Loading...
HomeMy WebLinkAbout09-5753GO.,DBECK 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RFI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL Mortgagors and Record Owners 302 South Enola Drive Enola, PA 17025 Defendants ACTION OF MORTGAGE FORECLOSURE Term No. 09 - b Z53 l Vi `em CIVIL ACTION- MO RTGAGr tr?- NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LISTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www. hp fa.org/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Horne Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at 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 85874FC. 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendants are BONNIE G. CAMPBELL, 302 South Enola Drive, Enola, PA 17025 and BRADLEY R. CAMPBELL, 302 South Enola Drive, Enola, PA 17025, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On June 28, 2000 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE COMPANY dba ACCUBANC MORTGAGE, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1625 Page 232. The mortgage has been assigned to: WACHOVIA BANK NA FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOANS TRUST 2005-RF1 by assignment of Mortgage June 30, 2008 as Instrument# 200822040. 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 ....................................................................................$84,488.48 Interest from 02/01/2009 through 07/24/2009 at 7.0000% .......................$2,818.79 Per Diem interest rate at $16.20 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,224.42 Late Charges from 03/01/2009 to 07/24/2009 .............................................$163.79 Monthly late charge amount at $32.76 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $189.85 $92,595.48 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8, Plaintiff is not seeking a judgment of personal liability (or an "in personam.1 judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose has been sent to Defendants 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 $92,595.48, together with interest at the rate of $16.20, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By: (?CX? GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 1Kathy Repka as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: (V r - 09 Kathy Repka?Asst. Secretary #85874FC - BONNIE G. CAMPBELL and BRADLEY R. CAMPBELL 302 South Enola Drive Enola, PA 17025 Eythi6itA May 28 2008 4s18PM HP LSSERJET 3330 p.17 ALL THAT CERTAIN piece, parcel or tract of land situate in Fast Peaasboro Township, Cumberland Cauoty, Pannsylvanla, sittate on the Easterly side of South Eaola Drive, described #k *=rda= wi a survey dated Juae 15, 1988, bearing drawing No. CC-23, prepared by William A. Burdwfmil Associates, a copy of which is attacbed hereto, wtiidt pcugises are bounded and d=05ed as follows, to wit: BEGUWING on an iron pin on the Easterly right-of-way line of South Ennis Drive at line of lands now or tbrmm of Rase C. and Fraoces T. Blosser; thence along South lritoht DXIVe North thirty-three (33) degree Oft-sight (5S) minutes Went forty-ulna (49) and t dM4bree (33) bandredit-feet to a drill hole suit line of lands now ar formerly of Willis R. Miller; thence aloe= ==North sixty-0ne (6i)'degtees seven (07) mhoms three (03) amooda East one hundred forty-six and twetq-elg tt hundredths (146.78) fed to au iron pia 00 the Weadetly Side Of a 16 foot W de alley; lltenCe alatl$ same Santh thirty (33) degrw fiUM (15) minutes zero (00) seconds Lust WW (50 feet to an iron pipe at Hue land aforesaid; thence along same Socalt Sixty-one (61) 4egrees twatty-four (24) rnlmam zero (00) seconda West am hundred Potty-flvo and seventy-two haadralths (145.72) *et to the iron pin at the point and place of BEGINNING. CONTAINING 0.16586 acres and Laving thereon erected a one and one-half frame dwelling house which is kwwn and =mbemd ae 302 South Enoaa Drive. Eaala, Pennsylvania 17075. TAX PARCEL NUMBER 13-1291-308 Exhibit (B Bank of America }tome Loans P.O. Box 660694 Send Payments to: Dallas, TX 75266-0694 P.O. Box 660694 Dallas, TX 75266-0694 May 15, 2009 Certified Mail 7113 8257 1473 3288 2967 Return Receipt Requested Bonnie G Campbell Account No.: 74148889 302 S ENOLA DR ENOLA, PA 17025-2809 Property Address: 302 S Enola Dr Enola, PA FHA/VA Case #: 4416302912703 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 Charges: 03/01/2009 $1,637.94 05101/2009 $812.03 Late Charges: 03/01/2009 $65.52 Other Charges: Uncollected Late Charges: $0.00 Uncollected Costs: $45.00 Partial Payment Balance: ($90,87) TOTAL DUE: $2,469.62 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 $2,469.62, 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 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, 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 (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Please write your accotmt number on all checks and correspondence. We may charge you a fee for any payment returned or rejected by your financial instllution, subject to applicable law. BLQPA2 63M10793 061032008 Paynwntlnshwixim: Account Number: 741488894 Bonnie G Campbell Balance Due for charges listed above: $2,469.62 as of May 15, 2009. • Make your check payable to BAC Home Loans Servicing, LP 302 S Enola Dr Please update e-mail information on the reverse side of this coupon. • Don't send cash Enola PA • Please include coupon with your , Addibona/ payment BLQPA2 For all full month payment pen ods, interest Ad--I is calculated