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Home My WebLink About09-6354 GOLDBECK McCAFFERTY & McKEEVER Bl': MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 N'NVW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. GEORGE P. BECK Mortgagor and Record Owner 415 4th Street New Cumberland, PA 17070 Plaintiff Term G ?V? 1 No. py, (J 35?/ CIVIL ACTION: MOR'T'GAGE Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you rnust 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 LISTED 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. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. Sl USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMATION 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.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.phiIadelphiafed.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 sand/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 87793FC. Para information 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005. 2. The names and addresses of the Defendant is GEORGE P. BECK, 415 4th Street, New Cumberland, PA 17070, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On July 12, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR FIRST NATIONAL BANK OF ARIZONA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1917, Page 449. The mortgage has been assigned to: THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE by assignment of Mortgage May 19, 2068 and recorded on June 18, 2008 as Instrument #200820455. 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 01, 2009 and each month thereafter and by the teens 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 .................................................................... Interest from 04/01/2009 through 09/09/2009 at 8.7500%..... Per Diem interest rate at $18.00 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph. Late Charges from 05/01/2009 to 09/09/2009 ........................ Monthly late charge amount at $29.09 Costs of suit and Title Search .................................................. Escrow Balance ....................................................................... Legal Fees F/C ........................................................................ Property Inspections ................................................................ BPO's ....................................................................................... Interest- Escrow Advance ....................................................... Monthly Escrow amount $646.13 .......... $75,072.18 ............ $2,916.00 ............... $3,753.61 .................. $436.35 .................. $900.00 ............... $5,632.14 .................. $745.00 .................... $33.00 .................. $130.00 .................... $43.30 $89,661.58 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 Attorneys Fees requested are in confonnity 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 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 $89,661.58, together with interest at the rate of $18.00, 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. B)(: McCAFFERTY & McKEEVER 'Vlll~HAEL T. McKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date ?-_ YaWl T. McKeever, Esquire I.D. #56129 #87793FC GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 EythibitA ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania. BEING the same promises granted and conveyed from Earl J Brandt and Dolores V Brandt, husband and wife, unto George P Beck, by deed dated May 29, 1998, and recorded June 8, 1998 in Book 178, Page 909. BEING Tax Parcel 25-25-0006-013. T certify this to be recorded In Cumberland County PA Recorder of Deeds OK 1917PG0 1,,69 E,-Y,hi*bi*t B ? Wilshire-" Nlaa 31.2009 (TR I-II 11:) RLTURN RECEIPT AND RE AIL.AR FIRST CLASS MAIL LI -b'(; 131,CK. (IFOR(il. 415 4FII ST NIA\ (I ?N1BP.RLAND. PA 17070 R1:: Loan No.: 1233169 Wilshire Credit Corporation Payments P.O. BOX 105344: Atlanta. GA 30348-5344 or P.O. Box 7195, Pasadena. CA 91109-7195 Correspondence P.O. Box 8517: Portland, OR 97207-8517 Phone 888.502.0100 Fax 503.952.7476 Website https://www,wcc.ml.com ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DI: BT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT. BUT NOTICE OF POSSIBLE- ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http:/ANwtv.ago. state co us/cadc/cadcmain cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840 TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W Millikan Way.. Beaverton. OR Wilshire s office hours are Monday - Friday 6:00 am to 500 pm Pacific time. holidays excluded - Ll78G his Notice with you when you meet with the Counseling Agency. BFCK.000RGF Loan No.: 1233169 Pane 2 Mav 31. 