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Home My WebLink About09-8077GOLDBECK 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 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MOLLY L. VOGELSONG ROBERT L. VOGELSONG Mortgagors and Record Owners 55 Glendale Drive Mechanicsburg, PA 17050 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. CIVIL ACTION: MORTGAGE 1;'f)-qr:n" nel lot: NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.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.philadelphiafed.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 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 89038FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendants are MOLLY L. VOGELSONG, 55 Glendale Drive, Mechanicsburg, PA 17050 and ROBERT L. VOGELSONG, 55 Glendale Drive, Mechanicsburg, PA 17050, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On June 13, 2007 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR COUNTRYWIDE BANK FSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#: 1998, Page 3501. The mortgage has been assigned to: BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May 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 .................................................................................. $165,121.88 Interest from 04/01/2009 through 10/01/2009 at 6.5000% .......................$5,411.44 Per Diem interest rate at $29.41 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$8,256.09 Late Charges from 05/01/2009 to 10/01/2009 .............................................$319.50 Monthly late charge amount at $53.25 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $239.85 $180,008.91 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 terns judgment in mortgage foreclosure in the sum of $180,008.91, together with interest at the rate of $29.41, 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: [77ULkaj p1 ? GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Des" Bentley , 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: O C T 3 0 2009 Destiny Bentley-Asst. Secretary #89038FC - ROBERT L. VOGELSONG 55 Glendale Drive Mechanicsburg, PA 17050 Ex. hibit A ALL THAT CERTAIN tract of land, situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron pin, four hundred and five-tenths (400.5) feet north of the centerline of Wertzville Road; thence along a dedicated right-of-way line situate twenty-five (25) feet from the centerline of Glendale Drive, as shown in the hereinafter mentioned Plan of Lots, North 9 degrees 50 minutes 30 seconds East, two hundred twenty-three and thirty-eight hundredths (223.38) feet to an iron pin at the corner of other land now or formerly of Lester Vogelsong and wife, as shown in the hereinafter mentioned Plan of Lots; thence along said other lands now or formerly of Lester Vogelsong and wife, the following courses and distances, South 79 degrees 59 minutes 26 seconds East, two hundred twenty-one and thirty-nine hundredths (221.39) feet to an iron pin; thence South 12 degrees 23 minutes 25 seconds West, two hundred twenty-three and fifty-four hundredths (223.54) feet to an iron pain; thence North 80 degrees West, two hundred eleven and forty-five (211.45) feet to an iron pin, situate four hundred and five-tenths (400.5) feet North of the centerline of Wertzville Road, the place of BEGINNING. BEING THE SAME PREMISES which Lester L. Vogelsong and Helen M. Vogelsong, his wife, by their deed dated October 24, 1984 and recorded November 2, 1984 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Book Y-30, Page 979 granted and conveyed unto Robert Lee Vogelsong and Molly L. Vogelsong, his wife, Mortgagors herein. Exhibit (B ACT 91 NOTICE DATE OF NOTICE: 10/15/2009 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 your home This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the 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 (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com 1 Date: 10/15/2009 To: MOLLY L. VOGELSONG Homeowners Name: MOLLY L. VOGELSONG and ROBERT L. VOGELSONG Property Address: 55 Glendale Drive, Mechanicsburg, PA 17050 Loan Account No.: 169633979 Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR COUNTRYWIDE BANK FSB Current Lender/Servicer: BAC HOME LOANS SERVICING, L.P. 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 (33) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM 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 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: 55 Glendale Drive, Mechanicsburg, PA 17050 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 05/01/2009 thru 10/15/2009 (6 mos. at $1,304.88/month) $7,829.28 (b) Late charges from 05/01/2009 thru 10/15/2009 (6 mos. at $53.25/month) $319.50 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $8,148.78 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 $8.148.78, 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: Attention: Act Letter Department BAC HOME LOANS SERVICING LP c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 HomeRetention@goldbecklaw. com 866-413-2311 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 brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due lp us any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any oth er costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: BAC HOME LOANS SERVICING LP Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 972-526-6000 Fax Number: 817-230-6811 Contact Person: Brady Mcdermott Email: PHFA.Program@bankofamerica.