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HomeMy WebLinkAbout09-7226GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 -MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM GMAC MORTGAGE, LLC SB/M GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. BARBARA E. MCCREA ANDREW T. MCCREA Mortgagors and Record Owners 906 Magnolia Drive Enola, PA 17025 Defendants Term CIVIL A No' aQ _,laalo ?v?1Ferm CT10 R M0R7"QA(3E 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. 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. 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.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: httD://www.Dhiladelphiafed.ora/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 homeretentiona,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 87922FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is GMAC MORTGAGE, LLC S/B/M GMAC MORTGAGE CORPORATION, 3451 Hammond Avenue, Waterloo, IA 50702. 2. The names and addresses of the Defendants are BARBARA E. MCCREA, 906 Magnolia Drive, Enola, PA 17025 and ANDREW T. MCCREA, 906 Magnolia Drive, Enola , PA 17025, who are the mortgagors and record owners of the mortgaged premises hereinafter described. On June 08, 1999 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to GMAC MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1550, Page 410.. 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 June 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$139,087.14 Interest from 05/01/2009 through 09/30/2009 at 7.3750% .......................$4,299.30 Per Diem interest rate at $28.10 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,954.36 Late Charges from 06/01/2009 to 09/30/2009 .............................................$225.31 Monthly late charge amount at $56.33 Costs of suit and Title Search ......................................................................$900.00 Escrow Advance ........................................................................................ ($437.35) Property Inspection Fees ..............................................................................$191.25 Monthly Escrow amount $353.99 $151,220.01 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 Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular 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 Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $151,220.01, together with interest at the rate of $28.10, 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: T, U(b I jf,?j GOLDBECK McCAFFERTY & MCKEEV R BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Lkor014 SkOKOL , as the representative of American Home Mortgage Servicing, Inc., Successor-In-Interest to Option One Mortgage Corporation, as Attorney in Fact for 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 falsificaationto7 authorities. Date:( 1 -T_ #87922FC - BARBARA E. MCCREA and 906 Magnolia Drive Enola , PA 17025 GMAC 1` ,6 CORPORATION _ ?f-ePhan I T. MCCREA E.,X,,hibit A SCHEDULE"N' ALL Tm CaRTI?rm exact or Parael of land Situate io the Tomwhip of It 'Ot fto"Obam, County 04 CUMberland, Paansylvaaia, - particularly bowaded and described as follows to wit. BIIW " at a point on the eoutharn right oII wry lino od magnolia Drive t5o, wi4e3 at the dividing lies between Lie No. 167 and no. ice an shown on the braiaafter mentioned plan, thwAs Slag the dividing lino between Lots Ko. 167 aM No. lie So h Oa dgg"m as ,cippteee 00 ¦aoo0da Bast a distance-of 100.00, feet to a Point at do dividing line betwee?e Leta no. 150, Kb.?15, No. 367 asd'Va. 16ar thane along the dividing lips behmsen Leta Ire. lei aaA 80. 167 South 61 degreaa 00 plants. ao seeomb Kest a diseanee of 00.60 feet to a point at the dividing line betwwt Leta No. 151, Do. 155, No. 166 sod°Iqo. 167r tbme along the dividing line between LDts no. 166 eM no, 167 Worth 0! dgran be Shute. 00 eaeonde KMt a distance of 100.00, feat to a point oar the *mubern right of way lime of Kagrmlia DOfivata the m - the southarn .rigaat of way line of Ksgnoiia Drive Korth al degrass 00 rusts. 00 seconds Bast a diataece of 60.00, feet to a Point, said point boiag the Plane of 1111 1 hat 1To. 167 as abown on the Final Subdivision Plan of Penn Valley, Pillage !. Roomded in Plan Book 71, Page 105. 6,000.00 equate feat. BEMIG KNOWN AS INS Msgnob Drees UNDER snot SUBJECT b csrlclrt restrbgenc now of nooro. OEM THE SAME PREMISES w? ich frWm Vday Corp WI^ By Irdenarn haarht?faMr.dab S!,,,W., , :: day of Jun. AD,1VW Mild k* r4ed b ba f *AM traoNad In ft 08be br fBOaOQ Bf Dssd5 ':,: a ?; tr,; In and far die cou* of Cumberland Conwramealth of patnal M r* 91 l- one eadr sd? ;ba. M;?:., caw Morfpagora, in fee. ..