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HomeMy WebLinkAbout09-4721GOLDBECK 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 LNV CORPORATION 7195 Dallas Parkway Plano, TX 75024 Plaintiff vs. THOMAS C. SWANGER HEIDI J. SWANGER Mortgagors and Record Owners 23 and 25 Roosevelt Street Enola, PA 17025 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVII, ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 0Q - N7a 1 Cl!/IL ACTION: MORTGAGE byll«, NOTICE lines 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 orby 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 mazy 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 http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 83489FC. Para informacion en espanol puede communicarse con Loretta a1215-825-•6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is LNV CORPORATION, 7195 Dallas Parkway, Plano, TX 75024. 2. The names and addresses of the Defendants are THOMAS C. SWANGER, 23 and 25 Roosevelt Street, Enola, PA 17025 and HEIDI J. SWANGER, 23 and 25 Roosevelt Street, Enola, PA 17025, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On June 22, 2000 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to AAMES FUNDING CORPORATION, DBA AAMES HOME LOAN, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1623 Page 96. The mortgage has been assigned to: LNV CORPORATION by assignment of Mortgage July 23, 2008 as Instrument # 200825170. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$27,912.85 Interest from 09/01/2008 through 07/30/2009 at 9.7500% .......................$2,509.83 Per Diem interest rate at $7.56 Reasonable Attorney's Fee .................................................................$2,000.00 Costs of suit and Title Search ......................................................................$900.00 $33,322.68 7. Plaintiff is not seeking a judgment of personal liability (or an "in person arn" 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. 8. 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 terris judgment in mortgage foreclosure in the sum of $33,322.68, together with interest at the rate of $7.56, 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: ! )V?// l ? GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF 07/09/2009 13:07 4692298606 MGC MORTGAGE PAGE 23 VERIFICATION I, Monica Hadley , 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 thereini, are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: -2/ ky -- - 1 Monfca Hadley Assistant Vice President, MGC Mortgage, Inc., as loan servicer for LNV Corporation and Authorized Representative #83489FC - THOMAS C. SWANGER and HEIDI J. SWANGER 23 & 25 Roosevelt Street Enola, PA 17025 E.,.x.hibitA Jun-02-2009 03:21pm From- T-240 P. 021/058 F-193 610-3ee-"24 srerwTum SEPIKH ea5 FCM jLk i7 •00 09112 11 : 1 COMIVtITmaNT 5CNBDKE C File NumbEr; SM2320 ALL THAT CERTAIN tract or parcel of land, beginning at a point at the southwest cgmar of Roosevelt and Camatt Streets; thence rauttrvvarcgy along the westem line of Roosevelt Street seventy five (75) feet to a paint at tha nonhweet comer of Roosevelt Street and an Unnamed Sbdgen Foot (16) Alley; thence wealwa dy along the r r fern Ikea of said $Wow Foot (16) Alley. seventy nine and thirty ttrea-" hutdred (78.33) feat to a point; ttoenee nor#wmrdty along land now d late of Gaorge W. and Eveatlne A Willa. seventy fnw (76) feat, mom or het, to a point on the southern tim of C matt Street; therm eashvardly along Ulm aoudmrn Arm of Commit Street, eighty one and twenty nine-one hundredths (81.29) feet to a point, the place of BEGINNING. BEING the eastern W of Lob Na 42.43 and 44 in the Plan of Lots laid out by Theodore M. MoU and rewrded in the Office for the Recording or Deods in end for Cumberland County in Plan Book 1, page 2. HAVING thereon eroded a one story frame dvmlNrlp kr oVm as No. 25 Roosevelt Street and a concrete bl** dweliklg kmw ss No. 23 Roosevelt Street BEING part of Tads No. 1. and No.. 2 of the earns premises whkh The Estate of Nyrp mt E. Wittle, by Deems dated it> MISe6 and recorded in and for doe Coady of Qumbarland. In DoW Book P.31. page 760, granted and conveyed unto Thomas C. 8wmW and WmN J. Svmnger, In fee. yrsta m mnspvanw l County Of CumbMWO f R r, I ttm offlrr fa, he rOCa?,npp" of panda act a? ?: ry.K,u w,erv."'14 . Uoi _ ?YfJ 1. my h aI al vj+e ( f? tdard Itool1?623?ia,1E iQ? 06102/2009 11:41:33 AM CUMBERLAND COUNTY Inst.* 200017410 - Page 7 of 7 Exthibit (B SWANGER, THOMAS C. THOMAS C. SWANGER 25 Roosevelt Street Enola, PA 17025 File #: 83489FC JC (ACT) Sale date: County: Cumberland Property: 23 & 25 Roosevelt Street Enola, PA 17025 i SWANGER, HEIDI J. HEIDI J. SWANGER 25 Roosevelt Street Enola, PA 17025 File #: 83489FC JC (ACT) Sale date: County: Cumberland Property: 23 & 25 Roosevelt Street Enola, PA 17025 I ACT 91 NOTICE DATE OF NOTICE: June 1, 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 mort a e on our hom_e_ 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 Agency. The name address and hone number of Consumer Credit Counseling Agencies serving our Count are listed at the end of this Notice. If you have an questions, ou may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 717 780-18691 This Notice contains important legal information. If your 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 notificacion en adjunto es de suma 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 al numero mencionada arriba. Puedes ser elegible para un prestamo 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. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 1 Date: June 1, 2009 Homeowners Name: THOMAS C. SWANGER and HEIDI J. SWANGER Property Address: 23 & 25 Roosevelt Street, Enola, PA 17025 Loan Account No.: 17100234 Original Lender: AAMES FUNDING CORPORATION, DBA AAMES HOME LOAN Current Lender/Servicer: MGC MORTGAGE, INC. 