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HomeMy WebLinkAbout09-5732GOLDBECK 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.(,OLDBECKLAW.COM ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plainti f vs. SHARON L. HOOVER Mortgagor and Record Owner 323 Manchester Road Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 04 - 573a1 bil CIVIL ACTI(J?? MpRTf?A( T??Ik ROAMLOOUff 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 RA7.ON 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 ELIGIBLI, 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 http://www. hp fa.orjz/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.Dhiladelphiafed.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 86238FC. 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, LF 1KA COUNTRYWIDE HOME LOANS SERVICING LP, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendant is SHARON L. HOOVER, 323 Manchester Road, Camp Hill, PA 17011, who is the mortgagor and record owner of the mortgaged premises hereinafter described. On April 25, 2003 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 HOME LOANS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1808 Page 1789. 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 March 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 ..................................................................................$100,870.81 Interest from 02/01/2009 through 07/31/2009 at 6.0000% .......................$3,000.97 Per Diem interest rate at $16.58 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$5,043.54 Late Charges from 03/01/2009 to 07/31/2009 .............................................. $177.45 Monthly late charge amount at $35.49 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $226.98 $109,992.77 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. Plaintiff is not seeking a judgment of personal liability (or an "in persona m" 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 ha.s 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 $109,992.77, together with interest at the rate of $16.58, 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. 4W L( - i\?"o GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: Michael T. McKeever, Esquire PA I.D. #56129 #86238FC SHARON L. HOOVER 323 Manchester Road Camp Hill, PA 17011 Prepared By and Return To: Beth Grades GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 GMM File Number: 86238FC Parcel ID#: 13-23-0545-373 ASSIGNMENT OF MORTGAGE -MMT-GA6E-EIJECTR0NK REGISTRA-TIO N 8YS`PEMS;-INC:-ACTING- -- - -- -- SOLELY AS A NOMINEE FOR 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 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP. BAC HOME 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 SHARON L. HOOVER , Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR COUNTRYWIDE HOME LOANS, INC. Bearing date of. April 25, 2003; Amount Secured: 5110,129.00; Recorded on April 28,2003; in Book 1808 Page 1789; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 323 Manchester Road, Camp Hill, PA 17011 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 2009. -AgAmak _, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR COUNTRYWIDE HOME LOANS, INC. (Affix Corporate Seal) _ %t./c (SEAL) Name: Mom Rh ft* - President Title: - -- -- - - --- - - Name:Aaron Fo -Asst. Vice President Title. ss: TOM STATE OF, COUNTY OF Tang it ) BE IT REMEMBERED, that on this Z day of , 2009, before me, the subscriber, a Notary Public personally appeared Rhoena Rice - Vice President Left nt MORTGAGE R NI O S MC. A MG SOLELY AS A M EE FOR COUNTRYWIDE HOME LOANS. INC. 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. Notary ublic My com fission ex it =?,k'"*?", KATHIE RACHELLE WIC.::•4RRF hereby certify the address of the Assignee is: (4otary Pubic, state ot r a: 7105 Corporate Drive, PTX C-35, Plano,TX 75024. ,o%- Commission Expires zs;,. ;<itt tune 08, 2011 Case #: 86238FC EyhibitA PMParad by: MICHELLE RADNOA COUNTRYWIDE HOME LOANS, INC. Stanch 0: 217 HAMPDEN CTR 4830 CARLISLE PIKE DATE: 04/25/2003 MECHANICSBURG, PA 17050 CASE #: PA4417202999703 Phone: (717)730-6670 DOG ID #: 0003131631204003 Br Fax No.: (717) 730-3824 BORROWER: SHARON L. HOOVER PROPERTY ADDRESS: 323 MANCHESTER ROAD CAMP HILL, PA 17011 LEGAL DESCRIPTION EXHIBIT A ALL THAT CERTAIN tract of land situate in the Township of Lower Alien, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a stake on the southerly line of Manchester Road, 118.49 feet west of the southeast comer of Manchester and Warwick Roads at the westerly line of Lot No. 17, Block "R" on the hereinafter mentioned Plan; thence on a line perpend'War to Manchester Road along the latter lot, South 09 degrees 57 minutes West, 105 feet to a stake on line of Lot No. 18, Block "R"; thence on a line parallel to Manchester Road along the latter lot, North 80 degrees 03 minutes West, 60 feet to a point at line of Lot No. 15, Block "R"; thence along the latter lot on a line perpendicular to Manchester Road, North 09 degrees 57 minutes East, 105 feet to the southerly One of Manchester Road; thence along Manchester Road, South 80 degrees 03 minutes East, 60 Feet to a point, the place of BEGINNING. BEING Lot No. 16, Block "R" on the Plan of Lots of a portion of Highland Park, recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 24. HAVING THEREON ERECTED a single frame dwelling house known as 323 Manchester Road, Highland Park, Camp Hill, Pennsylvania, as surveyed by D. P. Raffensperger. FHwNAACOW 0 Legal DasaWan Exhb4 A 1C4"XX(11101)(d) ' 2 3 9 9 1 0 3 1 9 1 0 33 1 2 0 0 0 0 0 1 0 0 4 N y f ! 