on a monthly basis. Accordingly, interest for all full months, BAC Home Loans Servicing, LP including February, is calculated as PO BOX 660694 301360 of annual interest, irrespective of Dallas TX 75266-0694 Cneck the actual number of days in the month- , IL LLL Ll ll ll ll I Tote/ For paNal months, merest is calcuated .. .k . .,, .. n.. , .,, . , L,I I I IIJk..L,L.l.l ll,..l BM dally on the basis of n 365 day yea. 074148889400000246962000246962 1: 5869900 581:0 74 LL.138B911' 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. BAC 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 BAC Home Loans Servicing, LP. Our basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least 1/z 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 BAC 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 of 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, BAC 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 19, 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: 74148889 E-mail use: Providing your e-mail address below will allow us to send you information on your account. Bonnie G Campbell E-mail address: Hoar 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 loan. 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 ban counselor agrees to honor the date written on the check as a condition of a repayment plan. Bank of America '0 Horne Loans P.O. Box 660694 Send Payments to: Dallas, TX 75266-0694 P.O. Box 660694 Dallas, TX 75266-0694 May 15, 2009 Bradley R Campbell Account No.: 74148889 302 S ENOLA DR ENOLA, PA 17025-2809 Property Address: 302 S Enola Dr Enola, PA FHANA Case #: 4416302912703 NOTICE OF INTENTION TO FORECLOSE BAG 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 Charges: 03/01/2009 $1,637.94 05/0112009 $812.03 Late Charges: 03/01!2009 $65.52 Other Charges: Uncollected Late Charges: $0.00 Uncollected Costs: $45.00 Partial Payment Balance: ($90.87) TOTAL DUE: $2,469.62 You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter. To cure the default, BAG Home Loans Servicing, LP must receive the amount of $2,469.62, 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 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, BAG 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 attorney's fees and costs incurred in connection with the foreclosure sale (and any other requirements Linder 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 acceurt number on all checks and correspondence. We may charge you a fee for any payment returned or rejected by yourfinancial ins litution, subjecl to applicable law. BLQPA2 8338/10793 061032008 Paymantlnstructbm: Account Number: 74148889-4 Bradley R Campbell Balance Due for charges listed above: $2,469.62 as of May 15, 2009. . Make your check payable to BAC Home Loans Servicing, LP 302S Enola Dr Pleese 10datB e-mail information on the raverBB d of this moron. . Don't send cash Enola, PA e Please include coupon with your payment BLOPA2 Forall full month paymerA periods, interest .9Udiba?a is calculated on a morthy basis. Accordirtgy, interest for all full months, BAC Home Loans Servicing, LP ?COiN including February, is calculated as PO BOX 660694 301360 of annual interest, irrespective of Dallas, TX 75266-0694 ck the actual number of days in the monb_ IlrrrLl.L..L1.ILrrlL.llrrrrll LL L ILL l l Ll I rota lL For path months, interest calculated .. ,. , rr rr rr „ daily on the basis of a 365 day y yea-. 074148889400000246962000246962 1: 58 6 9 900 580:0 7 L. I L.B66 9110 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. BAC 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'/. 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 BAC 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 BAG Home Loans Servicing, LP, you must contact us immediately. If you request assistance, BAG Home Loans Servicing, LP will need to evaluate whether that assistance will be extended to you. In the meantime, BAC 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 19, 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: 74148889 E-mail use: Providing your e-mail address below will allow us to send you information on your account. Bradley R Campbell E-mail address: How we post your pa mrenils. 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 In 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 ban. Please specify if you want an additional amount applied to future payments, rather than principal reduction. Postdated chocks: Postdated checks will be processed on the date received unless a ban counselor agrees to honor the date written on the check as a condition of a repayment plan. Q 1419 AUil') 20 EiII I I : 2 *19-50 PO All--( Ck`? ,3?39q 4 e3* aaq 5of Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy . ,1 Jody S Smith Cavil Process Sergeant OFFICE OF THE S nERIFF Edward L Schorpp Solicitor " 0 'C J CC"' Nfr) ir' R,-PPS,gy 20P4 ig UG 28 P Wachovia Bank, NA vs. Bonnie G. Campbell Case Number 2009-5753 SHERIFF'S RETURN OF SERVICE 08/24/2009 05:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on August 24, 2009 at 1730 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bonnie G. Campbell, by making known unto herself personally, at 302 South Enola Drive Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. 