•..rr?. of G,mh9rlrtndJ • ? ;' -• .:a.icd in the oNaw lot the raeo?dng 0f Deaft ??,?p e 0ryyg?lt*bnA Counly. 10gII?S3OMN AS i' (jI g?N??c1y.- vM, c ray head a xN of of Cdr P11rMe ? 1? E.,Xhibit 0 MCCREA, BARBARA E. BARBARA E. MCCREA 906 Magnolia Drive Enola , PA 17025 File #: 87922FC Sale date: County: Cumberland Property: 906 Magnolia Drive Enola , PA 17025 MCCREA, ANDREW T. ANDREW T. MCCREA 906 Magnolia Drive Enola , PA 17025 File #: 87922FC Sale date: County. Cumberland Property: 906 Magnolia Drive Enola , PA 17025 ACT 91 NOTICE DATE OF NOTICE: 09/16/2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP may be able to help to save Mg home. This Notice explains how the progxam 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 Counseling 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 call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call L717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notification en adjunto es de sums importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arnba. Puedes ser elegible para un prestamo por el programa Ilamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by. GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: 09/16/2009 Homeowners Name: BARBARA E. MCCREA and ANDREW T. MCCREA Property Address: 906 Magnolia Drive, Enola , PA 17025 Loan Account No.: 0165352907 Original Lender: GMAC MORTGAGE CORPORATION Current Lender/Servicer: GMAC MORTGAGE CORPORATION HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S 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 * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 1331 DAYS. IF YOU DO NOT APPLY FOR .EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling _Mencies for the county in which the Xis located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to 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 Med 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: 906 Magnolia Drive, Enola , PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 06/01/2009 thru 09/16/2009 (4 mos. at $1,480.77/month) $5,923.08 (b) Late charges from 06/01/2009 thru 09/16/2009 (4 mos. at $56.33/month) $225.32 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $6,148.40 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 $6.14&40 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to- GMAC MORTGAGE, LLC LOSS MITIGATION DEPARTMENT 3451 Hammond Avenue Waterloo, IA 50702 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the leader intends to exercise its A&ts to accelerate the mortnge 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 mortassed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If -you cure the default within the THIRTY (30) DAY period. you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the rit to cure the default and prevent the sale at any time un to one hour before the Sheriffs Sale You may do so by paving the total amount then past due plus any late or other charges then due rromnable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as suecified in writing by the lender and by pgbrmjW any other requirements under the mortaage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the We. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: GMAC MORTGAGE, LLC Address: 3451 Hammond Avenue Waterloo, IA 50702 Phone Number: 800-8504622 Fax Number: 319-236-7437 Contact: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Loss Mitigation Department Phone Number: 800-8504622 HEMAP Consumer Credit Counseling Agencies Report last updated: 9/1/2009 8:42:35 AM CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 570.602.2227 800.922.9537 CRAWFORD County Booker T. Washington Center 1720 Holland Street Erie, PA 16503 814.453.5744 CCCS of Western PA 4402 Peach Street Erie. PA 16509 888.5112227 ext 108 888.511.2227 ext 108 Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 814.337.8450 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrel, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Do" Street HaMaburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.2322207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Fran Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DAUPHIN County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.5112227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Opportunity Inc. 301 East Market Street York, PA 17403 717.424.3845 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DELAWARE County Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 215.765.1221 Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 215.389.2810 American CroM Counselling Institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 888.212.6741 Page 8 of 21 HEMAP Consumer Credit Counseling Agencies Report last updated: 9/112009 8:42:35 AM American Credit