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Home My WebLink About09-6056GOLDBECK 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 CITIMORTGAGE, INC. 1000 Technology Drive O'Fallon, MO 63304 vs. DAVA MARIE PAIGE Mortgagor and Record Owner ARTHUR L. REVERE JR. Mortgagor 1014 North College Street Carlisle, PA 17013 Plaintiff THE UNITED STATES OF AMERICA Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 0'ivil No. 09- t005(v CIVIL ACTION: MOMTQAGf- rem Clt?SUPIF 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 andmotice 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 maybe tiered against you by the Court without further no Ice or any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website ft://www.phfa.oroJconsumers/homeowners/real.gox. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.orgLforeclosure/ 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(a)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 86849FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is CITIMORTGAGE, INC., 1000 Technology Drive, O'Fallon, MO 63304. 2. The names and addresses of the Defendants are DAVA MARIE PAIGE, 1014 North College Street, Carlisle, PA 17013 who is the mortgagor and record owner and ARTHUR L. REVERE JR., 1014 North College Street, Carlisle, PA 17013, who is the mortgagor of the mortgaged premises hereinafter described. 3. Defendant, THE UNITED STATES OF AMERICA, is named a Defendant pursuant to 28 U.S.C. Section 2410, and Plaintiff requests that a judicial sale be held of the Property. 4. On June 24, 2008 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR FRANKLIN BANK, SSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Instrument # 200822613. The mortgage has been assigned to: CITIMORTGAGE, INC. 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. 5. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property") 6. The mortgage is in default because the money-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. 7. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$160,528.98 Interest from 03/01/2009 through 08/17/2009 at 6.5000% .... ...................$5,217.18 Per Diem interest rate at $28.59 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$8,026.45 Late Charges from 04/01/2009 to 08/17/2009 ....................... ......................$286.16 Monthly late charge amount at $40.88 Costs of suit and Title Search ................................................ ...................... $900.00 Unpaid Previous Late Charges ............................................... ........................$81.76 FHA/PMI premium ................................................................ ......................$130.58 Delinquent Expense Total ...................................................... ........................$45.00 Escrow Advance Balance ...................................................... ......................$607.35 Monthly Escrow amount $269.23 $175,823.46 8. 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. 9. 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. 10. THE UNITED STATES OF AMERICA, the above named Defendant, has a lien filed of record, set forth in Exhibit `C' which is attached and made part of this Complaint. 11. 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 $175,823.46, together with interest at the rate of $28.59, 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. /, I By: GOLDBECK MCCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I Aaron Menne 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: August 18, 2009 #86849FC - DAVA MARIE PAIGE and ARTHUR L. REVERE JR. 1014 North College Street Carlisle, PA 17013 PREPARED BY & RETURN TO: M. E. Wileman Orion Financial Group, Inc. 2860 Exchange Blvd. # 100 Southlake, TX 76092 Assignment of Mortgage Send Any Notices To Assignee. For Valuable Consideration, the undersigned, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS") SOLELY AS NOMINEE FOR FRANKLIN BANK, SSB G4318 Miller Road, Flint, MI 48507 (Assignor) by these presents does assign, and set over, without recourse, to CITIMORTGAGE, INC. 1111 NORTHPOINT DRIVE, BLDG. 4 SUITE 100, COPPELL, TX 75109 (Assignee) the described mortgage, together with certain note(s) described with all interest, all liens, any rights due or to become due thereon, executed by DAVA M. PAIGE, A SINGLE WOMAN AND ARTHUR