08/24/2009 05:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on August 24, 2009 at 1730 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bradley R. Campbell, by making known unto Bonnie Campbell, wife of defendant at 302 South Enola Drive Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.50 August 25, 2009 SO ANSWERS R THOMAS KLINE, SHERIFF BY De WSherif In the Court of Common Pleas of Cumberland County WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL (Mortgagor(s) and Record Owner(s)) 302 South Enola Drive Enola, PA 17025 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-5753 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 BONNIE G. CAMPBELL and BRADLEY R. CAMPBELL by default for want of an Answer. Assess damages as follows: Debt Interest from 10/10/2009 to Date of Sale per diem at $16.20 Total (Assessment of Damages attached) $94,320.86 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.Afckeever Attorney for Plaintiff I.D. #56129 AND NOW Q0 /5 9 , Judgment is entered in favor of WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RFI and against BONNIE G. CAMPBELL and BRADLEY R. CAMPBELL by default for want of an Answer and damages assessed in the sum of $94,320.86 as per the above certification. Isl d4A4,4 • LxR P othonotary 4310 85874FC 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. TO: BONNIE G. CAMPBELL CAMPBELL, BONNIE G. 302 South Enola Drive Enola, PA 17025 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL (Mortgagor(s) and Record Owner(s)) 302 South Enola Drive Enola, PA 17025 Defendant(s) TO: BONNIE G. CAMPBELL 302 South Enola Drive Enola, PA 17025 DATE OF THIS NOTICE: September 15, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-5753 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 85874FC 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: BRADLEY R. CAMPBELL CAMPBELL, BRADLEY R. 302 South Enola Drive Enola, PA 17025 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL (Mortgagor(s) and Record Owner(s)) 302 South Enola Drive Enola, PA 17025 TO: BRADLEY R. CAMPBELL 302 South Enola Drive Enola, PA 17025 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-5753 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, BONNIE G. CAMPBELL, is about unknown years of age, that Defendant's last known residence is 302 South Enola Drive Enola, PA 17025, 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: // r 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, BRADLEY R. CAMPBELL, is about unknown years of age, that Defendant's last known residence is 302 South Enola Drive Enola, PA 17025, 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. e?? Date: 64 ?Gj 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005- RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL (Mortgagor(s) and Record owner(s)) 302 South Enola Drive Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-5753 ORDER FOR JUDGMENT Please enter Judgment in favor of WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RFI, and against BONNIE G. CAMPBELL and BRADLEY R. CAMPBELL 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 $94,320.86. Z? --- Michael 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 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 BONNIE G. CAMPBELL, 302 South Enola Drive Enola, PA 17025 and BRADLEY R. CAMPBELL, 302 South Enola Drive Enola, PA 17025; GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 02/01/2009 through 10/09/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 2 X $189.85 $84,488.48 $4,066.19 $4,224.42 $262.07 $900.00 $379.70 $94,320.86 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 15-IT111 day of L1.10- f 2009 damages are assessed as above. o Prothy FILEL)?l -T 2009 OCT 15 Aid 8: 23, CUFLM'::r a'; ?' ?? ` Nlly f ' lk?SYCVOA' 44-oo PD a-rM co gwobs K" dea 0(04 Norhee I?lOulec? Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RFI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff No. 09-5753 vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL (Mortgagors and Record Owner(s)) 302 South Enola Drive Enola, PA 17025 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. Curt Long ProthonotLti! By: S & &' wA b Deputy 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 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005- RF1 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 BONNIE G. CAMPBELL BRADLEY R. CAMPBELL Mortgagor(s) and Record Owner(s) 302 South Enola Drive Enola, PA 17025 Defendant(s) No. 09-5753 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 10/10/2009 to Date of Sale per diem at $16.20 $94,320.86 (Costs to be added) GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff 14 N uj ¢ C? 0 m d? Ln - = F-- Z j ? Q i U N ?Wz x o ?,o zoF- Q W Ho"0 P, UQOo U O ? x ? H ¢? w M? ? a??f=+ ?UUz H°O ?' H?4¢ z ° z wH ? V ?GH?C7 ?O¢C¢7 F' Q? z > W ?Z 44 U x w1:4 ¢ Q 4 Q Q Co a a v Q3 0-?' A 0 00 0 ki in o ?? 8 00 0(0 , 4 C: 0 -7: in r V Lij z o .. a V W W u ? i a1 .a 0 • ? W a ,, ,?, Pr p O L U cjW moo' IN O N w fd OK1 O W o a N N ??Urr !-1 U O ¢ > U a? Eli U ? I. O U w 4 k a u a? v O ? N y o p., ? o b ° ALL THAT CERTAIN piece, parcel or tract of land situate in East Pennaboro Township, Cumberland County„ Pennsyvlania, situate on the easterly side of South Enola drive, described in accordance with a survey dated June 15" 1988, being drawing No. CC-23 prepared by William A. Burch and Associates, a copy of which is attached hereto, which premises are bounded and described as follows" to wit: BEGINNING on an iron pin on the easterly right-of-way line of South Enola Drive at line of lands now or formerly of Ross C_ and Frances T. Blosser, thence along South Enola Drive Worth thirty-three degrees Fifty- eight minutes West forty-nine and thirty-three hundredths feet (N. 33° 58`W 49.33") to a drift hole set at line of lands now or formerly of Willis R_ Miller; thence along same North sixty-one degrees seven minutes three seconds East one hundred forty-six and twenty-eight hundredths feet (N_ 61° TY E_ 148.28') to an iron pin on the westerly side of a 16 foot wide alley; thence along same South thirty-three degrees, fifteen minutes zero seconds East fifty feet (S. 33° 15' 0" E_50) to an iron pipe at line of land aforesaid;. thence along same South sixty-one degrees twenty-four minutes zero seconds West one hundred forty-five and seventy-two hundredths feet (S.61° 24"0" .