Counseling institute 175 Strafford Avenue Suite 1 Wayne, PA 19087 610.971.2210 888.212.6741 American Financial Counseling Services Inc. 175 Strafford Avenue Sidle One Wayne, PA 19087 257.228.7903 800.490.3039 American Financial Counseling Services Inc. 1080 N. Delaware Avenue Suite 200 Philadelphia, PA 19125 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 405 West Germanlown Pike Norristown, PA 19403 267.228.7903 800.490.3039 American Red Cross of Cheater 1729 Edgemont Avenue Chester, PA 19013 610.874.1484 APM 2147 North Sixth Street Philadelphia, PA 19122 215.235.6788 Carroll Park Community Council, Inc, 5218 Master Street Philadelphia, PA 19131 215.877.1157 CCCS of Delaware Valley 113 East Main Sheet 2nd Floor Norristown, PA 19401 215.583.5685 CCCS of Delawaro Valley 1001 East Lincoln Highway Suite 102 Caalesville, PA 19320 215.563.56115 CCCS of Delaware Valley 1608 Walnut Street 10th Floor Philadelphia, PA 19107 215.563.5685 CCCS of Delaware Valley 280 North Providence Road Media, PA 19063 215.563.5665 CCCS of Delaware Valley 790 E. Market St. Suite 170, Marshall Building West Chester, PA 19382 215.583.5665 CCCS of Delaware Valley 4400 North Reese Street Philadelphia, PA 19140 215.563.5665 Chester Community Improvement Project 412 Avenue of the States PO Box 541 Chester, PA 19016 610.876.8663 Diversified Community Services Dixon House 1920 South 20th Street Philadelphia, PA 19145 215.336.3541 FOB CDC 1201 West Olney Avenue Philadelphia, PA 19141 215.549.8755 Germantown Settlement 5538 Wayne Avenue Bldg C Philadelphia, PA 19144 215.849.3104 MACE 167 W. Allegheny Avenue 2nd FI Philadelphia, PA 19140 215.428.8025 Housing Partnership of Cheater County 41 West Lancaetar Ave Downingtown, PA 19335 610.518.1522 Mar6a Fellowship House 302 South Jackson Street Media, PA 19063 610.565.0434 Northwest Counseling Ssrvlca 5001 North Broad Street Philadelphia, PA 19141 215.324.7500 Page 9 of 21 HEMAP Consumer Credit Counseling Agencies Report last updated: 9/1/2009 8:42:35 AM Opportunity Inc. Two Bela Plaza Suite 300 Philadelphia, PA 19004 610.660.6687 Phil* Council For Community Advmnt 1617 John F Kennedy OW Suite 1550 Philadelphia, PA 19103 215.587.7803 800.930.4663 Urban League of Philadelphia 121 S Broad St 9th Floor Philadelphia, PA 19107 215.985.3220 ELK County FAYETTE County Action Housing, Inc 425 6th Avenue Suite 950 Pittsburgh, PA 15219 412.281.2102 800.792.2801 CCCS of Western PA 1 North Gate Square #2 Garden Center Drive Greensburg. PA 15801 888.511.2227 888.511.2227 Community Action Southwest 58 East Greene Street Waynesburg, PA 15370 724.852.2893 Northern Tier Community Action Corp. P.O. Box 389 135 West 4th Street Emporium, PA 15834 814.486.1161 ERIE County Booker T. Washington Center 1720 Holland Street Erie, PA 16503 814.453.5744 CCCS of Western PA 4402 Peach Street Erie, PA 16509 888.511.2227 ext 108 888.511.2227 ext 108 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 Voices for Independence 1107 Payne Avenue Erie, PA 16503 814.874.0064 800.838.9890 Fayette Co. Community Action Agency, Inc. 108 North Beeson Avenue Uniontown, PA 15401 724.437.6050 800.427.INFO Southwestern Pennsylvania Legal Services Inc. 45 East Main Street Suite 200 Uniontown, PA 15401 724.439.3591 Tableland Services inc. 535 East Main Street Somerset, PA 15501 814.445.9628 800.452.0148 FOREST County Warren-Forest Counties Economic Opportunity Council 1209 Pennsylvania Ave, West P.O. Box 547 Warren, PA 16365 814.726.2400 FRANKLIN County Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 717.637.3768 Page 10 of 21 F(Lrr4 , w.. e"`r 7 J? ' Y AR I i._ , 2009 0 C T L 1 Pi E?: 5 J- CAP *78.5b pM All-f 5c4a o(o ( a3a3y3 Sheriffs Office of Cumberland County R Thomas Kline FILED-OFFICE Sheriff r OF THE r,-C) P,.jn`NOTAp Ronny R Anderson ¢ Chief Deputy 2009 OCT 2$ AM 9:40 Jody S Smith Civil Process Sergeants ??ro aU Edward L Schorpp f Ei?l?,iJYl.WINJA. Solicitor GMAC Mortgage, LLC I Case Number vs. Barbara E. McCrea 2009-7226 SHERIFF'S RETURN OF SERVICE 10/22/2009 05:48 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 22, 2009 at 1748 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Barbara E. McCrea, by making known unto Andrew T. McCrea, adult in charge, at 906 Magnolia Drive, Enola, Cumberland County, Pennsylvania, 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. 10/22/2009 05:48 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 22, 2009 at 1748 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Andrew T. McCrea, by making known unto Andrew T. McCrea, personally, at 906 Magnolia Drive, Enola, Cumberland County, Pennsylvania, 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $57.50 October 23, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sheriff