L. REVERE JR., A SINGLE MAN to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ('MERS') SOLELY AS NOMINEE FOR FRANKLIN BANK, SSB. Said mortgage Dated: 6/24/2008 is recorded in the State of PA, County of Cumberland on 7/2/2008, as INST# 200822613 AMOUNT: $ 161,721.00 Parcel # 06-19-1643-045 AND 06- 19-1643-0 Property Address: 1014 NORTH COLLEGE STREET, CARLISLE, PA 17013 IN WITNESS WHEREOF, the undersigned corporation has caused this instrument to be executed by its proper officer. Executed on: August 28, 2009 MORTGAGE EL ONIC REGISTRATION SYSTEMS, INC. ("MERS") SOLELY AS NOMINEE FOR FRANKL , SSB A Imm INN By: 111111 111 Nil PAIGE CMR *00093878* D. M. Wileman, Vice President State of Texas, County of Tarrant On August 28, 2009, before me, the undersigned, personally appeared D. M. Wileman, who acknowledged that he/she is Vice President of/ for MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS") SOLELY AS NOMINEE FOR FRANKLIN BANK, SSB and that he/she executed the foregoing instrument and that such execution was done as the free act and deed of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS") SOLELY AS NOMINEE FOR FRANKLIN BANK, SSB. A ?rrla? ?- ro.WyJ. PLOAEE$ NOTARY PUBLIC STATE OF TSLIC Notary publicVon o My commissiOctober 13, 2009 Comm. E xpires 1L AS MIN 100213300000233804 MERS Phone 888-679-6377 PA Cumberland AHESFIP/GOLDBECK/AHE The Assignee hereby certifies that the precise residence is 1111 NORTHPOINT DRIVE, BLDG. 4 SUITE 100, COPPELL, TX 75109. E.ThibitA Loan No.: 08402104 EXHIBIT "A" TRACT # 1: ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in Carlisle Borough, Cumberland County, Pennsylvania, more particularly bounded and described as follows,-to wit: BEGINNING on the East by North College Street, on the South by Lot No. 9 in Block No. 34 according to the plan of lots laid out and adopted by the Carlisle Land & Improvement Company, said Plan being recorded in Cumberland County Miscellaneous Book 11, Page 572: on the West by a 16 foot alley; and on the North by a 16 foot alley; containing 50 feet in front on North College Street and extending in depth 200 feet to said alley on the West; in being composed of Lot Nos. 7 and 8 in Block No. 34 according to the above-mentioned Plan of Lots of said Carlisle Land & Improvement Company. TRACT #2: ALL THAT CERTAIN had of land situate in Carlisle Borough, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the East by North College Street, on the South by Lot No. 11 in Block No. 34 according to the plan of lots of the Carlisle Land & Improvement Company; on the West by an alleyr and on the North by Lot No. 8 in said Block No. 34; containing 50 feet in front on North College Street and extending in depth 200 feet to said alley on the West, it being composed of Lot Nos. 9 and 10 in Block No. 34 according to the plan of lots of the Carlisle Land & Improvement Company, which Plan is recorded in Cumberland County Miscellaneous Record Book 11, Page 572. Parcel #06-19-1643-045 and Parcel #06-19-1643-045A (DoD) RA0231229 - eAlbitkm - 09/2512008 E.xhibit B REPRESENTATION OF PRINTED DOCUMENT c ti mortgage 7107 8381 6540 1004 6764 06/22/09 98923 001190 Dava M Paige 1014 N College St Carlisle PA 17013-1308 RE: Property: 1014 North College Street Carlisle, PA 17013 Loan No: 2005559187 Mortgagee: G N M A NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No. 6 of 1974. (READ ALL PAGES OF THIS NOTICE CAREFULLY) :J .7 V O CitiMortgage, Inc. is providing this notice as lender or servicing agent for the lender. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION--PAR-RGSES ONLY AND SHOULD NOT BE CONSIDERED AS--AN-- ATTEMPT TO COLLECT THE DEBT. The MORTGAGE held by the above name MORTGAGEE (hereinafter we, us, or ours) on your property noted above under RE:, IS IN DEFAULT because you have not made the monthly payments as noted below under (a). Previous late charges under (b), if any, have also accrued to this date. THE TOTAL AMOUNT NOW REQUIRED TO CURE THIS DEFAULT IS $4,093.66, INCLUDING $204.40 IN LATE CHARGES AND $15.00 IN DELINQUENCY RELATED EXPENSES IS NOTED BELOW UNDER (d). (a) 04/01/09 thru 06/01/09 3 @ $1,291.42/month 3 @ $40.88/late charge/month $4,093.66 (b) Previous late charge(s) $81.76- (c) Delinquency Expense(s) $15.00 (d) TOTAL AMOUNT (a)+(b)+(c) REQUIRED AS OF THIS DATE: $4,093.66 You may cure this default by 07/22/09 (or the next business day thereafter if 07/22/09 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan current. Such payment must be made either by CASH, CASHIER'S CHECK, CERTIFIED CHECK, OR MONEY ORDER made payable to CitiMortgage, Inc., Loan Payments, P.O. Box 689196, Des Moines, IA 50368-9196. 