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 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. BEHALF. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR * 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 Person: Brady Mcdermott Phone Number: 972-526-6000 HEMAP Consumer Credit Counseling Agencies Report last updated: 9/30/2009 1:18:45 PM CCCS of Northeastern PA Loveship, Inc. 401 Laurel Street 2320 North 5th Street Pittston, PA 18640 Harrisburg, PA 17110 570.602.2227 717.232.2207 800.922.9537 Maranatha CRAWFORD County 43 Philadelphia Avenue Waynesboro, PA 17268 Booker T. Washington Center 717.762.3285 1720 Holland Street Erie, PA 16503 PHFA 814.453.5744 211 North Front Street Harrisburg, PA 17110 CCCS of Western PA 717.780.3940 4402 Peach Street 800.342.2397 Erie, PA 16509 888.511.2227 ext DAUPHIN County 108 888.511.2227 ext CCCS of Western PA 108 2000 Linglestown Road Harrisburg, PA 17102 Center for Family Services, Inc. 888 511 2227 213 Center Street 888.511.2227 Meadville, PA 16335 814.337.8450 Community Action Commission of Captial Region 1514 Derry Street Greater Erie Community Action Committee Harrisburg, PA 17104 18 West 9TH Street 717.232.9757 Erie, PA 16501 814.459.4581 Loveship, Inc. 2320 North 5th Street Shenango Valley Urban League, Inc. Harrisburg, PA 17110 601 Indiana Avenue 717.232.2207 Farrell, PA 16121 724.981.5310 Opportunity Inc. 301 East Market Street St. Martin Center York , 17403 1701 Parade Street 717.4244. .3645 Erie, PA 16503 814.452.6113 PHFA 211 North Front Street CUMBERLAND County Harrisburg, PA 17110 Adams County Interfaith Housing Authority 717.780.3940 40 E High Street 800.342.2397 Gettysburg, PA 17325 DELAWARE County 717.334.1518 Acorn Housing Corporation CCCS of Western PA 846 North Broad Street 2000 Linglestown Road Philadelphia, PA 19130 Harrisburg, PA 17102 215.765.1221 888.511.2227 888.511.2227 Advocates for Financial Independence 202 East Hinkley Avenue Community Action Commission of Captial Region Ridley Park, PA 19078 1514 Derry Street 215.389.2810 Harrisburg, PA 17104 717.232.9757 American Credit Counseling Institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 888.212.6741 Page 8 of 21 ACT 91 NOTICE DATE OF NOTICE: 10/06/2009 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) mgy be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling A eg_nc. 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 ,717 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com Date: 10/06/2009 Homeowners Name: ROBERT L. VOGELSONG Property Address: 55 Glendale Drive, Mechanicsburg, PA 17050 Loan Account No.: 169633979 Original Lender: BAC HOME LOANS SERVICING, L.P. Current Lender/Servicer: BAC HOME LOANS SERVICING, L.P. 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 (33) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM 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 criteri a established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) 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: 55 Glendale Drive, Mechanicsburg, PA 17050 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 05/01/2009 thru 10/06/2009 (6 mos. at $1,304.88/month) $7,829.28 (b) Late charges from 05/01/2009 thru 10/06/2009 (6 mos. at $53.25/month) $319.50 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $8,148.78 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 $8,148.78, 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: Attention: Act Letter Department BAC HOME LOANS SERVICING LP c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 HomeRetenti on@goldbecklaw. com 866-413-2311 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 brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY Period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus anv late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing anv other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: BAC HOME LOANS SERVICING LP Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 972-526-6000 Fax Number: 817-230-6811 Contact Person: Brady Mcdermott Email: PHFA. Program@b ankofamerica. com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the 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 Person: Brady Mcdermott Phone Number: 972-526-6000 HEMAP Consumer Credit Counseling Agencies Report last updated: 9/30/2009 1:18:45 PM CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 570.602.2227 800.922.9537 CRAWFORD County Booker T. Washington Center 1720 Holland Street Erie, PA 16503 814.453.5744 CCCS of Western PA 4402 Peach Street Erie, PA 16509 888.511.2227 ext 108 888.511.2227 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 Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DAUPHIN County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Opportunity Inc. 301 East Market Street York, PA 17403 717.424.3645 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DELAWARE County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 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 Credit Counseling Institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 888.212.6741 Page 8 of 21 11 tI FlLED-0r-?u;.. RICTt',"",li1j- CF it Pt 2019 ""V 20 FIl 12: 5 9 eK°u so?ys? ?