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 FORECLOSU"' - 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 YOU 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 counselin a encies for the coun in which the roperty 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 completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To 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 ARK CURRENTLY PROTECTED BY THE FILING OT! A PPTITION IN BANK3t1fIPTCY, THE FOLLOWING PART OF THIS. NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMP'T' TO COLLECT THE DEBT. (If you`have filed bankruptcy you can still apply for Eme ne Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it uD to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 23 & 25 Roosevelt Street, Enola, PA 17025 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 10/01/2008 thru 6/1/2009 (9 mos. at $476.72/month) $4,290.48 (b) Other charges; Escrow, Inspec., NSF Checks (c) Other provisions of the mortgage obligation, if any (d) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $4,290.48 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 $4J90-48 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Parents must be made either b cashier's check certified check or money order made payable and sent to: MGC MORTGAGE, INC. 7195 Dallas Parkway Plano, TX 75024 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 mortaa a 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 mortraged nronerty. 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 the default within the THIRTY (30) DAY period. you will not be required to nay 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 ri t to cure the default and revent the sale at an time u to one hour before the Sheriffs Sale. You may do so by paving 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 another 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 four (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 any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: MGC MORTGAGE, INC. Address: 7195 Dallas Parkway Plano, TX 75024 Phone Number: 469-229-8792 Fax Number: Contact Person: Kylan Carter 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 it 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 We 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 INSTMMON TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. 5 * 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: Kylan Carter Phone Number: 469-229-8792 HEMAP Consumer Credit Counseling Agencies Report feet updated; 12123r W 1.62:41 PM Ltrcwn.Ctntn CO COMM 1o Csarnt Action 2138 Lincoln Street P.O. Box 3588 Williamsport PA 17703 570.328.0587 COLUMBIA County American Cram Counseling bwm to 212 Berwick }iazekon Hwy Neacopedn, PA 18835 OBBA68.8847 CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18840 570.8022227 800.922.9537 CRAWFORD County CCCS of Mfeatsrn PA 2000 Linglestown Road Harrisburg, PA 17102 088.5112227 8811.5112227 Community Action Cotmninslon of Capttal Region 1514 Derry Street Harrisburg, PA 17104 717.232:9757 Lovaship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717232.2207 1#ranatha 43 Philadelphia Avenue Waynesboro, PA 17288 717.782.3285 Booker T. Washington Center 1720 Holland Street Erie, PA 18503 814A83.5744 CCCS at West mt PA 4402 Peach Street Elie, PA 16509 888.511.2227 ext 108 888.5112227 ext 108 Center for Family Services, inc. 213 Canter Street Meadville, PA 16335 814.337.8450 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 18301 814ABBA681 Shenanga Varlley Urban League, ire, 801 I ndlerra Avenue Farrok PA 18121 724.981.5310 St: Martin Center 1701 Parade Sheet Etta, PA 16503 814.452.8113 CUMBERLAND County Adams Caurryr hillsHaffh HousingAu#wft 40 E High Street Gettysburg, PA 17325 717.334.1818 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.3422397 DAUPHIN Cou CCCS of Western PA 2000 Lingiestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commiselwr of Captial Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 Loveship, hw- 2320 North 5th Street Harrisburg, PA 17110 7172322207 OPpottuntty Inc. 301 East Market Street York, PA 17403 717A24.3645 PHFA 211 North Front Street Hartiebu?g, PA 17110 717.780.3040 OW-942239T DELAWARE County Acorn Housing Corporation 848 North Broad Sheet Philadelphia, PA 19130 215.768.1211 Page 7 of 19 0 7 ," 2 G11' vLF_ : b r.; 5, 4 +Ig.5o Po ATrf CL* 32m 1'1 I e aas o(o a Sheriffs Office of Cumberland County R Thomas Kline F1LFD- OF CE Sheri t ?titn of clutibrit THE RR(Y`` °nyJtOTAp Ronny R Anderson Chief De uty ' a r 009 JUL 22 p pro { +Yq 2: G 8 Jody S Smith CU ! Civil Process Sergeant OFFICE c ` -"e s"ERIFF M& :. „- ?,• ? ?? i > Ff {1JSY Edward L Schorpp , L1,- NIA Solicitor LNV Corporation Case Number vs. Heidi J. Swanger 2009-4721 SHERIFF'S RETURN OF SERVICE 07/21/2009 05:23 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 21, 2009 at 1723 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Heidi J. Swanger, by making known unto Thomas Swanger, husband of defendant at 23 and 25 Roosevelt Street Enola, Cumberland County, Pennsylvania 17025 its contents anc at the same time handing to him personally the said true and correct copy of the same. 07/21/2009 05:23 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 21, 2009 at 1723 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Thomas C. Swanger, by making known unto himself personally, defendant at 23 and 25 Roosevelt Street Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $57.50 July 22, 2009 SO ANSWERS, iopo*A*Qe?? R THOMAS KLINE, SHERIFF D uty S eriff GOLDBECK WCAFFERTY & NtcKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 LNV CORPORATION 7195 Dallas Parkway Plano, TX 75024 Plaintiff vs. THOMAS C. SWANGER HEIDI J. SWANGER 23 and 25 Roosevelt Street Enola, PA 17025 Defendants No. 09-4721 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. Michael T. McKeever, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Attorney for Plaintiff OF THE PFiMIJONOTARY 2009 NOV -2 PM 3: 35 1 GUIM P i NS` LVA IA.