 0 9 S m ?' m m m E D m m Q¢QCn Y 2 O U o ? ? ? ? Q O Ir W E m x V m w i ]??({ G w t 0- co co z Y m Z E ) a m 3 O V m m c= v Q m N U) R g o m U? Zfq -° DLO W m m ® Z a d '6 0- L; r- U T U 2 o m0'?X m U U O W J= U CN x N P: a ) 3 O U) F- X W ???? z? fl_ m j:- Co z 0 m 00 y awU m=d 0 a- 0 m m U CD ? V5 O p a n? E m CD W E Z CD LJQ v o CC [L m U) Q a 4/ l YOWa - o - N UOY-?co m v V O w Lo w?'na m ? p7 mOW2Qco T zA E.JI _J O to r-r o ?b I Z O d O N c7 V L6 c0 Ih c6 , d 0. C 0 a. m m O w T H T Q M m Q U O O N co O N Z r O N U) W _N m c0 Q U) z z a 0 U 06 Z C O i6 N m E W ? ? CI] U U Q \ti p yM U Q LL {n o U a co CC K c u c V J ifa' = c r O t v U) L 2 V ? r ? t a. 0 i CO L c N :n O Q i?'t1 Lo g L C-.4 7 Z > CD ? C O m m m C Q) V a Q `C > mw C a m N ? C? a. m = Qi 'D W L U m d) W tOEc g = Q a o Emmoa(D w ? 25 ra ? O Cn m m ON ? ¢c `oo n.? _ ¢ U c m o ? to N L d ~ C ?. m a m o ? ? o ? a U ?5m{? m m d a A LL O LL o ° a ?? m U m ?0?? C) O w z 3 Z a Q ¢ m m o r X C: U-) M n lL a LL z 12 w c0 ? , a ° z c4 O S co O ?y co z c?i F- 0) co Q< W _ N = r v N a in O U) m _ m •? t0 L E $ -60> C) a <U o m d 0 r J a O Na Q (M r _. m w m? 1 !g o p y ¢ Nm CO w U ? n O H LL =C Y Q Z ° Z) o O co Zw 0 N laL N J L X, ' -- d Y???o J 0 J?? m ?w mc`? g) m w ? L g> co to J z' .. tome,,. z e a O z LLI U 0Itma X U w a= IL 4 = . m a ' o IL. Ey m ? r E ' U C W z Q n m Q oYoWd a? ?W° aw M ° o , M llSm'?QGT CD Lu Q c y A m ? E g a E -1 i-- j c5 z c9 cn *,- a - r cli c ui ui a o N c m Q C O a m m `o Y C d CL a a m m CL E O U .- O N co O N_ ai Rf 0 ft1 N >, o c 3 O U N f6 o L N N z ? m ? U lL rti rl. M U € co LL N a c°o Z O W m J Q W Z Z Q Z O U) F - w W m J Q 0 No L.L 2 U Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 8.?rdu p{ tr+brr4.0? w_ 47 2", T ©MCE or THE SiEPiFF t BAC Home Loans Servicing, LP Case Number vs. Richard D. Albertson (et al.) 2005-2771 SHERIFF'S RETURN OF SERVICE 10/08/2010 05:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1719 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 Richard D. & Anne M. Albertson, located at 132 Briar Patch Drive, Carlisle, , Cumberland County, Pennsylvania according to law. 10/08/2010 05:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1719 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: Richard D. Albertson, by making known unto, Richard D. Albertson, Jr., son of defendant, at, 132 Briar Patch Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 10/08/2010 0523 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1719 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: Anne M. Albertson, by making known unto, Anne M. Albertson, personally, at, 132 Briar Patch Drive, Carlisle, 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: $908.92 October 26, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF 11-7 COMt;&ate Shwffl. Tele.. Ix. GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. RICHARD D. ALBERTSON ANNE M. ALBERTSON Mortgagor(s) and Record Owner(s) 132 Briar Patch Drive Carlisle, PA 17013 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. civil-09-2771 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P., Keith C. Halili, an employee of Goldbeck McCafferty & McKeever, counsel of Plaintiff, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 132 Briar Patch Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): RICHARD D. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 ANNE M. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: RICHARD D. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 ANNE M. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PENNSYLVANIA STATE BANK 2148 Market Street Camp Hill, PA 17001 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 WELLS FARGO BANK, N.A. c/o Joshua I. Goldman 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 COMMONWEALTH OF PA, DEPT. OF REVENUE Bureau of Compliance Dept. 280946 Harrisburg, PA 17128 COMMONWEALTH OF PA, DEPT. OF REVENUE Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 WELLS FARGO BANK, N.A. 3476 Stateview Boulevard Fort Mills, SC 29715 PENNSYLVANIA STATE BANK C/O ROBERT D. KODAK 407 North Front Street P.O. Box 11848 Harrisburg, PA 17108 4. Name and address of the last recorded holder of every mortgage of record: WELLS FARGO BANK NA 11601 North Black Canyon Highway Phoenix, AZ 85029 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 132 Briar Patch Drive Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 1, 2010 GOLDBECK McCAFFERTY & c CFEVER BY: Keith C. Halih Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor BAC Home Loans Servicing, LP vs. Richard