2009 _number of Consumer Credit Col 'this Notice. If you have any clue e A(-,encv toll free at 1.800.342.2 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 INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE 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. HOMEOWNERS' NAME(S): PROPERTY ADDRESS LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: BECK, GEORGE 415 4TH ST NEW CUMBERLAND, PA 170701802 1233169 First National Bank of Arizona Wilshire Credit Corporation HOMEOWNER'S 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 EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), 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 (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT. SEE http://www.ago state co.us/cadc/cadcniain.cfni . NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W_ Milhkan Way. Beaverton. OR. Wilshire s office hours are Monday - Friday 600 am to 500 pin Pacific time. holidays excluded L 178G BECK. GEORGE Loan No.: 1233169 Pau, e 3 N1a% 31. 2009 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 consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. 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. You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. 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 duo so. You must till out. sign and file a completed Homeowner's Emergency Mortgage 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 forwarded 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 HA V E 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 TEMPORARIL Y PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STA Y OF FORCLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMA P A PPLICA TION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BL/T IF YOUR APPLICATION IS EVENTUALL YAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL. PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http/hvrvta.ago.state.co.us/cads/cadcmain.cfm NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840 TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton. OR Wilshire s office hours are Mondav - Friday 6:00 ant to 5:00 pm Pacific time, holidays excluded. Ll7SG BECK. GFORGF. Loan No.: 1233169 Paae 4 Ma. 31. 2009 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 youu 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: 415 4TH ST NEW CUMBERLAND, PA 170701802 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Your loan is delinquent for the following months: April 2009, May 2009. Past Due Installments: Principal Interest Other Open Charges: Prior Servicer Charee Late Charges $0.00 Legal/Attorney 0.00 Escrow Advance Interes Property Inspections 0.00 0.00 WCC Charges $480.22 745.00 13.60 11.00 Totals $122.12 1,095.24 $1,217.36 $480.22 745.00 13.60 11.00 $1,249.82 Less Suspense (Balance) $0.00 (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM .A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT. BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.aeo.state.cous/cadc/cadcmain.cfm. NEW YORK CITY: License 1032»1. NORTH CAROLINA: Permit 3840 TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton. OR Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time. holida} s excluded. LI78G BECK.GLORGE Loun No.: 1233169 Paac 5 N1a\ 3 1. 2009 TOT: L S2,467.18 HOW TO CURE THE DEFAULT - You may cure the default Nvithin THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2.467.18, 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: Wilshire Credit Corporation P.O. Box 7195 Pasadena, CA 91109-7195 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. LIP 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 tees 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 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 tithe 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 Sheriffs Sale of the mortgaged property could be held would be approximately eight (8) 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 (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT. BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE httpJAN\ \+ ago.state.co.us/cads/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840 TENNESSEE: This collection agency is licensed by the Collection Sen ice Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S W. Millikan Wav, Beaverton. OR Wilshire*s office hours are Monday Friday 6:00 am to 5 00 pm Pacific time, holidays excluded. L / 786- BECK. GEORGE Lean No.: 1233 169 Paae 6 Mav 31. 2009 the required payment or action will be by contacting the lender/servicer. HOW TO CONTACT THE LENDER/SERVICER: Name of Lender/Servicer: Address: Phone Number: Fax Number: Contact Person(s): E-Mail Address: Wilshire Credit Corporation P.O. Box 8517 Portland, OR 97207-8517 888.917.1050 503.946.3848 Holli Jennings or David Solomon loanworkoutgeneral@wee.mi.com 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 or X may not (CHECK ONE) 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 PAYOFF THE MORTGAGE DEBTOR 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 (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEB"1' HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT. BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http.