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Home My WebLink About09-6138GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 NN'"'W.GOLDBECKLAVV.COM ATTORNEY FOR PLAINTIFF M&T BANK 1 Fountain Plaza Buffalo. NY 14203 TARYN N. DIXON Mortgagor and Record Owner 3426 Walnut Street Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS vs. Plaintiff OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE F ECLOSURE Oq - (P138 Utvi( `Tarm Defendant CIVIL AC : MORTGAGE 1r:7- 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 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.Dhfa.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: httl2://www.Dhiladelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention rggoldbecklaw 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 8719017C. 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 M&T BANK, 1 Fountain Plaza, Buffalo, NY 14203. 2. The names and addresses of the Defendant is TARYN N. DIXON, 3426 Walnut Street, Camp Hill, PA 17011, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On June 16, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR M&T MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1818, Page 296. The mortgage has been assigned to: M&T BANK 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 May 07, 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 ........................ ............................................... .......... $114,172.63 Interest from 04/23/2009 through 08/31/2009 at 5.1250% ........ .............. $2,099.93 Per Diem interest rate at $16.03 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .... .............. $5,708.63 Late Charges from 05/07/2009 to 08/31/2009 ............................ .. $609 96 .............. . Costs of suit and Title Search ...................................................................... $900 00 Fees ..................................................................... ........................ . ................ $87.00 Pro Rata MIP/PMI ...................................................................... ................ $210 92 Escrow Advance .......................................................................... NSF Charges ........ . ............. $1,085.01 ....................................................................... Monthly Escrow amount $167.54 ................ $400.00 $125,274.08 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, 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 Defendant 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 Defendant 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 $125,274.08, together with interest at the rate of S 16.03, 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:_k4J (F, Wka,,c GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Christopher M. Z e i s , 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: 8/28/09 Christop M. Z i Vice Pre 'dent #87190FC - TARYN N. DIXON 3426 Walnut Street Camp Hill, PA 17011 E.rthibitA ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described according to a survey of D.P. Raffensperger, R.S., dated July 24, 1956, as follows, to wit: BEGINNING at a point on the North side of Walnut Street at the distance of three hundred and seventy-six hundredths (300.76) feet East of the northeast corner of the intersection of Walnut and 35th Streets, and at the dividing line between Lots Nos. 4 and 5, Block U on the hereinafter mentioned Plan of Lots; thence northwardly along the same and at right angles to Walnut Street, one hundred twenty (120) feet to a point; thence eastwardly seventy-five (75) feet to a point at the dividing line between Lots Nos. 5 and 6, Block U on said plan; thence along the same southwardly and at right angles to Walnut Street, one hundred twenty (120) feet to a point at the northern side of Walnut Street; thence westwardly along the same seventy-five (75) feet to a point, the place of BEGINNING. BEING Lot No. 5, Block U on Plan of Part of Hampden Gardens, said Plan being recorded in Cumberland County Recorder's Office in Plan Book 6, Page 30. HAVING THEREON ERECTED a dwelling house known and numbered as 3426 Walnut Street. UNDER AND SUBJECT, NEVERTHELESS, to restrictions, conditions, and easements of prior record pertaining to said premises. BEING THE SAME PREMISES which Barry J. Schoch, single man, by his Deed to be recorded simultaneously herewith, in the office of the Recorder of Deeds of Cumberland county, granted and conveyed unto Taryn N. Dixon, single woman. I Certify this to be rc-, d rn Cumberland COU11 ty 13n keeorder of I BK 181 S PG 0 312 Ex hi6lot (B M&T Bank P.O. Box 840 Buffalo, NY 14240-0840 07/13/2009 Taryn N Dixon 3426 Walnut St Camp Hill, PA 17011 HOMEOWNERS NAME(S): Taryn N Dixon PROPERTY ADDRESS: 3426 Walnut Street Camp Hill, PA 17011 LOAN ACCT NO: 0006674857 ORIGINAL LENDER: M&T Mortgage CURRENT LENDER/SERVICER: M&T Bank ? M&T Bank Certified No.: 71826389306014813550 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'a YOU MAY 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 3 days for mailing). During that time you must arrange and attend a "faceto-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING M11CT nVV1FT0 wrrunv T1XV .,. X70 _ - _ .... . HM rAK I IJh "I HIS NOTH-F CAi I FD"HO Ir TO CURF YOUR MORTGAGF DFFAlJLT" FXPT AlNq HOW TO HRIi`TC, YOUR MORTGAGE IJP TO DATF CONSUMER CREDIT COUNSELING AGENCIES --If you meet with one of the consumer credit counseling agency 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 and of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. 