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Home My WebLink About09-5549U? GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. RANDY M. WILSON Mortgagor and Record Owner 23 East Allen Street Mechanicsburg, PA 17055 Defendant C IVIL ACTION: MORTGAGE rn t: f, NOTICE '!t*p_n1-11w!- You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term Cl -IIi J No. ej - 55Z/ J A 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 AQTJI 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 hhqn://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: hLtp://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 8512417C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendant is RANDY M. WILSON, 23 East Allen Street, Mechanicsburg, PA 17055, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On February 27, 2008 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR COUNTRYWIDE BANK, FSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Instrument #200806032. The mortgage has been assigned to: BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 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 February 01, 2009 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 ....................................................................................$88,343.48 Interest from 01/01/2009 through 07/09/2009 at 6.5000% .......................$2,988.70 Per Diem interest rate at $15.73 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,417.17 Late Charges from 02/01/2009 to 07/09/2009 .............................................$179.52 Monthly late charge amount at $29.92 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $184.12 $96,828.87 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 Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose has been sent to Defendant by certified mail, as required by Act 6 of 1974 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". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $96,828.87, together with interest at the rate of $15.73, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, %mr* Harman , 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 unworn falsification to authorities. Date: q - ?-Oq Haman; Assistant Vice president #85124FC - RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 Prepared By and Return To: Beth Grade] GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 GMM File Number: 85124FC Parcel ID#: 18-23-0565-040 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR COUNTRYWIDE BANK, FSB (Assignor), for and inconsideration 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 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP. BAC ROME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP (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 RANDY M. WILSON , Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR COUNTRYWIDE BANK, FSB. Bearing date of. February 27,2008; Amount Secured: $89,195.00; Recorded on February 29,2008; in Instrument # 200806032; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 23 East Allen Street, Mechanicsburg, PA 17055 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 MG (11 &a 1 2009. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR COPJTRYWIDE BANK, FSB (Affix Corporate Seal) ry K im ' yWe President Name: Oft Title: Title: Ken Satsky, Assistant ss: STATE OF TEXAS -cou COUNTY OF BE IT REMEMBERED, that on this day of AU r G DIM , 2009, before me, the subscriber, a Notary Public personally appeared Mary Kitt Ken Barsky M4 v yvn GLCC, l xvN IU KMI i I NATION SYSTEMS INC ACTING SOLELY AS A NOMINEE FOR RYWIDE BANK FSB 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 an&dof hcorporation made by virtue 0 of a Resolution of its Board of Directors. Notarybiic LMana MOW My commission expires: OCT 2 1 2012 I hereby certify the address of the Assignee is: 7105 Corporate Drive, PTX C-35, Plano,TX 75024 Case #: 85124FC 'Tt• LILIANA MORCAN My Commission Expires October 21, 2012 4'R d ? ft? Ex,ohibitA Exhibit A ALL that certain lot of ground situated an the North side of East Allen Street, in the Borough of Mechanicsburg, County of Cumberland Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the building line of said East Allen Street and the line of land now or formerly of Daniel K. Kopenhaver; thence northwardly along the line of the latter land and through and beyond a joint private alley, one hundred thirty-two (132) feet, more or less, to an iron pin at a public alley; thence eastwardly along said alley, twelve and eight hundred seventy-five thousands (12.875) feet to a line of lands now or formerly of James A. Potteiger and Emma F. Pottelger, his wife, thence southwardly along said lands and through the partition wall of a double frame dwelling house, said wall dividing properties known as Nos. 23 and 25 East Allen Street, one hundred thirty-two and five- tenths (13250) feet, more or less, to a point on the building line of said East Alen Street; thence westwardly along said building line twelve and eight hundred seventy-five thousands (12.875) feet to the place of BEGINNING. HAVING thereon erected the western half of a two and one-half story double frame dwelling house known and numbered as No. 23 East Allen