D. Albertson (et al.) ofoi,r:L?rf416 C- - F1I_ -)j-(1It'- I i P P'1 ? I ", )1f;?TA'.d Y LU° i mti -7t A 8* 2!, COUNITY r ,• Case Number 2009-2771 SHERIFF'S RETURN OF SERVICE 10/08/2010 05:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1719 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 Richard D. & Anne M. Albertson, located at 132 Briar Patch Drive, Carlisle, , Cumberland County, Pennsylvania according to law. 10/08/2010 05:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1719 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: Richard D..Albertson, by making known unto, Richard D. Albertson, Jr., son of defendant, at, 132 Briar Patch Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 10/08/2010 05:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1719 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: Anne M. Albertson, by making known unto, Anne M. Albertson, personally, at, 132 Briar Patch Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/07/2010 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011 01/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney McCafferty on 12/28/10. SHERIFF COST: $1,477.67 January 04, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ?0 If-4 79?1' ;?f IC cou;fySuite S.^e'ff. T;! eczoft li'„;. c? 1 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff V5. RICHARD D. ALBERTSON ANNE M. ALBERTSON (Mortgagor(s) and Record Owner(s)) 132 Briar Patch Drive Carlisle, PA 17013 Defendant(s) No. civil-09-2771 AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P., 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: 132 Briar Patch Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): RICHARD D. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 ANNE M.ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: RICHARD D. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 ANNE M. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PENNSYLVANIA STATE BANK 2148 Market Street Camp Hill, PA 17001 SPA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: WELLS FARGO BANK NA 11601 North Black Canyon Highway Phoenix, AZ 85029 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 he 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 132 Briar Patch Drive Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August 16, 2010 L CMCKEEVER BY: Martin Hynes civil-09-2771 GOLDBEC$•McCAMRTY & 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 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. of Cumberland County CIVIL. ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RICHARD D. ALBERTSON ANNE M. ALBERTSON Mortgagor(s) and Record Owner(s) 132 Briar Patch Drive Carlisle, PA 17013 Docket No. civil-09-2771 Defendant(s' , THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN,ANN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WELL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALBIERTSON, RICHARD D. RICHARD D. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 Your house at 132 Briar Patch Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $151,636.81 obtained by BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: civil-09-2771 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 civil-09-2771 717-243-9400 civil-09-2771 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.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.orWconsumers/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 1-866413-2311 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 80269FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain lot or tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, as described in accordance with the Final Subdivision Plan for the Meadows IV, Phases 1-C and 3-C, prepared by Hartman and Associates, Inc., Engineers and Surveyors, dated November 8, 1993 and revised December 30, 1993, more particularly bounded and described as follows, to wit: Beginning at a point on the Western line of Briar Patch Drive:, a 50 foot right of way, at the dividing line of Lot #82 and #81 on the aforementioned plan; thence along the Western line of Briar Patch Drive, along a curve to the right with a radius of 675.00 feet, a distance of 96.11 feet to a point, thence continuing along the Western line of Briar Patch Drive, South 25 degrees 29 minutes 19 seconds East a distance of 58.89 feet to a point at the dividing line of Lot #81 and #80; thence along the Northern line of -Lot #80, South 81 degrees 12 minutes 39 seconds West, a distance of 156.00 feet to a point at the dividing line of Lot #81 and Lot #69 on plan of