//wwty.ago.state.co.us/cadc/cadeniain.cf-n. NEW YORK CITY: License 1032551 NORTH CAROLINA: Permit 3840 TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 13523 S.W. Millikan Way, Beaverton. OR Wilshire s office hours are Mondav - Friday 6:00 am to 5 00 pm Pacific time, holidays excluded. L1 78G BECK. GEORGE Loan No.: 1233169 Pai7c 7 Mav 3I. 2009 BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of Consumer Credit Counseling Agencies serving your county. Sincerely. Wilshire Credit Corporation Enclosures: PHFA list of HEMAP-approved agencies,How to Avoid Foreclosure YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT. THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago state co.us/cadc/cadcmain cfm. NEW PORK CITY: License 1032551 NORTH CAROLINA: Permit 3840 TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton. OR. W ilshire s office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time. holidays excluded. L178G W Wilshire- United States Department of Housing and Urban Development Servicemembers Civil Relief Act Notice Leal Rights and Protections Under the SCRA Ser icememhers on "active duty' or -'active sen ice." or a dependent of-such a ser icemember may be entitled to certain legal protections and debt reliei'pursuant to the Servicemembers C'iyil Rclicl-Act (50 t I.S.C App. 501. ct seq.) (SCRA). Who May Be Entitled to Legal Protections Under the SCRA? • Active duty members of the Ann}'. Navy. Air Force. Marine Corps. Coast Guard. and active service National Guard; • Active scrvicemembets of the commissioned corps of the National and Atmospheric Administration; • Active Servicemembers of the commissioned corps of the Public I Iealth Service: • United States citizens serving with the armed Iorces of a nation \yith v%hich the United States is allied in the prosecution of a war or military action; and • Dependants of the above (e.g.. spouse or children). What Legal Protections Are Servicemembers Entitled to Under the SCRA? • The SCRA states that a debt incurred by a ser icememher. or spouse jointly, prior to entering military ser ice shall not bear interest at a rate above 6 percent during the period of military serice. • The SCRA states that in a legal action to enforce a debt against real estate that is tiled during. or within 90 days after the servicemember's military service. a court may stop the proceedings for a period of time, or adjust the debt. In addition. the sale. foreclosure. or seizure of real estate shall not be valid if it occurs during. or within 90 days. after the servicemember's military service unless the creditor has obtained a court order approving the sale. foreclosure. or seizure of the real estate. How Does a Servicemember or Dependent Request Relief Under the SCRA? • A servicemember or dependent. or both, may request relief under the SCRA by providing the lender/servicer a written notice with a cop; ofthe ser•iccmember's militar; orders. Wilshire Credit Corporation P.O. Box 8517 Portland. OR 97207-8517 How Does a Servicemember or Dependent Obtain Information About the SCRA? The U.S. Department of Defense's information resource is "Military One Source." Web site: <http://www.militarN,onesourcc.com=. The toll-free telephone numbers for Military One Source are: From the United States: 1-800-342-9647. From outside the United States (with applicable access code): 800-342-9647-7. International Collect: 1-484- 530-5908. Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate. or their installation's Legal Assistance Officer. A military legal assistance office locator for each branch ofthe armed forces is available at: <http://le2atassistancL.law.,tf.mil/content/locatoLphp>. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER. IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http//"-"Nv.ago.state.co.us/cads/cadcmainctm NEW FORK CITY: License 1032551 NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton. OR Wilshire 's office hours are Monda% - Friday 6:00 am to 500 pm Pacific time. holidays excluded. L178G p OF 7PEE ? r t.. y 2001 SEr 24 All 11: 40 ?v F ?? op- Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy d 5 ^ FILED-i r=cz OF 711,c pllY? 1 p 1009 OCT -3 PIS !2: 00 Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor vt Jiu '???t?i Bank of New York Mellon vs. Case Number George P Beck 2009-6354 SHERIFF'S RETURN OF SERVICE 10/05/2009 03:22 PM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 5, 2009 at 1522 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: George P. Beck, by making known unto himself personally, at 415 Fourth Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 October 06, 2009 SO ANSWERS 10001AP A?" i R THOMAS KLINE, SHERIFF By -? Deputy Sheriff i GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 VS. GEORGE P. BECK Mortgagor(s) and Record Owner(s) 415 4th Street New Cumberland, PA 17070 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 09-6354 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to Plaintiff's Complaint filed on September 24, 2009 in the above captioned matter. GOLDBECK McCAFFERTY & McKEEVER BY: ,, Iv,( k uAi4n Michael T. McKeever Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. GEORGE P. BECK Mortgagor(s) and Record Owner(s) 415 4th Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 09-6354 CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification to Plaintiff s Complaint was served on Defendant(s) via first class mail on November 16, 2009 as follows: GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 GOLDBECK McCAFFERTY & McKEEVER Michael T. Mc keever Attorney for Plaintiff VERIFICATION