8 0bPGb 17 E..x.hidit B Bank ofAmerica --!W- home Loans PO Box 9048 Ternecula, CA 92589-9048 Send Payments To: PC Box 660694 Dallas, TX 75266-0694 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley. CA 93065 7113 8257 1473 3041 6591 Sharon L Hoover 323 MANCHESTER RD CAMP HILL, PA 17011-6123 2009050E-7 BLQPA2 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1128-v25 Bank of America '?i?,, Home Loans P.O. Box 660694 Send Payments to: Dallas, TX 75266-0694 P.O. Box 660694 Dallas, TX 75266-0694 May 6, 2009 Certified Mail 7113 8257 1473 3041 6591 Return Receipt Requested Sharon L Hoover Account No.: 31316312 323 MANCHESTER RD CAMP HILL. PA 17011-6123 Property Address: 323 Manchester Road Camp Hill, PA FHANA Case #: 44 1 720299970 3 NOTICE OF INTENTION TO FORECLOSE BAC: Home Loans Servicing, LP (hereinafter "BAC Home Loans Servicing, LP") 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 the date of this letter is as follows: Monthly Charaes: 0 3/0 1 12 0 09 $1,774.52 05/01 /2009 $872.33 Late Charges: 03/01/2009 $70 98 Other Charaes: Uncollected Late Charges: $0.00 Uncollected Costs: $15.00 Partial Payment Balance: ($0.00) TOTAL DUE: $2,732.83 You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter. To cure the default, BAC Home Loans Servicing, LP must receive the amount of $2,732.83, 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 BAC Home Loans Servicing, LP at P.O. Box 660694, Dallas, TX 75266-0694. If any check (or other payment) is returned to LIS 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, BAC Home Loans Servicing, LP 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 attomey'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, BAC Home Loans Servicing, LP may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (1) observe the physical condition of your property, (ii) verify that the property is occupied and/or (Iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Please write your account number on all checks and correspondence. We may charge you a fee for any payment returned or rejected by yourfinancial institution, subject 1o applicable law. SLQPA2 8338/10793 06/03/2008 PaymsntlnsWethnr Account Number: 31316312 Sharon L Hoover Balance Due for charges listed above: $2,732.63 as of May 6, 2009. Make your check payable to BAC Home Loans Servicing, LP 323 Manchester Road Please update e-mail information on the roverse Side of this coupon. . Don't send cash Camp Hill, PA e Please include coupon with your qd?y payment BLQPA2 ??F?' For all full month payment periods, Interest is calculated on a monthly basis. Accordingly, interest for all full months, including February, is calculated as 301360 of annual interest, irrespective of the actual number of days in the month. For partth monttrs. i 365 d y ew. ated dally on the bass of a 365 day year. ?7tld4'Orrral BAC Homo Loans Servicing, LP aLYO1 PO BOX 660694 Dallas, TX 75266-0694 - rural 031316312300000273283000273283 1: 5869900 5ED:0 3 L 3 L6 3 L 21i¦ Ih.,I,I,L.,1,I,IL.,IL.IL,..II,rI,L.Jr.ll.l,.,l..l..l.lll.rr 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. 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: 1-800-669-4578. 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 Sheriff's sale, a lawsuit could be started to evict you. BAG: Home Loans Servicing, LP wants you to be aware of various options that may be available to you through BAC Home Loans Servicing. LP 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 BAG Home Loans Servicing, LP. Our basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least 1/2 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 BAG Home Loans Servicing, LP 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 cf these foreclosure alternatives with BAC Home Loans Servicing, LP, you must contact us immediately. If you request assistance, BAC Home Loans Servicing, LP will need to evaluate whether that assistance will be extended to you. In the meantime, BAG: Home Loans Servicing, LP 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 June 10, 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 1-800-669-4578. BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Account Number: 31316312 E-mail use: Providing your e-mail address below will allow us to send you information on your account. Sharon L Hoover E-mail address: How we post your payments: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (i) to outstanding monthly payments of principal and interest, (ii) escrow deficiencies, (iii) late charges and other amounts you owe in connection with your ban and (iv) to reduce the outstanding principal