2005559187 CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 2005559187 c ti mortgage Page Two 06/22/09 2005559187 If you do not cure the default by 07/22/09, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by 07/22/09, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by 07/22/09, you-wt-"-not be required to pay attorney's fees. - Also, we may sue you personally for the unpaid principal balance, and all other sums due under the mortgage. If you have not cured the default by 07/22/09, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of the Sheriff's 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 will be by calling us at the following number: 1(800)723-7906*. You should realize that a Sheriff's 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. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 2005559187 c ti mortgage Page Three 06/22/09 2005559187 You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. Under IRS regulation, we must report any foreclosure to the IRS on form 1099-A. The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a resuTt of a loss of employment income or a reduction in employment income you may be eligible for homeownership counseling from one of the Department of Housing and Urban Development ("HUD") approved homeownership counseling agencies. Please call us at 1(800)723-7906* for information regarding the HUD-approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *Calls are randomly monitored and recorded to ensure quality service. This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issued by a United States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. 090622D0007276 il. 4 N O CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT dti mortgage 7107 8381 6540 1004 6771 06/22/09 98923 001191 Arthur L Revere Jr 1014 N College St Carlisle PA 17013-1308 RE: Property: 1014 North College Street Carlisle, PA 17013 Loan No: 2005559187 Mortgagee: G N M A NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of PA Act No. 6 of 1974. (READ ALL PAGES OF THIS NOTICE CAREFULLY) CitiMortgage, Inc. is providing this notice as lender or servicing agent for the lender. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE -- 16 FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. The MORTGAGE held by the above name MORTGAGEE (hereinafter we, us, or ours) on your property noted above under RE:, IS IN DEFAULT because you have not made the monthly payments as noted below under (a). Previous late charges under (b), if any, have also accrued to this date. THE TOTAL AMOUNT NOW REQUIRED TO CURE THIS DEFAULT IS $4,093.66, INCLUDING $204.40 IN LATE CHARGES AND $15.00 IN DELINQUENCY RELATED EXPENSES IS NOTED BELOW UNDER (d). (a) 04/01/09 thru 06/01/09 3 0 $1,291.42/month 3 ! $40.88/late charge/month $4,093.66 (b) Previous late charge(s) $81.76- (c) Delinquency Expense(s) $15.00 (d) TOTAL AMOUNT (a)+(b)+(c) REQUIRED AS OF THIS DATE: $4,093.66 You may cure this default by 07/22/09 (or the next business day thereafter if 07/22/09 is a Saturday, Sunday, or Federal Holiday) by paying to us the amount under (d) above. Any additional payments and late charges that fall due during this period must also be paid to bring your loan current. Such payment must be made either by CASH, CASHIER'S CHECK, CERTIFIED CHECK, OR MONEY ORDER made payable to CitiMortgage, Inc., Loan Payments, P.O. Box 689196, Des Moines, IA 50368-9196. J O K M O CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT 2005559187 REPRESENTATION OF PRINTED DOCUMENT 2005559187 c ti mortgage Page Two 06/22/09 2005559187 If you do not cure the default by 07/22/09, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original mortgage amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made by 07/22/09, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default by 07/22/09, yoa-wi7T not be required to pay attorney's fees. -- Also, we may sue you personally for the unpaid principal balance, and all other sums due under the mortgage. If you have not cured the default by 07/22/09, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of the Sheriff's 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 will be by calling us at the following number: 1(800)723-7906*. You should realize that a Sheriff's 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. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 2005559187 c ti mortgage Page Three 06/22/09 2005559187 You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES, ATTORNEY'S FEES, AND COSTS ARE PAID PRIOR TO, OR AT THE SALE (AND THAT OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY A THIRD PARTY ACTING ON YOUR BEHALF. Under IRS regulation, we must report any foreclosure to the IRS on form 1099-A. The foreclosure may result in income tax consequences to you. Consult the IRS or your tax advisor for further information. If your delinquency is a resufit -of a loss of employment income or a reduction in employment income you may be eligible for homeownership counseling from one of the Department of Housing and Urban Development ("HUD") approved homeownership counseling agencies. Please call us at 1(800)723-7906* for information regarding the HUD-approved counseling agency nearest you and/or to discuss the circumstances of the default with one of our Loan Counselors. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department CitiMortgage, Inc. *Calls are randomly monitored and recorded to ensure quality service. This is an attempt to collect a debt, and any information obtained will be used for that purpose. In the event you are subject to an Automatic Stay issued by a United States Bankruptcy Court or the referenced debt has been discharged in Bankruptcy, this communication is not intended to be an attempt to collect a debt. 090622D0007277 a N O CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT ?hibit C 2009-05107 U S TRr:4ASURY DEPT (VS) REVERE ARTHUR L JR Reference No... Filed........: 7/27/2009 Case Type...... FEDERAL TAX LIEN Time.........: 2:31 Tudd ent...... 53739.95 Execution Date 0/00/0000 q'i a Assigned: Ju Trial.... Disposed Desc : Disused Date. 0/00/0000 ------------ Case Comments -------- ---- Higher Crt 2.: ****w:e?r*****r*t?***wx•**?r**w*r?******w**w*?•*****w***ww*********w*wt*****?ex,ew*****?r* General Index Attorney Into U S TREASURY DEPARTMENT PLAINTIFF PITTSBURGH OFFICE ROOM 808 2000 LIBERTY AVE PITTSBURGH PA 15222 9974 REVERE ARTHUR L JR DEPM RANT 1014 N COLLEGE ST CARLISLE PA 17013 Judgment Index Amount Date Dese REVERIE ARTHUR L JR 53,739.95 7/27/2009 TAX LIEN **w?r**w**www,?*+r***www*****,tww?rw*?r*****?r*ar,a********ar***w*********************ww*w * Date Entries wx**w***w**wwwwwwxww?r*,t*w*w*?r,twww?r*,r***w***w***+tw+ewwwww,?www?rwww»wwwwwww,rww*****w 7/27/2009 FEDERAL TAX LIEN IN THE AMOUNTSOF$$63739.95 - - - - - - - - - - - - - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - ********wwwwww**w****wi?**+***wwwww**w****wwf*,rwww*wx*ww*w?ewwwwwwx,r*wwwww*?rwwwar** * Escrow Info ?t$on * Fees & Debits Beg Bal PrmtslAdI End Bal *w**ww********ww*wwww*******+?*ww ?r**wwww* **w*** **x,r***?r*******x***?r*w,?*w**w**,c FED TAX LIEN r4 QU 14.00 .00 AUTOMATION FEE '-_-- 5.00 y-_----5_00- -_---,-y_00 -29.00- 19.00 .00 **www,+w+ewwww?r+?wwwwwww?rw***w******************************'****'**www*ww*wa?+.+t*w•www * End of Case Information w *w*wt****w*?r*,rw**w****t**w****w#****w*r?**wd??eat***ww**w*w**w*:*w*******?ewxww*w-x*** 0 a OF ` , 209 SEP -4 PM 1: 52 MBERAND CQU4rY P?J'?lx- 4'18.50 Po ATTq V* A3= (A Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ioolljr of u irit?r? f ?{ OMCE F '-EglrF ARY FILE:=k, .: Citimortgage Inc vs. Dava Marie Paige 2 S :'-' 2I ki!I C: ?. Case Number 2009-6056 SHERIFF'S RETURN OF SERVICE 09/15/2009 03:56 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on September 15, 2009 at 1556 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dava Marie Paige, by making known unto herself personally, at 1014 North College Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/15/2009 03:56 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on September 15, 2009 at 1556 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Arthur L. Revere, Jr., by making known unto Dava M. Paige, adult in charge at 1014 North College Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.40 September 16, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By A)A C UUt0L-LqMLLt--) Deputy Sheriff