I, "j3a Cec, k , 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: °1- \5 - U°1 X-??7 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE RESIDENTIAL FUNDING COMPANY, LLC ITS ATTORNEY IN FACT #87793FC - GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 FILED-OFFICE OF THEE PROTHONOTARY 2009 NO`S 19 P 1: 35 % In the Court of Common Pleas of Cumberland County THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. GEORGE P. BECK (Mortgagor(s) and Record Owner(s)) 415 4th Street New Cumberland, PA 17070 Defendant(s) No. 09-6354 PRAECIPE FOR JUDGMENT 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 GEORGE P. BECK by default for want of an Answer. Assess damages as follows: Debt Interest from 11 / 11/2009 to Date of Sale per diem at $18.00 Total (Assessment of Damages attached) $92,128.02 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 M w 6, Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW L )W /,I +L C2W , Judgment is entered in favor of THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE and against GEORGE P. BECK by default for want of an Answer and damages assessed in the sum ofA92,128.02 as perhe above certification. iothonotary Sheriffs Office of Cumberland County R Thomas Kline Sheri, f j of cvm be'rl'4?4 Ronny R Anderson Chief Dieeputy Jody S Smith Civil Process Sergeant anM CC TK s"OR" Edward L Schorpp Solicitor Bank of Now York Mellon Case Number vs. 2009-6354 George P Beck SHERIFF'S RETURN OF SERVICE 10105/2009 03:22 PM - Ron Hoover, Deputy Sheriff, who being duty swum according to law, states that on October 5, 2009 at 1522 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: George P. Bede, by making known unto himself personally, at 415 Fourth Stream New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 SO ANSWERS ?c rooowAiW?Z-- October 06, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff 87793FC 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: October 27, 2009 TO: GEORGE P. BECK BECK, GEORGE P. 415 4th Street New Cumberland, PA 17070 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. GEORGE P. BECK (Mortgagor(s) and Record Owner(s)) 415 4th Street New Cumberland, PA 17070 Defendant(s) TO: GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-6354 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, GEORGE P. BECK, is about unknown years of age, that Defendant's last known residence is 415 4th Street New Cumberland, PA 17070, 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: (--I0-(? 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. GEORGE P. BECK (Mortgagor(s) and Record owner(s)) 415 4th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-6354 ORDER FOR JUDGMENT Please enter Judgment in favor of THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE, and against GEORGE P. BECK 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 $92,128.02. Michael T. cKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 and that the name(s) and last known address(es) of the Defendant(s) is/are GEORGE P. BECK, 415 4th Street New Cumberland, PA 17070; M Kg??? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff TO THE PROTHONOTARY: ASSESSMENT OF DAMAGES Kindly assess the damages in this case to be as follows: Principal Balance Interest from 04/01/2009 through 11/10/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 2 X $646.13 Escrow Balance Legal Fees F/C Property Inspections BPO's Interest- Escrow Advance $75,072.18 $4,032.00 $3,753.61 $494.53 $900.00 $1,292.26 $5,632.14 $745.00 $33.00 $130.00 $43.30 $92,128.02 AND NOW, this 14x'' day of K)W c^ GO B K McCAF ERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff , 2009 damages are assessed as above. ro Prothy i AN .z st4.o° Co 505qlLp -AV a$33h'1 cn Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff No. 09-6354 vs. GEORGE P. BECK (Mortgagors and Record Owner(s)) 415 4th Street New Cumberland, PA 17070 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-captione tter t red against you. urt Long Prothon By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever 111 /01/01009 Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 4 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. GEORGE P. BECK Mortgagor(s) and Record Owner(s) 415 4th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-6354 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 11/11/2009 to Date of Sale per diem at $18.00 (Costs to be added) $92,128.02 cl"-- GOLDtECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ?oW W"'W O a p u+ d d ? O ?, ? C ap z Ub ,¢? C oU HBO ,zH Q?U 3 O p Zo, ? Q H Z O Q p., 00 U v4 N? H U ?U d ? v A yQ" N d M 00 ? o P+ 0 o a? 6' 08 Ul ALL THAT CERTAIN piece of parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania. BEING the same premises granted and conveyed from Earl J Brandt and Dolores V Brandt, husband and wife, unto George P Beck, by deed dated May 29, 1998, and recorded June 8, 1998 in Book 178, Page 909 BEING PREMISES: 415 4th Street New Cumberland, PA 17070 SOLD as the property of GEORGE P. BECK BEING Tax Parcel 25-25-0006-013. ./+ GACdbeck 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GEORGE P. BECK (Mortgagor(s) and Record Owner(s)) 415 4th Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-6354 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE, 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: 415 4th Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: 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 1 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL, INC. 