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Home My WebLink About09-5867.GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 -MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007EMXI 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. AMBER L. LAUDERMILCH THOMAS W. LAUDERMILCH JR. Mortgagors and Record Owners 428 West Simpson Street Mechanicsburg, PA 17055 Defendants CIVIL ACTION: le"t lr0pr!?? if ,0 r?,?MORTGAGE 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 QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term n No. Oq- 58 VI l?;v?? DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.gvx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: htip://www. hip 'ladelphiafed.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 8535317C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007EMX1, 3451 Hammond Avenue, Waterloo, IA 50702. 2. The names and addresses of the Defendants are AMBER L. LAUDERMILCH, 428 West Simpson Street, Mechanicsburg, PA 17055 and THOMAS W. LAUDERMILCH JR., 428 West Simpson Street, Mechanicsburg, PA 17055, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On September 19, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. A/N/F MORTGAGE LENDERS NETWORK USA, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1968 Page 3401. The mortgage has been assigned to: U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007EMX1 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 April 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 ..................................................................................$121,234.18 Interest from 03/01/2009 through 07/31/2009 at 10.5000% .....................$5,335.10 Per Diem interest rate at $34.87 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,061.71 Costs of suit and Title Search ......................................................................$900.00 NSF Charges ..................................................................................................$20.00 Property Inspection Fee .................................................................................$22.50 Corporate Advance ........................................................................................$83.00 Monthly Escrow amount $229.75 $133,656.49 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 personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular snail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $133,656.49, together with interest at the rate of $34.87, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: qd&Tt - ulga)-h GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Jeffrey Stephan Umited Signing Officer 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: #85353FC - AMBER L. LAUDERMILCH 428 West Simpson Street Mechanicsburg, I ry Stephan Signing Officer Prepared By and Return To: Beth Gradel GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 7655531507 GMM File Number: 85353FC Parcel ID#: 20-23-0567-037 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR MORTGAGE LENDERS NETWORK USA, INC. (Assignor), for and inconsideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007EMX1. U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007EMXI (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 AMBER L. LAUDERMILCH and THOMAS W. LAUDERMILCH JR., Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR MORTGAGE LENDERS NETWORK USA, INC. Bearing date of. 09/19/2006; Amount Secured: $124,000.00; Recorded on 10/0612006; in Book 1968 Page 3401; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 428 West Simpson Street, Mechanicsburg, PA 17055 AS FURTHER DESCRIBED IN EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate corpo ffi s e uted and sealed with its corporate seal this Assignment of Mortgage on this day of , 2009. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR MORTGAGE LENDERS NETWORK USA, INC. (Affix Corporate Seal) Vice President ss: I Po-, .4e STATE OF COUNTY BE IT REMEMBERED, that on this Mday of Notary Public personally appe#re4, f1 _ _ Title: ?n Kerr, Assistant Stone" before me, V MORTGAGE ELFt;, IRONIC REGIMW W991 C AS NOMINEE FOR MORTGAGE LENDERS .. NETWORK USA. rNQ 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 seat 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. 1?? Pubfic- r My commission expires: I hereby certify the address of the Assignee is: 3451 Hammond Avenue, Waterloo,IA 5o702 COMMONWEALTH OF PENNSYLVANIA Notarial Seat Mary Lynch. Notary PubNc UpW Dublin Tarp.. Montgomery Cowry Commissltln FXpkft NOV. 4 2010 Merrtbar, Pennsyivanta Association 7655531507 Case #: 85353FC Ey,hiditA ALL THAT CERTAIN house and lot of ground situate on the North side of West Simpson Street, in the Fifth Ward of the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: isECINNING at a point in the center of a twenty (20) foot alley; thence Southwardly along lot now or formerly of E.L. Stansfield, one hundred nineteen (119) feet to a point on the line of Simpson Street; thence Westwardly along the line of Simpson •;treet, thirty-five and twenty-five one-hundredths (35.25) feet i:o an iron pin on the line of Simpson street; thence Northwardly ,long lot now or formerly of Russel A. Hale, sixty-five and :sixty-five one-hundredths (68.65) feet to a notch in concrete retaining wall; thence Weetwardly along said lot now or formerly of Russel A. Hale, six and seventy-five one-hundredths (6.75) feet to an iron pin; thence Northwardly along the same, Forty-nine and fifty-five one-hundredths (49.55) feet to a point in the center of the aforesaid alley; thence Eastwardly along the center line of said alley, thirty-four and twenty-five :one-hundredths (34.25) feat to the place of BEGINNING. PAVING THEREON ERECTED a two and one-half story frame dwelling i:nown and numbered as 428 West Simpson Street. riEING the same premises which William L. Bortner and Lisa K. iiortner, husband and wife, by their deed dated February 7, 1997 ,nd recorded February lo, 1997 in Record Book 153, Page 154 ;ranted and conveyed unto William L, Bortner. ao dt pannrlAri? I as „i it of Cumin n,. rscocdkw Of o•eds d lend n 1.1PAIM6 •a paoorurr ROOK1369ME 2"16 `w- Eythibit B LAUDERMILCH JR., THOMAS W. THOMAS W. LAUDERMILCH JR. 428 West Simpson Street Mechanicsburg, PA 17055 File #: 85353FC JC (ACT) Sale date: County: Cumberland Property: 428 West Simpson Street Mechanicsburg, PA 17055 IIAI?AI?II LAUDERMILCH, AMBER L. AMBER L. LAUDERMILCH 428 West Simpson Street Mechanicsburg, PA 17055 File #: 85353FC JC (ACT) Sale date: County: Cumberland Property: 428 West Simpson Street Mechanicsburg, PA 17055 IIIIIIIIIIIII ACT 91 NOTICE DATE OF NOTICE: July 21, 2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP may be able to help to save ypiWg home, hir, AT®e tigo 1 1, tho pTpe works. ?sr?rrvasa'? 