Street, Mechanicsburg, Cumberland County, Pennsylvania. BEING the same premises which Mark A. Wagner and Allyson L. Carnes nka Allyson L. Wagner by deed dated October 15, 2007 and recorded in the Recorder of Deeds in and for Cumberland County to Instrument No. 200739750, granted and conveyed unto John W. Vogelsong. BEING the same premises which Harrison P.11alterman and Gloria R. Halteraman by deed dated 4/24/03 and recorded in Cumberland County Deed Book 256, Page 3799, granted and conveyed unto Mark A. Wagner and Allyson L. Carnes, single persons. TS S E..x.hibit (B ® Countrywide Bank- SERVICED BY COUNTRYVYIDE PD Box 9048 Temecula, CA 92589-9048 Send Payments To: PO Box 660694 Dallas, TX 75266-0694 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 II?I?In???II?UI?VI?IO?I?I?IIW 2217552400 Randy M Wilson 23 E ALLEN ST MECHANICSBURG, PA 17055-3302 20090406-7 BLOPA2 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1068-?22 IK ® Countrywide Bank. SERVICED BY COUNTRYWIDE P.O. Box 660694 Dallas, TX 75266-0694 Send Payments to: P.O_ Box 660694 Dallas, TX 75266-0694 April 3, 2009 Randy M Wilson 23 E ALLEN ST MECHANICSBURG, PA 17055-3302 Account No.: 187057694 Property Address: 23 E Allen St Mechanicsburg, PA FHA/VA Case #: 4418140198703 NOTICE OF INTENTION TO FORECLOSE Countrywide Home Loans Servicing LP (hereinafter 'Countrywide') services the home loan described above on behalf of the holder of the promissory note (the "Noteholder"). The home loan is in serious default because the required payments have not been made. The total amount now required to reinstate the loan as of 111 Monthly Charges: Late Charae?• Other Charaes• 02/01/2009 $2,243.67 02/01/2009 $59.84 Uncollected Late Charges: Uncollected Costs: $59.84 Partial Payment Balance: $0.00 ($0.00) TOTAL DUE: $2,363.35 You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter. To cure the default, Countrywide must receive the amount of $2,363.35, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due during this period. Such payment must be in the form of certified check, cashier's check or money order, and made payable to Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. If any check (or other payment) is returned to us for insufficient funds or for any other reason, "good funds" will not have been received and the default will not have been cured. No extension of time to cure will be granted due to a returned payment. If this default is not cured within THIRTY-FIVE (35) DAYS, the mortgage payments will be accelerated. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to have the original mortgage paid off in monthly installments. If the full payment of the amount of default is not made within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the default is cured before we begin legal proceedings against the collateral involved, Countrywide and the Noteholder will be entitled to collect the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started the reasonable attorney's fees will have to be paid even if they are over $50.00. Any attorney's fees will be added to whatever is owed to us, which may also include our reasonable costs. If this default is cured within the Thirty-five (35) day period, the attorney's fees will not be required to be paid. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If the default has not been cured within the Thirty-five (35) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the foreclosure sale. To do so, the total due, as well as all reasonable attorney's fees and costs incurred in connection with the foreclosure sale (and any other requirements under the mortgage) must be performed. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (1) observe the physical condition of your property, (if) verify that the property is occupied and/or (Iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. • Make your check payace to Countrywide Home Loans • Write your account number on your dtedk or money order • Write in any additional amounts you are including (N Dotal Is more than $5000, please send certified check) • Don't attach your check to the payment coupon • Don't include correspondence • Don't send cash ffili o e date of this letter is as follows: Please write your account number on all checks and oomespondence. We may charge you a fee for any payment returned or rejected by your finandal institution, subject to applicable law. Account Number: 187067094-7 bandy le Will 23 E Allen St son Balance Due for charges listed above: $2,363.35 as of April 3, 2009. Please update a-mall information on tha reverse side of this coupon. Additional 8LQPA2 P incipal Additional Countrywide 'Escrow PO BOX 660694 Dallas, TX 75266-0694 one Ilrrrl.1.Irr.I.Irllrrrllrrllrrrrllr,I.Irrrirrll,l.,rlr.lr.l.ill.rrl Chock Total 187057694700000236335000236335 It is estimated that the earliest date that such a foreclosure sale could be held would be approximately six (6) months from the date of this letter. A notice of the date of the foreclosure sale will be sent to you before the sale. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-888-872-6514. This payment must be in the form of cashier's check, certified check or money order and made payable to us at the address stated above. If this default is cured, the mortgage will be restored to the same position as if no default had occurred. However, the default may not be cured more than three (3) times in any calendar year. You should realize that a foreclosure sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least''Yz of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you rnust contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by May 8, 2009 as outlined above will result in the acceleration of your debt. Time is of the essence. Should you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-888-872-6514. E-mail use: Providirn?g yyoouur a-mail address below will allow us to send you information on your account. Account Number: 1d70ti7694 E-mail address Nos we Pod Your Pwm mb: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. K you sulxrdt an amount in addition to your scheduled monthly amount, we will apply your payments as fdbws: (r) to outstanding monthly payments of principal and interest, (ii) escrow deficiencies, (iii) late charges and other amounts you owe in connection with your lien and (iv) to reduce the outstanding Principal balance of your ban. Please specify if you want an additional amount applied to future payments, rather than principal reduction. PO$kWOd cheeks: Countrywide's policy is to not accept postdated checks, unless specifically agreed to by a ban counselor or technician. fd:?lf - 5-0 C,? 3tia ?.?y Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor BAC Home Loans Servicing, LP vs. Randy M. Wilson ?p114xtp 01 t u m Grr f?,?f? OFFICE,-)P THE S-ERIFF Case Number 2009-5549 SHERIFF'S RETURN OF SERVICE 09/03/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Randy M. Wilson, but was unable to locate him in his bailiwick. He therefore returns the within Complaint In Mortgage Foreclosure as not found as to the defendant Randy M. Wilson. A neighbor of 23 East Allen Street Mechanicsburg, PA 17055 advised the Deputy's the defendant has moved. The Mechanicsburg Postmaster has advised the defendant's mail is delivered to address given. An exact address is not available. SHERIFF COST: $51.00 September 03, 2009 ALED--OFFICE OF THEE PROTHCNOTAW 2009 SEP -8 AM 10: 3 7 F64,&LV,aNV SO ANSWERS, R THOMAS KLINE, SHERIFF t% GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 OF Cumberland COUNTY No. civil-09-5549 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: Plaintiff is the holder of a first mortgage upon the premises 23 East Allen Street, Mechanicsburg, PA, 17055, hereinafter, the "mortgaged premises". 2. Defendant, RANDY M. WILSON, is the mortgagor and real owner of the mortgaged premises. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, David Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. IN THE COURT OF COMMON PLEAS 4. The last known address of Defendant, RANDY M. WILSON, is 23 East Allen Street, Mechanicsburg, PA, 17055 as set forth in Paragraph 2 of the Complaint. The Sheriff has been unable to effect service of the Complaint upon Defendant, RANDY M. WILSON, at his last known address after numerous attempts. As per the Sheriff, service was attempted at 23 East Allen Street, Mechanicsburg, PA, 17055 but there was no answer. The neighbor advised the Defendant has moved from the property. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, RANDY M. WILSON. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant, RANDY M. WILSON, by posting the premises and certified and regular mail to the Defendant's last known address. Respectfully submitted, zta- A6?1? David B. Fein, Esq. ?- ProVest, LLC Affidavit of Good Faith Investigation Client provided information: File Number: 85124FC Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: Randy M. Wilson Property Address: Street: 23 East Allen Street City: Mechanicsburg State: PA Zip 17055 Skip Results: Date of Birth: 05/18/1969 ProVest File Number: 1906164 Verified Dates: As of 9/14/2009 Street: 23 East Allen Street Phone: City: Mechanicsburg State: PA Zip: 17055 Death Records: As of 9/14/2009, the Social Security Administration has no death record on file for Randy M. Wilson. Social Security Number Search Completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Randy M. Wilson as 23 East Allen Street, Mechanicsburg, PA 17055. Department of Motor The Pennsylvania Department of Motor Vehicles provided no change for Randy M. Wilson from Vehicle Records: 23 East Allen Street, Mechanicsburg, PA 17055. Public Licenses (Pilot, Search performed provided no information. Real Estate, etc): Voter Registration The County Voters Registration Office has no listing for Randy M. Wilson. Information: National Postal Has no change for Randy M. Wilson from 23 East Allen Street, Mechanicsburg, PA 17055. Address Search: Military Search: There was no active military status found. Comments: 717-620-8261: Answering machine verifei dRandy Wilson, reverse search verified address as 23 East Allen Street Mechanicsburg PA 17055. On 9/14/2009, I, Tonya Hardin being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investigation. Sui?scr`b--d A d Sworn to tore fne, ?.k 91 TX-Y) Aftiant Nam o A ya Hardltr- Notary Flublic Date: 9/14/2009++ CMML~ 5 WCOMOSM Sheriffs Office of Cumberland