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 CITIFINANCIAL MORTGAGE CO., INC. 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 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 415 4th Street New Cumberland, PA 17070 (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: November 10, 2009 M /h n & GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 1j TOT [ E 1 I'Y lP 2009 h,O € 2 I'll 42,. 4 7 .. , Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. GEORGE P. BECK Mortgagor(s) and Record Owner(s) 415 4th Street New Cumberland, PA 17070 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 09-6354 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. C ichael T. McKeever Attorney for plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 20 g yt1' 12 Fl'i I.2: 4; 1 4 l GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.456129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 09-6354 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. GEORGE P. BECK Mortgagor(s) and Record Owner(s) 415 4th Street New Cumberland, PA 17070 Defendant(s Term No. 09-6354 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: BECK, GEORGE P. GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 Your house at 415 4th Street, New Cumberland, PA 17070 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 $92,128.02 obtained by THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 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: 09-6354 1. The sale will be cancelled if you pay to THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE, 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. 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. You may contact the Foreclosure Resource Center: hn://www.philadell2hiafed.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 8 Irvine Row 09-6354 Carlisle, PA 17013 717-243-9400 09-6354 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 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 87793FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6354 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION f/k/a THE BANK OF NEW YORK TRUST COMPANY, N.A., Successor to JPMORGAN CHASE BANK N.A., as Trustee, Plaintiff (s) From GEORGE P. BECK (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 $92,128.02 L.L. $.50 Interest from 11/11/09 to Date of Sale per diem at $18.00 -- To Be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $162.30 Other Costs Plaintiff Paid Date: 11/12/09 Curtis R. Lon roth nota (Seal) By: REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Deputy Supreme Court ID No. 56129 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R ArPderso~i .r ~ ~' Sheriff - -' `,- ~~~ 4P1~~f' D~ 4{t~1NfJPtj~i~ r - ~ Jody S Smith ~ "~ ~ , t ,. Chief Deputy ~ ~ ~ ~ : ~ ., ~_ ._ ~ ~ ~~ I ~~ ~ ~-~ "J 3 ,at Richard W Stewart ~ ~ ~ ,~ .~ ,-" Solicitor c~~ ~ ~ ~ 7 -,.~~~~~ ~~i~~ . - _ . ~~~ t r i ~. ~, ._ . The Bank of New York Mellon Case Number vs. George P Beck 2009-6354 SHERIFF'S RETURN OF SERVICE 12/18/2009 05:03 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2009 at 1702 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Geroge P. Beck, located at, 415 Fourth Street, New Cumberland, Cumberland County, Pennsylvania according to law. 01/04/2010 01:31 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on January 4, 2010 at 1331 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: George P. Beck, by making known unto, George P. Beck, personally, at, 415 Fourth Street, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 02/12/2010 Property sale postponed to 5/5/2010. 04/15/2010 Property sale postponed to 6/2/2010. 06/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 2, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of The Bank of New York Mellon Trust Company, et. al., 14523 SW Millikan Way, Suite 200, Beavorton, OR 97005, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 824.18 SHERIFF COST: $824.18 SO ANSWERS, y.Y \~~1 June 30, 2010 RON R ANDERSON, SHERIFF app ~(.Co. . S o LL p~~ ~~ 7~ ms's ,~" a ~5~~ !c; couniySuitA Shenff, Teleosof't, Inc. Goldbeck McCafferty & McKeever BY: Michael T.1l4cI~eve~ Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. GEORGE P. BECK (Mortgagor(s) and Record Owner(s)) 415 4th Street New Cumberland, PA 17070 No. 09-63 54 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE, 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: 415 4th Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE 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: CITIFINANCIAL, INC. 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 CITIFINANCIAL MORTGAGE CO., INC. 