balance of your ben. Please specify if you want an additional amount applied to future payments, rather than principal reduction. Postdated checks: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the date written on the check as a condition of a repayment plan. ALED OF THE Pr- '?' lr e r:T1f:1 i 2uC ; a 19 f, # E ! ?o *'79 .5 0 Pry ATH CO -iqv7ooq V-r*aaggII Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ,'Sow clutib"fi,4 # OFFi',E OF THE $-ERIFF FLED- OF THE, r .?RRY Edward L Schorpp Solicitor 2009 AUG 28 P1112:51 CL`Iv+4' BAC Home Loans Servicing, LP I vs. Case Number Sharon L. Hoover 2009-5732 SHERIFF'S RETURN OF SERVICE 08/24/2009 06:51 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 24, 2009 at 1851 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sharon L. Hoover, by making known unto herself personally, at 323 Manchester Road Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 August 25, 2009 SO ANS RS R THOMAS KLINE, SHERIFF By Depu y Sheriff GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. SHARON L. HOOVER Mortgagor(s) and Record Owner(s) 323 Manchester Road Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 09-5732 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to Plaintiffs Complaint filed on August 19, 2009 in the above captioned matter. GOLDBECK McCAFFERTY & McKEEVER BY:`?? J - 1-? ,u tAI-? Michael T. McKeever Attorney for Plaintiff y F GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. SHARON L. HOOVER Mortgagor(s) and Record Owner(s) 323 Manchester Road Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 09-5732 CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification to Plaintiff's Complaint was served on Defendant(s) via first class mail on September 16, 2009 as follows: SHARON L. HOOVER 323 Manchester Road Camp Hill, PA 17011 GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever Attorney for Plaintiff ? :.h VERIFICATION I, Tiaquanda Tumer, Assistait Secretary , 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: AUG 2 0 2009 Assistant Secretary #86238FC - SHARON L. HOOVER 323 Manchester Road Camp Hill, PA 17011 R F c ..ii 1 c OF THE DF`, 2009 SEP 18 Ph 2.81 In the Court of Common Pleas of Cumberland County BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. SHARON L. HOOVER (Mortgagor(s) and Record Owner(s)) 323 Manchester Road Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-5732 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against SHARON L. HOOVER by default for want of an Answer. Assess damages as follows: Debt Interest from 10/09/2009 to Date of Sale per diem at $16.58 Total (Assessment of Damages attached) $111,697.22 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKeeve Attorney for Plaintiff I.D. #56129 AND NOW t ,60F , Judgment is entered in favor of BAC HOME LOANS SERVICING, LP FKA CO YWIDE HOME ANSS SERVICING LP and against SH ON L. HOOVER by default for want of an Answer and damages assessed in the sum o 111,697.22 as er the ab e ertification. S Pr honotary Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. SHARON L. HOOVER (Mortgagors and Record Owner(s)) 323 Manchester Road Camp Hill, PA 17011 No. 09-5732 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 CurtLong Prothonotary By. P1eP'rxt9- VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, SHARON L. HOOVER, is about unknown years of age, that Defendant's last known residence is 323 Manchester Road Camp Hill, PA 17011, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: /dyOv ? 86238FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: September 15, 2009 TO: SHARON L. HOOVER HOOVER, SHARON L. 323 Manchester Road Camp Hill, PA 17011 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. SHARON L. HOOVER (Mortgagor(s) and Record Owner(s)) 323 Manchester Road Camp Hill, PA 17011 TO: SHARON L. HOOVER 323 Manchester Road Camp Hill, PA 17011 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-5732 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 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, 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 SHARON L. HOOVER (Mortgagor(s) and Record owner(s)) 323 Manchester Road Camp Hill, PA 17011 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 09-5732 ORDER FOR JUDGMENT Please enter Judgment in favor of BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, and against SHARON L. HOOVER for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $111,697.22. chael T. Mc ver Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are SHARON L. HOOVER, 323 Manchester Road Camp Hill, PA 17011; GOLDBECK MCCAFFE TY VEVER BY: Michael T. McKeever Attorney for Plaintiff 41 ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $100,870.81 Interest from 02/01/2009 through $4,144.99 10/08/2009 Reasonable Attorney's Fee $5,043.54 Late Charges $283.92 Costs of Suit and Title Search $900.00 Escrow Payments Due 2 X $226.98 $453.96 $111,697.22 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this Q4 "may of 0&. , 2009 damages are assessed as above. TH' '70- _.0q,yOTAPY 2004 OCT 12 ABM 11: 12 a CK# ,SZb7/S ? 