3 X::=C : 7l viip xm[ixD xxy Y1^a" To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. . The name, address and phone number of Consumer Credit Counseling Agencies serving our Coup are listed at the end of this Notice. If you have an uestions ou may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. Persons with im aired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion im>mediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numeeo mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: July 21, 2009 Homeowners Name: AMBER L. LAUDERMILCH and THOMAS W. LAUDERMILCH JR. Property Address: 428 West Simpson Street, Mechanicsburg, PA 17055 Loan Account No.: 7655531507 Original Lender: MORTGAGE LENDERS NETWORK USA, INC. Current Lender/Servicer: GMAC MORTGAGE CORPORATION HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S ICA&PR-GENC 9- ?rnnmr? w r_E A SO= A XCE 4 cz OF 408i (1149 Tn?? you A;AY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARIING ® EURECI.n-SITIR AA CAr1VCT vpjiR PROPER.IX, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to snake a decision after it receives your application. During that time; no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 428 West Simpson Street, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 04/01/2009 thru July 21, 2009 (4 mos. at $1,322.53/inonth) $5,290.12 (b) Other charges; Escrow, Inspec., NSF Checks (c) Other provisions of the mortgage obligation, if any (d) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $5,290.12 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $5,290.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME iii 1F DI113ING THE THIRTY (10) DAY PER ICID Pat+v+Pnte miict hP martP pithpr by rael,ia, .l, n. b certified check or money order made payable and sent to: GMAC MORTGAGE, LLC LOSS MITIGATION DEPARTMENT 3451 Hammond Avenue Waterloo, IA 50702 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the tender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY ('0) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by wing the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by perfon-ning any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4 to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Address: 3451 Hammond Avenue Waterloo, IA 50702 Phone Number: 800-850-4622 Fax Number: 319-236-7437 Contact: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Loss Mitigation Department Phnne Nnmher• SOU-S50-4672 HEMAP Consumer Credit Counseling Agencies Report last updated: 71112009 8:45:33 AM CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 570.602.2227 800.922.9537 CRAWFORD County Booker T. Washington Center 1720 Holland Street Erie, PA 16503 814.453.5744 CCCS of Western PA 4402 Peach Street Erie, PA 16509 888.511.2227 ext 108 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DAUPHIN County 888.511.2227 ext CCCS of Western PA 108 2000 Linglestown Road Harrisburg, PA 17102 Center for Family Services, Inc. 888 511 2227 213 Center Street ne .+ uo?a ia?u 888.511.2227 814.337.8450 Community Action Commission of Captial Region 1514 Derry Street Greater Erie Community Action Committee Harrisburg, PA 17104 18 West 9TH Street 717.232.9757 Erie, PA 16501 814.459.4581 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County Adams County interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Opportunity Inc. 301 East Market Street York, PA 17403 717.424.3645 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.3421397 DELAWARE County Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 215.765.1221 Advocates for Financial independence 202 East Hinkley Avenue Ridley Park, PA 19078 215.389.2810 Page 8 of 21 0 CF T`it-- Z0j) F(_! e i t: GO cul a 478.50 Po A W CK7 3R y tag e aaq scq Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ??ntr ofuutbrrt? OFFIU OF 'NE S"ERI€F FILED _ OF THE 'MARY US Bank National Association vs. Thomas W. Laudermilch, Jr. 2009 AUG 31 P11 3.34 Ivll iii i'3' iY. Case Number 2009-5867 SHERIFF'S RETURN OF SERVICE 08/27/2009 08:55 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 2055 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Thomas W. Laudermilch, Jr., by making known unto himself personally, at 428 West Simpson Street Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. 08/27/2009 08:55 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 2055 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Amber L. Laudermilch, by making known unto herself personally, at 428 West Simpson Street Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $53.00 August 28, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF BY Deputy Sheriff Sheriffs Office of Cumberland County R Thomas Kline Sheriff #,s,?tr of ?.:N??ubcr??«dOFFPCE _?F ',-E :-ERIFF RLE OF TVi c a ')k;')TARY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor International Portfolio Inc. vs. Jeffrey A. Long 2009 Sc"P _ 1 PH 2: 17 Case Number 2008-5867 SHERIFF'S RETURN OF SERVICE 08/29/2009 09:32 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 0932 hours, she served a true copy of the within Complaint and Notice, upon the withir named defendant, to wit: Jeffrey A. Long, by making known unto Tina James, adult in charge at 6360 Galleon Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $64.00 August 31, 2009 SO?ANS R THOMAS KLINE, SHERIFF Depu S eri GOLDBECK McCAFFERTY &OM&MEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007EMXI 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff VS. AMBER L. LAUDERMILCH THOMAS W. LAUDERMILCH JR. 428 West Simpson Street Mechanicsburg, PA 17055 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 09-5867 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. 4yjaj kll. Michael T. McKeever, Esquire Attorney for Plaintiff RLOOrME OF THE PROTHONOTARY 2004 NOV 20 Ply 1: 00 CU 4 L ,?1ix? ?,'I JN Y P EL Tt?1??l1tIA