- a a a4as SI`ILF~IFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Fi~.~} ~~ "'~ r 3~,,~, Jody S Smith ~o~-~tp ct t~uu,bpr~iry~ !t)f ~i ;"~~jls~ ;,'°~~~~ Chief Deputy ~~ ~- ~{, 2J~~ Jilit ~() ~` ~: ~ >,:. , 3 ,. Richard W Stewart ''~'' SoilCltor C~fF GE ": ~ 'Nf: $!FERIFfi i~'~rfy,gr t .l ~ i ,..'VI ~~ 1y 3 1~? BAC Home Loans Servicing, LP vs. Case Number Molly L. Vogelsong (et al.) 2009-8077 SHERIFF'S RETURN OF SERVICE 04/01/2010 06:08 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 1805 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 Molly L. Vogelsong & Robert L. Vogelsong, located at 55 Glendale Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 04/01/2010 06:08 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 1805 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: Molly L. Vogelsong, by making known unto, Molly Vogelson, personally, at 55 Glendale Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1 the same. 04/01/2010 06:08 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 1805 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: Robert L. Vogelsong, by making known unto, Robert Vogelson, personally, at 55 Glendale Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 06/02/2010 Property sale postponed to 7/7/2010. 06/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Michael McKeever on 6/8/10 SHERIFF COST: $894.35 June 28, 2010 SO ANSW'ER"S~, RON R ANDERSON, SHERIFF a .oa ~ - ~. . ,~ LL~od ~-~ >~ ~aG ~ ~ ~~f ~S (cj GountyS~ite Shenff. Teleosoft. Inc. t ~- *. ~, .~ Goldbeck McCafferty & McKeever BY: Michael T.wlcIw~ever Attorney I.D. ir56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MOLLY L. VOGELSONG ROBERT L. VOGELSONG (Mortgagor(s) and Record Owner(s)) 55 Glendale Drive Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVII, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 09-8077 AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, 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: 55 Glendale Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): MOLLY L. VOGELSONG 55 Glendale Drive Mechanicsburg, PA 17050 ROBERT L. VOGELSONG 55 Glendale Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: MOLLY L. VOGELSONG 55 Glendale Drive Mechanicsburg, PA 17050 ROBERT L. VOGELSONG 55 Glendale Drive Mechanicsburg, PA 17050 3. Name and last Imown 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 IG f Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisbwg, PA 17105-2675 UPPER ALLEN TOWNSHIP 100 Gettysbwg Parkway Mechanicsbwg, PA 17055 MBNA AMERICA BANK NA 655 Paper Mill Road Mail Stop 1411 Wilmington, DE 19884 CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013 DISCOVER BANK P.O. Box 7112 Dover, DE 19903 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, AZ 85216 PNC BANK DELAWARE 9321 Olive Boulevard Street Louis, MO 63132 MBNA AMERICA BANK NA C/O PHILIP C WARHOLIC ESQ 4660 TRINDLE RD STE 300 CAMP HILL, PA 17011 DISCOVER BANK C/O EDWARD STOCK ESQ 804 WEST AVENUE JENKINTOWN, PA 19046 FORD MOTOR CREDIT COMPANY C/O CHARLENE A TAYLOR ESQ 1 PENN CTR 1617 JFK BLVD #935 PHILADELPHIA, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: 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. r~ TENANTS/OCCUPANTS 55 Glendale Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) 1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. 1 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: January 4 ?010 ~ GOLDBECK Mc A TY McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 09-8077 GOEDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 2]5-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-3 5 Plano, TX 75024 Plaintiff vs. MOLLY L. VOGELSONG ROBERT L. VOGELSONG Mortgagor(s) and Record Owner(s) 55 Glendale Drive Mechanicsburg, PA 17050 Defendants Term No. 09-8077 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: VOGELSONG, ROBERT L. ROBERT L VOGELSONG 55 Glendale Drive Mechanicsbwg, PA 17050 Yow house at 55 Glendale Drive, Mechanicsbwg, PA ] 7050 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $183,682.16 obtained by BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 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: 09-8077 l . The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. To fmd 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 attomey 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 attomey). 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 fmd 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/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 Carlisle, PA 17013 09-8077 Resources available for Homeowners in Foreclosure ACT NOW! Even though your ]ender (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 7l 7-243-9400. 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 as~x. 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 homeretentionng_aldbecklaw.