2 ar71.? t-f- nulat L( PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. SHARON L. HOOVER Mortgagor(s) and Record Owner(s) 323 Manchester Road Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-5732 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 10/09/2009 to Date of Sale per diem at $16.58 (Costs to be added) $111,697.22 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff a d C7 w a a> o z? Q1 ? O O ? yO Fy '7QI' o H a O W w A H 0? Fr ? Z Q 7 0 U z O H ° j o o "pr- W ° o o O a b U -•---+ Fry cd c) U M U x CC Cl) W o a' a N cl. .emu ? a: LU V 0. _ CJ v, : N C) X00 00 I O J -?oo?RS o s. U U V O h ?U U ? O GJ N N ??v]dM 2 p. r V N N ,?-i O ? N „o a ?o o a? V M N 1 4 c? ? A" 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, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. SHARON L. HOOVER (Mortgagor(s) and Record Owner(s)) 323 Manchester Road Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-5732 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 filed the following information concerning the real property located at: 323 Manchester Road Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): SHARON L. HOOVER 323 Manchester Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: SHARON L. HOOVER 323 Manchester Road Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: ATLANTIC CREDIT & FINANCE INC. C/O David J. Apothaker 520 Fellowship Road # C306 Mt Laurel, NJ 08054 FIA CARD SERVICES, N.A. 275 South Valencia Avenue Brea, CA 92823 FIA CARD SERVICES, N.A. f C/O Frederic I. Weinbera 1001 East Hector Street, Suite 220 Conshohocken, PA 19428 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 4. Name and address of the last recorded holder of every mortgage of record: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR EQUITY ONE, INC. D/B/A POPULAR FINANCIAL SERVICES 301 Lippincott Drive Marlton, NJ 08053 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR EQUITY ONE, INC. D/B/A POPULAR FINANCIAL SERVICES 3300 SW 34th Avenue Suite 101 Ocala, FL 34474 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR EQUITY ONE, INC. D/B/A POPULAR FINANCIAL SERVICES P.O. Box 2026 Flint, MI 48501 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 323 Manchester Road Camp Hill, PA 17011 (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: October 8, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff r FILED?Jrrl r- 'HE 'y 0 .r ')TAP 12 2m OCI 12 Am 11 09-5732 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, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. SHARON L. HOOVER Mortgagor(s) and Record Owner(s) 323 Manchester Road Camp Hill, PA 17011 Defendant(s' , Term No. 09-5732 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: HOOVER, SHARON L. SHARON L. HOOVER 323 Manchester Road Camp Hill, PA 17011 Your house at 323 Manchester Road, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Tuesday, March 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $111,697.22 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 41 09-5732 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 may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 . I- Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 09-5732 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 86238FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. FILED--O FlCf OF ?Fr P; ?T? e0l'AHY 2009 OCT i 2 AM 11: 12 ITY ALL THAT CERTAIN tract of ianxd sittate In dw Tout of Long Allen, County of c mbwbnd. mrnranwoalth of Penn. more particularly bounded and described as favowe, to wit WGINMNGat a stakeon am 9maherly lineof NianchaeletirRo9d,114149 fleetwest of thesoutheast corner of Mandyl+eler " Warwick Rands at #0 tee line of LA)t No. 17, f]lodc "R" on Nw hweirWiernner7tlonedPlan; thenoeonaline prrperdWartoMwtd rRoWalongtheWerK Soulh f!0 d ee ff mI s West ice fleet oo s dake online of Lof fun, iS, Bl©dc "R,,. thentw on a Una parallel to Manrhesler Rid abrV the letter let, Nor* 80 degrsas W a***S West, 8D(eet to a Polht atfineof La No.15, Blcwf "Ft';?Btrtllgtha letl iott?n a Jk pe rldiCUlafttt l4MtfCllrw r Rnad, North 09 degrees 57 minutes Ei tst 106 taet to the southerly One ofiliencheeter• ice; #once alang N%nahea r Road, Sotrlh 80 degreee 03 minutes East, 60 feet to a paint. W* pilace of E INNIN . aMNO Lot No, 1S, Skek "fit" on the Mart of LA* of a porgy of Highlaw Park, recorded In the CurrhMand County per's Office In Plan Book F, Paq& 3#. HAVING THEREON ERECTED a single firannct *AW1hg house known as 323 Ianchester Road, Highlaind Park, "'t,&m Hill, Ponns*aWa, as surveyerd by 0. P. Raffermperger. TAX PARCEL #123-23-0545-373 BEING KNOWN AS: 323 Manchester Road, Camp Hill, PA 17011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5732 Civil 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 SHARON L. HOOVER (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 $111,697.22 L.L. $.50 Interest from 10/9/09 to Date of Sale per diem at $16.58 -- To be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $160.50 Other Costs Plaintiff Paid Date: 10/12/09 1- Curtis R. Lo , Prothono (Seal) Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129