County ?R Thomas Kline Sher Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OF=w£ Or T,4b S!!ERIFF Edward L Schorpp Solicitor BAC Home Loans Servicing, LP vs. Randy M. Wilson Case Number 2009-5549 SHERIFF'S RETURN OF SERVICE 09/03/2009 R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Randy M. Wilson, but was unable to locate him in his bailiwick. He therefore returns the within Complaint In Mortgage Foreclosure as not found as to the defendant Randy M. Wilson. A neighbor of 23 East Allen Street Mechanicsburg, PA 17055 advised the Deputy's the defendant has moved. The Mechanicsburg Postmaster has advised the defendant's mail is delivered to address given. An exact address is not available. SHERIFF COST: $51.00 September 03, 2009 SO ANSWERS, 1 R THOMAS KLINE, SHERIFF 61A ar? GOLDBECK MCCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 VERIFICATION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. civil-09-5549 h L72? Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service 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 unworn falsification to authorities. Z'4a ` A? BY: David B. Fein, Esq. GOLDBECK MCCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024" vs. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 No. civil-09-5549 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa R C P 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant, RANDY M. WILSON, which the Sheriff has been unable to personally serve upon Defendant, RANDY M. WILSON. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, RANDY M. WILSON, by posting the premises and certified mail and regular mail to the Defendant's last known address. Respectfully submitted, IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY David B. Fein, Esq. r GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 of Cumberland County No. civil-09-5549 CERTIFICATE OF SERVICE ?.?- , does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, RANDY M. WILSON, this day of49/9- ?AlCF 2009, by first class mail, postage prepaid. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS BY: David B. Fein, Esq ILUD -t ;.. ? Ty SEP 2 2 200 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY civil-09-5549 ORDER AND NOW, this day o 009, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, RANDY M. WILSON, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant, RANDY M. WILSON, by posting a copy of the Complaint upon the premises 23 East Allen Street, Mechanicsburg, PA, 17055, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address at 23 East Allen Street, Mechanicsburg, PA, 17055, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, RANDY M. WILSON, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the pret J. Dts bution list: ichael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, Philadelphia, PA 19106-1532 RANDY M. WILSON, 23 East Allen Street Mechanicsburg, PA 17055 4 I? 701 Market Street, RLED- CA, OF Tf -E P!?" 2009 SEP 24 A 11* 18 1 , )' i' i GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. civil-09-5549 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER M Aw??- By Michael T. McKeever, Esq. Attorney for Plaintiff OF 209 OCT -I FM 3: 02 CU B?,- t?-r 1 ;LINTY PENNS?VAN A 4 to. oo Po ATr/ Cx,`" 3g9ya9 eomr* a31M? Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 1 i7. ED tJ'- E OF THE PRC ?i ;.A lowy 0111111 2009OCT -7 AM 8: 48 CWhI? _ 1;4? jti 7?ITY QFFl4F :;c .?wF?IFF PE `VSIPl.Y!'?IFA BAC Home Loans Servicing, LP vs. Randy M. Wilson Case Number 2009-5549 SHERIFF'S RETURN OF SERVICE 10/02/2009 04:29 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2009 at 1629 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Randy M. Wilson, pursuant to order of court by posting the premises located at 23 East Allen Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 with a true and correct copy according to law. SHERIFF COST: $43.00 October 05, 2009 SO ANS R R THOMAS KLINE, SHERIFF r" By ` Deputy Sheriff GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. RANDY M. WILSON Mortgagor(s) 23 East Allen Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. civil-09-5549 CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER ESQUIRE hereby certifies that on he did serve upon Defendant(s) RANDY M. WILSON a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated September 24, 2009. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, / 1)&IZa-7 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE ALED- ' =- ICE OF 11E F--l' -",ARY 2 0 0 9 0 v i 2 1 PM 12 = 5 5 ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~4#``11,, d~ 4~r,nG~r~7rt~ ~;, ~.., ~~ ,~,G~ ,~- .~E. ~F~~F~ FI" , E ~ ,T,~,r;{~~, ,, BAC Home Loans Servicing, LP Case Number vs. Randy M. Wilson 2009-5549 SHERIFF'S RETURN OF SERVICE 04/01/2010 07:43 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 1943 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 Randy M. Wilson, located at 23 East Allen Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. 04/01/2010 07:43 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 1943 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Randy M. Wilson, located at 23 East Allen Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. 