°145.72) to the iron pin set the paint and place of BEGINNING. CONTAINING 0.16586 acres and having thereonerected one and one-half frame dwelling house which is know and numbered as 302 South Enola Drive, Pennsylvania 17025_ BEING KNOWN AS: 302 S Enola Dr. Enola, PA 17205 TAX PARCEL #09-15-1291-308 Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL Mortgagor(s) and Record Owner(s) 302 South Enola Drive Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) NO. 09-5753 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Michael T. McKeever Attorney for plaintiff FILED-041CE OF THE PRO7 j,"')NOTARY 2009 OCT 15 AM 8: 24 CUMBE . , Iu ?OUNTY PENNSYLVANIA J• 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005- RF 1 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL (Mortgagor(s) and Record Owner(s)) 302 South Enola Drive Enola, PA 17025 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-5753 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1, 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: 302 South Enola Drive Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): BONNIE G. CAMPBELL 302 South Enola Drive Enola, PA 17025 BRADLEY R. CAMPBELL 302 South Enola Drive Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: BONNIE G. CAMPBELL 302 South Enola Drive Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE BRADLEY R. CAMPBELL 302 South Enola Drive Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 3300 South-West 34th Avenue Suite 101 Ocala, FL 34474 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. C/O Frank Federman 8327 Cedar Road Elkins Park, PA 19027 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: WACHOVIA BANK NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOANS TRUST 2005-RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 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 302 South Enola Drive Enola, PA 17025 (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 unswom falsification to authorities. DATED: October 13, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff r F LED--MCIE CF THEN 143©T N ?TARY 2009 OCT 15 AM 8: 24 CUMB Fi 44.:; ? UUNTY PENNSYLVANIA 09-5753 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL Mortgagor(s) and Record Owner(s) 302 South Enola Drive Enola, PA 17025 Defendant(s; Term No. 09-5753 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: CAMPBELL, BONNIE G. BONNIE G. CAMPBELL 302 South Enola Drive Enola, PA 17025 Your house at 302 South Enola Drive, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $94,320.86 obtained by WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 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: r 09-5753 1. The sale will be cancelled if you pay to WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 09-5753 8 Irvine Row Carlisle, PA 17013 717-243-9400 r 09-5753 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 htip://www.phfa.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 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 85874FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 0 09-5753 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 WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. BONNIE G. CAMPBELL BRADLEY R. CAMPBELL Mortgagor(s) and Record Owner(s) 302 South Enola Drive Enola, PA 17025 Defendant(s) Term No. 09-5753 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: CAMPBELL, BRADLEY R. BRADLEY R. CAMPBELL 302 South Enola Drive Enola, PA 17025 Your house at 302 South Enola Drive, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $94,320.86 obtained by WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 09-5753 1. The sale will be cancelled if you pay to WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1, 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 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 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: httn://www.L)hiladeli)hiafed.or2/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 09-57.53 8 Irvine Row Carlisle, PA 17013 717-243-9400 r 09-5753 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 8587417C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5753 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WACHOVIA BANK, NATIONAL ASSOCIATION FOR THE BENEFIT OF THE SECURITY HOLDERS OF THE STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE LOAN TRUST 2005-RF1, Plaintiff (s) From BONNIE G. CAMPBELL and BRADLEY R. CAMPBELL (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 $94,320.86 L.L. $.50 Interest from 10/10/09 to Date of Sale per diem at $16.20 -- To be Determined Atty's Comm % Atty Paid $176.50 Plaintiff Paid Date: 10/15p9 Due Prothy $2.00 Other Costs (Seal) By: Long, Prothonotary Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET ST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129