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 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 415 4th Street New Cumberland, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 10.2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 1 09-6354 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. GEORGE P. BECK Mortgagor(s) and Record Owner(s) 415 4th Street New Cumberland, PA 17070 Defendants; Term No. 09-6354 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: BECK, GEORGE P. GEORGE P. BECK 415 4th Street New Cumberland, PA 17070 Your house at 415 4th Street, New Cumberland, PA 17070 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 $92,128.02 obtained by THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE 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 CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 09-6354 1. The sale will be cancelled if you pay to THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE, 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~/foreclosurel 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 8 Irvine Row 09-6354 Carlisle, PA 17013 717-243-9400 09-6354 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/homeownerslreal 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 homeretentionna,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 87793FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. ALL THAT CERTAIN piece of parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania. BEING the same premises granted and conveyed from Earl J Brandt and Dolores V Brandt, husband and wife, unto George P Beck, by deed dated May 29, 1998, and recorded June 8, 1998 in Book 178, Page 909 BEING PREMISES: 415 4th Street New Cumberland, PA 17070 SOLD as the property of GEORGE P. BECK BEING Tax Parce125-25-0006-013. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6354 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION f/Wa THE BANK OF NEW YORK TRUST COMPANY, N.A., Successor to JPMORGAN CHASE BANK N.A., as Trustee, Plaintiff (s) From GEORGE P. BECK (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 $92,128.02 L.L. $.50 Interest from 11/l 1/09 to Date of Sale per diem at $18.00 -- To Be Determined Atty's Comm Due Prothy $2.00 Atty Paid $162.30 Other Costs Plaintiff Paid Date: 11 /12/09 Curtis R. Lon roth not ry (Seal) By. REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Deputy Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 On November 24, 2009 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, T Known and numbered 415 4`" Street, New Cumberland more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 24, 2009 By: Real Estate C t~'tia ' " !' i,~ ~ ~ _ ( : ~ . . '~ Y,s ~ r_` , ~~ 1,~ y .~.. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22 January 29 and February 5 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Writ No. 2009-6384 Civil Bank of New York Mellon Trust Company vs. George P. Beck Atty: Michael Mckeever ALL THAT CERTAIN piece of parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania. BEING the same premises granted and conveyed from Earl J. Brandt and Dolores V. Brandt, husband and wife, unto George P. Beck, by deed dated May 29, 1998, and recorded June 8, 1998 in Book 178, Page 909. BEING PREMISES: 415 4th Street, New Cumberland, PA 17070. SOLD as the property of GEORGE P. BECK. BEING Tex Parcel 25-25-0006- 013. PROPERTY ADDRESS: 415 4th Street, New Cumberland, PA 17070. lsa Mari Coyne, Edi r SWORN TO AND SUBSCRIBED before me this 5 day of February, 2010 ~` , Notary / NOTARIAL SEAL DEBORAH A COLLINS Notory Public CARLISLE BORO, CUMBERfANp COUNTY My Commission Expires Apr 28, 2010 . The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c~he ~latriot News NOw you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /22/10 Docks Nor: 4 ~~ ~ 01 /29/10 ~ :., ~tk of Nsw 1-o~ft NNMn'hivat 02/05/10 Gompanq /!~1~~/,/' Gorge P:igeck L lL . .... .... ........... . Atty: A1lchpeh ~ilRkeever ~ ,~ al,t, Tf1AT CERTAIN p~ ~parcel`of land Sworn to and bscribed before me this 25Y'ciay f ebruary, 2010 A.D. situate.. in the Boiough of•New Cuml~rland, County of ' _ ~ / ,, ~-- Cumbaland aadState of Pamsylvanae. ' ~ ~_... _ . ~,.y t,. ( r ~ ~ ~ ~ ---~_ BEING the starve Promises aAd Notary Public ~'eY~ from. Ead J Brandt anal Dolvtes V Brent, husbaod,aad wife, unto George P<$~14 hY ~ dated May 29,1998' and ~'deSl,lune COMMONWEALTH OF PENNSYLVtihll~, 8,1998, Book I78, Page 909 _,_ BEING PIiE1H1SES: 413 4th Street Notarial Seel ~. Nee' Ctunbpfand, PA I'I070 - Sherrie L iGsner, Notary Public SOLD as the pmpetty ~G$OI2GE P. BBCR City Of Harrisburg; Dauphht riOlP^t,: HE11VG'~r Parcel?3=25-0006013. MY Commissiort E~irea Nw. 26, P]~PERIy ~IDDR-BSS: 415, 4th Stmt, New Member, Pennsylvania Association of NotarRes Cumberl~d, PA 170711 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which BANK OF NEW YOUR MELLON TRUST CO N A TR is the grantee the same having been sold to said grantee on the 2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on the 12TH day of NOV, A.D., 2009, out of the Court of Common Pleas of said (Q 355 ~~ County as of Civil Term, 2009 Number 6r3~; at the suit of BANK OF NEW YOUR MELLON TRUST CO N A TR against GEORGE P BECK is duly recorded as Instrument Number 201018173. IN TESTIMONY WHEREOF, I have hereunto set my hand and~s`eal of said office this _ day of A.D. a,F~ /0 of Deeds OMde,~