residual of Phase 3-A; thence along the Eastern line of Lot #69 North 25 degrees 29 minutes 18 seconds West a distance of 13.89 feet to a point; thence continuing along the Eastern line of Lot #69, along a curve to the left with a radius of 725.00 feet a distance of 79.63 feet to a point at the dividing line of Lots #81 and #82; thence along the Southeastern line of Lot No. 82 North 58 degrees 13 minutes 06 seconds East, a distance of 150.00 feet to a point and place of beginning. Being known as Lot #81, Phases 1-C and 3-C, The Meadows IV recorded in Cumberland County, Plan Book 68, page 2. Commonly known as: 132 Briar Patch Drive TAX PARCEL #21-05-0433-287 civil-09-2771 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 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. 7105 Corporate Drive PTX C 35 Plano,-TX 75024 Plaintiff VS. RICHARD D. ALBERTSON ANNE M. ALBERTSON Mortgagor(s) and Record Owner(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. civil-09-2771 132 Briar Patch Drive Carlisle, PA 17013 Defendant(s; THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU INAN 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: ALBERTSON, ANNE M. ANNE M. ALBERTSON 132 Briar Patch Drive Carlisle, PA 17013 Your house at 132 Briar Patch Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $151,636.81 obtained by BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. 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: civil-09-2771 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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.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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 civil-09-2771 717-243-9400 civil-09-2771 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 I.-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 hiip://www.phfa.ortLonsumers/homeowners/real.Mx. 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 80269FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain lot or tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, as described in accordance with the Final Subdivision Plan for the Meadows IV, Phases 1-C and 3-C, prepared by Hartman and Associates, Inc., Engineers and Surveyors, dated November 8, 1993 and revised December 30, 1993, more particularly bounded and described as follows, to wit: Beginning at a point on the Western line of Briar Patch Drive, a 50 foot right of way, at the dividing line of Lot #82 and #81 on the aforementioned plan; thence along the Western line of Briar Patch Drive, along a curve to the right with a radius of 675.00 feet, a distance of 96.11 feet to a point, thence continuing along the Western line of Briar Patch Drive, South 25 degrees 29 minutes 18 seconds East a distance of 58.89 feet to a point at the dividing line of Lot #81 and #80; thence along the Northern line of -Lot #80, South 81 degrees 12 minutes 39 seconds West, a distance of 156.00 feet to a point at the dividing line of Lot #81 and Lot #69 on plan of residual of Phase 3-A; thence along the Eastern line of Lot #69 North 25 degrees 29 minutes 18 seconds West a distance of 13.89 feet to a point; thence continuing along the Eastern line of Lot. #69, along a curve to the left with a radius of 725.00 feet a distance of 79.63 feet to a point at the dividing line of Lots #81 and #82; thence along the Southeastern line of Lot No. 82 North 58 degrees 13 minutes 06 seconds East, a distance of 150.00 feet to a point and place of beginning. Being known as Lot #81, Phases 1-C and 3-C, The Meadows IV recorded in Cumberland County, Plan Book 68, page 2. Commonly known as: 132 Briar Patch Drive TAX PARCEL #21-05-0433-287 ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-2771 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff (s) From RICHARD D. ALBERTSON and ANNE M. ALBERTSON (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 $151,636.81 L.L.$.50 Interest from 8/17/10 to Date of Sale ($21.37 per diem) Atty's Comm % Due Prothy $2.00 Atty Paid $168.40 Other Costs Plaintiff Paid Date: 8/23/10 David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: KRISTINA MURTHA, 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. 61858 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA, Known and numbered as, 132 Briar Patch Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: eal Estate Coordinator ?u e" ? 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 22, October 29, and November 5, 2010 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 Coyne, F/ditor SWORN TO AND SUBSCRIBED before me this 5 da of November. 