06/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 2, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of BAC Home Loans Servicing, LP, F/K/A Countrywide Home Loans Servicing LP, 7105 Corporate Drive, PTX C-35, Plano TX 75024, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 850.85 SHERIFF COST: $850.85 SO ANSWERS, June 30,2010 RON R ANDERSON, SHERIFF a -Dp f,~ ~ ~'o . ell ~ 7 7o.5`~y' a ~Sa ~3 {c~ CouniySuite ShenfY. Tei~osoft. Inc. Goldbeck McCafferty & M~Keevet~ BY: Michael T. McKeever Attorney LD. #56129 Suite 5000 -Mellon hldependence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE RANDY M. WILSON (Mortgagor(s) and Record Owner(s)) 23 East Allen Street Mechanicsburg, PA 17055 Defendant(s) No. civil-09-5549 AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by its attorney. Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was tiled the following information concerning the real property located at: 23 East Allen Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): RANDY M. WILSON 23 East Allen Street Mechanicsburg. PA 17055 2. Name and address of Defendant(s) in the judgment: RANDY M. WILSON 23 East Allen Street Mechanicsburg. PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MECHANIC'SBURG BOROUGH OF W STRAWBERRY LtNORTH MARKET ST. C;O David ,1 Spotts 36 West Allen Street Mechanicsburg. Pr1 1755 DOMESTIC RFLA"LIONS OF CUMBERLAND COUNTY PO Boz 320 Carlisle. PA 17013 PA DEPARTMI:N"1 OF PUBLIC WELI=ARF -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O'. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 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 23 East Allen Street Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and coiTect to the best ~m personal la~owledge or information and belief. I understand that false statements herein are made subject to the en ties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 2, 2009 GOLDBECK Mc FER & McKEEVER BY: Michael T cKeever, Esq. Attorney for aintiff '~ civil-09-5549 ,« ~ . GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney LD.#56 ] 29 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. RANDY M. WILSON Mortgagor(s) and Record Owner(s) 23 East Allen Street Mechanicsburg, PA 17055 Defendant(s) of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. civil-09-5549 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WILSON, RANDY M. RANDY M. WILSON 23 East Allen Street Mechanicsburg, PA 17055 Your house at 23 East Allen Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010. at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $100,195.65 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU NIAY BE ABLE TO PKEVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take innnediate action: r civil-09-5549 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, 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 maybe able to stop the sale by tiling a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE 1. If the Sheriff's 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 maybe 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 ti-om 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 tiled 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 tiled. 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 uhilade~hi•~ifed or<='foreclosure' YOU SHOULD TAKE TFIIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT .AFFORD ONE, GO TO OR TELEPHONE THE OFFICL: LISTED BEI.O~~~ TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCLAT[ON 2 Liberty Avenue Carlisle. PA 17013 LEGAL SERVICES INC 8 Irvine Ro~~~ Carlisle. PA 17013 civil-09-5549 717-243-9400 l civil-09-5549 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.~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 ors/consumers/homeowners/real aspx. S). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention a~oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 85124FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL that certain lot of ground situated on the North side of East Allen Street, in the Borough of Mechanicsburg, County of Cumberland Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the building line of said East Allen Street and the line of land now or formerly of Daniel K. Kopenhaver; thence northwardly along the line of the latter land and through and beyond a joint private alley, one huudred thirty-two (132) feet, more or less, to an iron pin at a public alley; thence eastwardly along said alley, twelve and eight hundred seventy-five thousands (12.875) feet to a line of lands now or formerly of James A. Potteiger and Emma F. Potteiger, his wife, thence southwardly along said lands and through the partition wall of a double frame dwelling house, said wall dividing properties known as Nos. 23 and 25 East Allen Street, one hundred thirty-two and fivetenths (132.50) feet, snore or less, to a point on the building line of said East Allen Street; thence westwardly along said bnilding line twelve and eight hundred seventy-five thousands (12.875) feet to the place of BEGINNING. BEING THE SAME PREMISES BY DEED DATED 02/27/2008, GIVEN BY JOHN W. VOGELSONG AND PAULA R. VOGELSONG TO RANDY M. WILSON, MARRIED AND RECORDED 02/29/2008 INSTRUMENT # 200806031. BEING KNOWN