1 800 724 1633 Payment Processing -P.O. Box 62182, Baltimore, MD 21264-2182 Mortgage account information, just a click away. www.mtb.com 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'sEmergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'sEmergency 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 forwaded to PHFA and received within thirty (30) days of your face-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 A PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED 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 EVENTURALLY 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 make 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.) M&T Bank is attempting to collect a debt and any information obtained will be used for that purpose. If you are in bankruptcy or received a bankruptcy discharge of this debt, this communication is not an attempt to collect the debt against you personally, but is notice of a possible enforcement of the lien against the collateral property. HOW TO CURE YOUR MORTGAGE DEFAULT Brine it up to date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 3428 walnut street IS SERIOUSLY IN DEFAULT becai H111 , PA 17011 YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Regular payments of $526.43 for the months of 05/07/2009 through today's date: $ 2632.15 Other charges: Accrued Late Charges: $ 558.14 Accrued Other Charges $ 438.00 TOTAL AMOUNT PAST DUE: $ 3828.29 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 $3626.29, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: M&T Bank, P.O. Box 62182, Attn: Payment Processing, Baltimore, MD 21264-2192 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 lender 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 (30) 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 begins 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 --qbe 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 Sheriff's Sale. You may do so by paying 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 Sheriffs Sale as specified in writing by the lender and by performing 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 Sheriff's Sale of the mortgaged property could be held would be approximately 10 months from the date of this Notice. A notice of the actual 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: M&T Bank Fax Number: 716-630-4900 Address: P.O. Box 840 Contact Person: Evelyn Wilson Buffalo, NY 14240 Email Address: ewilson@mtb.com Phone Number: (800) 724-161 EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff's 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 Sheriff's 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 or X may not 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. Sincerely, Evelyn Wilson Homeowner Assistance Center Enc: Act 91 Notice Consumer Credit Counseling Agencies Serving Your County 1 800 724 1633 Payment Processing -P.O. Box 62182, Baltimore, MD 21264-2182 Mortgage account information, just a click away. www.mtb.com ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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 your home. This Notice explains how the program works. 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 Counseline Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions. you may can the Pennsylvania Housing Finance Agency toll free at 1-800342-2V7.(Persons with impaired hearing can call (717) 780-180) 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 an 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 NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO 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. 1 800 724 1633 Payment Processing -P.O. Box 62182, Baltimore, MD 21264-2182 Mortgage account information, just a click away. www.mtb.com Homeowner's Emergency Assistance Program Cumberland County Adam C-tF IaterhM Hoadaf Aatborlty 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of WeNera PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Coa wWq Acdoz COaa=Wm of Csptlal Beaoa 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveddp, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Mareaatka 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 APANIMCPQ-0 EASI1 taisaom 0 OF MY 2409 S 10 ACS 11: 1 7 8.5o Pp, fll7`{ ,v it o18) PT# a3OyoB Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor FILED 4?'- r,,- T ,w UL 2009 Si:!' S P 2, , wR1NF tr ?? '' OPIZE --E ,ATY M & T Bank vs. Taryn N. Dixon Case Number 2009-6138 SHERIFF'S RETURN OF SERVICE 09/14/2009 07:27 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 14, 2009 at 1927 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Taryn N. Dixon, by making known unto himself personally, at 3426 Walnut Street Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 September 15, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By ?- Deputy Sheriff GOLDBECK McCAFFERTY & McKEEVER 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 M&T BANK 1 Fountain Plaza. Buffalo, NY 14203 Plaintiff VS. TARYN N. DIXON 3426 Walnut Street Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 09-6138 Defendant PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. i Viicb??el T. McKeever, Esquire Attorney for Plaintiff FUi 'er'r- E OF I- ^? i.:'74 r 2009 NOY -5 FM ; - 5 9 fly