2010 Notary OTARIAL SEAL ORAH A COLLINS otary Public COUNTY UGH, CUMBERLAND FCARL ion Expires Apr 28, 2014 +ATId?! i t ,?f A ?::.y 4 CUMBERLAND LAW JOURNAL Writ No. 2009-2771 Civil BAC Home Loans Servicing, LP, F/K/A Countrywide Home Loans Servicing, LP vs. Richard D. Albertson Anne M. Albertson Atty.: Michael McKeever All that certain lot or tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, as described in accordance with the Final Subdivision Plan for the Meadows IV, Phases 1-C and 3-C, prepared by Hartman and Associates, Inc., Engineers and Surveyors, dated November 8, 1993 and revised De- cember 30, 1993, more particularly bounded and described as follows, to wit: Beginning at a point on the West- ern line of Briar Patch Drive, a 50 foot right of way, at the dividing line of Lot #82 and #81 on the aforementioned plan; thence along the Western line of Briar Patch Drive, along a curve to the right with a radius of 675.00 feet, a distance of 96.11 feet to a point, thence continuing along the Western line of Briar Patch Drive, South 25 degrees 29 minutes 18 seconds East a distance of 58.89 feet to a point at the dividing line of Lot #81 and #80; thence along the Northern line of Lot #80, South 81 degrees 12 minutes 39 seconds West, a distance of 156.00 feet to a point at the dividing line of Lot #81 and Lot #69 on plan of residual of Phase 3-A; thence along the Eastern line of Lot #69 North 25 degrees 29 minutes 18 seconds West a distance of 13.89 feet to a point; thence continuing along the Eastern line of Lot #69, along a curve to the left with a radius of 725.00 feet a distance of 79.63 feet to a point at the dividing line of Lots #81 and #82; thence along the Southeastern line of Lot No. 82 North 58 degrees 13 minutes 06 seconds East, a distance of 150.00 feet to a point and place of beginning. Being known as Lot #81, Phases 1-C and 3-C, The Meadows IV re- corded in Cumberland County, Plan Book 68, page 2. Commonly known as: 132 Briar Pat.ch Drive. TAX PARCEL #21-05-0433-287 The Patriot-News Co. 2020 Technology Pkwy Suite 300 ` Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Of Patriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWTS Proof of Publication Under Act No. 587, Approved May 16, '1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being (July 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 StreE!t, 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: 10/15/10 10/22/10 - 10/29/10 .... e:,< .......... . Sworn to anp(/subscribedb?fore me t*10Oay.of November, 2010 A.D. t Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisner, Notary Public Lower Paxton Twp., Dauphin county my rprnmisslon E)Ores Nov. 26, 2011 _ Member, Pennsylvania Association of Notaiies 2009-2171 CM Torm BAC HOW Lawns Servicing, LP, F/K/A C rWe Home Loans SerWcfng, LP Vs Rictu" D. Albertson Anne M. Alertson Att1r: Mict" McKeever All that certain lot or tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, as described in accordance with the 'i;W Subdivision Plan for the Meadows IV, Phases 1-C and 3-C, prepared by Hartman and Associates, Inc., Engineers and Surveyors, dated November 8,1993 and revised December 30,1993, more particularly bounded and described as fellows, to wit: Beginning at a point on the Western line of Briar Patch Drive, a 50 foot right of way, at the dividing line of Lot #82 and #81 on the aforementioned plan; thence along the Western be of Briar Patch Drive, along a curve to the right with a radius of 675.00 feet, a distance of 96.11 feet to a point, thence continuing along the Western line of Briar Patch Drive, South 25 degrees 29 minutes 18 seconds East a distance of 58.89 feet to a point at the dividing he of Lot #81 and #80; thence along the Northern line of Lot #80, South 81 degrees 12 minutes 39 seconds West, a distance of 156.00 feet to a point at the dividing he of Lot #81 and Lot #69 on plan of residual of Phase 3-A; thence along the Eastern he of Lot #69 North 25 degrees 29 minutes 18 seconds West a distance of 13.89 feet to a point; thence continuing along the Eastern line of Lot #69, along a curve to the left with a radius of 725.00 feet a distance of 79.63 feet to a point at the dividing be of Lots #81' and #82; thence along the Southeastern line of Lot No. 82 North 58 degrees 13 minutes 06 seconds East, a distance of 150.00 feet to a point and place of beginning. Being known as Lot #81, Phases 1-C and 3-C, The Meadows IV recorded in Cumberland County, Plan Book 68, page 2. Commonly known as: 132 Briar Patch Drive 'X PARCEL #21-05-0433-287