AS 23 E ALLEN STREET, MECHANICSBURG PA 17055 TAX PARCEL NO: 18-23-0565-040 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-5549 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/Wa COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff (s) From RANDY M. WILSON (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 $100,195.65 L.L. $.50 Interest from 12/3/09 to Date of Sale per diem at $15.73 -- To be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $223.00 Other Costs Plaintiff Paid Date: 12/4/09 ~S urt .Long, Prothonota (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 92069 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 23 East Allen Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: ~~ ' Real Estate Coordinator L I ~Z d I { 330 b00t 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: April 16, Apri123, and Apri130, 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. ~--- Lis Marie Coyne, E ' or SWORN TO AND SUBSCRIBED before me this 30 da of Aril 2010 ~' Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Pubiic CARLISLE BOROUGH, CUMBERLAND COUNTY My Commlaeion Expires Apr 28, 2011 Writ Fo. ZOO9-b849 Civil BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP vs. Randy M. Wilson Atty: Michael McKeever ALL that certain lot of ground situ- ated on the North aide of East Allen Street, in the Borough of Mechanics- burg, County of Cumberland Com- monwealth of Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the building line of said East Allen Street and the line of land now or formerly of Daniel K. Kopenhaver; thence north- wardly along the line of the latter land and through and beyond a joint private alley, one huudredthirty-two (132) feet, more or less, to an iron pin at a public alley; thence eastwardly along said alley, twelve and eight hundred seventy-five thousands (12.875) feet to a line of lands now or formerly of James A. Potteiger and Emma F. Potteiger, his wife, thence southwardly along said lands and through the partition wall of a double frame dwelling house, said wall divid- ingproperties known as Nos. 23 and 25 East Allen Street, one hundred thirty-two and fivetenths (132.50) feet, more or less, to a point on the building line of said East Allen Street; thence westwardly along said bnild- ing line twelve and eight hundred seventy-five thousands (12.875) feet to the place of BEGINNING. BEING the same premises by deed dated 02/ 27/ 2008, given by John W. Vogelsong and Paula R. Vogelsong to Randy M. Wilson, married and recorded 02/29/2008 Instrument # 200806031. BEING KNOWN AS 23 E. ALLEN STREET, MECHANICSBURG PA 17055. TAX PARCEL NO: 18-23-0565- 040. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which BAC HOME LOANS SERV L P is the grantee the same having been sold to said grantee on the 2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on the 4TH day of DEC, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 5549, at the suit of BAC HOME LOANS SERV L P against RANDY M WILSON is duly recorded as Instrument Number 201018385. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~` A.D. ~ ~ b day of of Deeds ~~n E~"resd ~' Cad~aie,, PA ~daYofJen. 2at4 The Patriot-News Co. 020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~e~latriot News NOw you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/16/10 04/23/10 ,_,__ ~ 04/30/10 .~ ~~~~ ,_ Sworn t~ subscribed before m~th~ 18 ~a/y of May, 2010 A.D. ~/ Notary Public COMMONWEALTH OF PENNSYLVANIA NotaAal Seal Sherrie L. Kisner, Notary Publk Lower Paxton Twp., Dauphin County My Comrt ExW-es Nov. 26, 2011 Member, PennsyNanla Association of Notaries NVrK No. 2009.9549 Clvll Term 8~`4C Honig Loans Servicing, LP FYIC/A Gountt'ywldb Home Loans „ SerWcing, LP Vs. Rartidy M. Willson Arty: MlChaei McKeever ALL THAT C$RTAIIV lot of ground situated on t>x North side of EastAlleo Stre~; in the Borough of` Mechanieshurg, Cooniy of Cumberland Comrtwowealth of'Pennsylvania, bounded and described as foltotvs: , BRGI1dNfNG at ao iron pia on the building line of said East Al1in Street and the line of land now , t; or formeiiy of Deaiel I{. Kopenhaver; thence _, nadtwatdty a~itg the line of the latter land and ~ - ttarortgh aed beyond a joint private alley, one ;, •, Mpiidrod thf~,V-ttvo>(132) feu, more. or less, to an n , iratpinat apub~ alley; thencceastwardly along ,; , said"alley; twelve and eight hundred seventy-five ~ - thoueands (12.>i75} feu to a line of lands now ,,;,, or formerly: of James A. Potteiger and Emma F. ; Potteiger, his wife; thence southwatdly along ~ . said lands artd ttirbug6 the partition wall of a .,:~s dopbk frame Mvelling house, said wall dividing ., properties ksbwn as Nos. 23 and 25 East Alen St{eat,.4na;btmdred thirty-two and fivetenths ,-. (192.50} fast, mole ar less,. to a point on the bua"~m' g lue Of 88id East AIleA Street;. thence we~wartfly along ~ banding line twelve and eight hundibd seventy-five thousands (12.875) . feu to the place of BEGINNING. BEING THE SAME PREMISES BY DEED DATBD ty1/27i2008, GIVEN BY JOHN W. VOGEG90NG AND PAULA R, VOGELSONG TO RANDY M. WII.SON, MARRIED AND RECORDED 02!3912008 INSTRUMENT # 200816(131. BEAVG Y{N4WAi AS 23 E ALLEN STREET, M~HANICl48URG PA 17035 . TAX PARCEL N0:18-2-0565.040