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 89038FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract of land, situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron pin, four hundred and five-tenths (400.5) feet north of the centerline of Wertzville Road; thence along a dedicated right-of--way line situate twenty- five (25) feet from the centerline of Glendale Drive, as shown in the hereinafter mentioned Plan of Lots, North 9 degrees 50 minutes 30 seconds East, two hundred twenty-three and thirty-eight hundredths (223.38) feet to an iron pin at the comer of other land now or formerly of Lester Vogelsong and wife, as shown in the hereinafter mentioned Plan of Lots; thence along said other lands now or formerly of Lester Vogelsong and wife, the following courses and distances, South 79 degrees 59 minutes 26 seconds East, two hundred twenty-one and thirty-nine hundredths (221.39) feet to an iron pin; thence South 12 degrees 23 minutes 25 seconds West, two hundred twenty-three and fifty-four hundredths (223.54) feet to an iron pin; thence North 80 degrees West, two hundred eleven and forty-five (211.45) feet to an iron pin, situate four hundred and five- tenths (400.5) feet North of the centerline of Wertzville Road, the place of BEGINNING. BEING THE SAME PREMISES which Lester L. Vogelsong and Helen M. Vogelsong, his wife, by their deed dated October 24,1984 and recorded November 2,1984 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Book Y-30, Page 979 granted and conveyed unto Robert Lee Vogelsong and Molly L. Vogelsong, his wife, Mortgagors herein. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 55 Glendale Drive Mechanicsburg, PA 17050 SOLD as the property of MOLLY L. VOGELSONG and ROBERT L. VOGELSONG TAX PARCEL #38-OS-0435-020A ..' 1 ' 09-8077 1~ GOLOBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 70l Market Street Philadelphia, PA 19106 215-825-6318 Attomey for Plaintiff BAC HOME LOANS SERVICING. L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MOLLY L. VOGELSONG ROBERT L. VOGELSONG Mortgagor(s) and Record Owner(s) SS Glendale Drive Mechanicsburg, PA 17050 Defendants; Term No. 09-8077 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: VOGELSONG, MOLLY L. MOLLY L. VOGELSONG 55 Glendale Drive Mechanicsbwg, PA 17050 Yow house at 55 Glendale Drive, Mechanicsbwg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $183,682.16 obtained by BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 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: o9-so~~ 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call ow 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 yow 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, yow property will be sold to the highest bidder. You may fmd 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 yow property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd 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 yow 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 Forecloswe Resource Center: http://www.philadelphiafed.orglforecloswe/ 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 Carlisle, PA 17013 09-8077 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 l -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 httn:/lwww. hp fa.org/consumers/homeowners/real aspx. S). 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, ar payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 89038FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract of land, situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron pin, four hundred and five-tenths (440.5) feet north of the centerline of Wertzville Road; thence along a dedicated right-of--way line situate twenty- five (25) feet from the centerline of Glendale Drive, as shown in the hereinafter mentioned Plan of Lots, North 9 degrees 50 minutes 30 seconds East, two hundred twenty-three and thirty-eight hundredths (223.38) feet to an iron pin at the comer of other land now or formerly of Lester Vogelsong and wife, as shown in the hereinafter mentioned Plan of Lots; thence along said other lands now or formerly of Lester Vogelsong and wife, the following courses and distances, South 79 degrees 59 minutes 26 seconds East, two hundred twenty-one and thirty-nine hundredths (221.39) feet to an iron pin; thence South 12 degrees 23 minutes 25 seconds West, two hundred twenty-three and fifty-four hundredths (223.54) feet to an iron pin; thence North 80 degrees West, two hundred eleven and forty-five (211.45) feet to an iron pin, situate four hundred and five- tenths (400.5) feet North of the centerline of Wertzville Road, the place of BEGINNING. BEING THE SAME PREMISES which Lester L. Vogelsong and Helen M. Vogelsong, his wife, by their deed dated October 24,1984 and recorded November 2,1984 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Book Y-30, Page 979 granted and conveyed unto Robert Lee Vogelsong and Molly L. Vogelsong, his wife, Mortgagors herein. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 55 Glendale Drive Mechanicsburg, PA 17050 SOLD as the property of MOLLY L. VOGELSONG and ROBERT L. VOGELSONG TAX PARCEL #38-OS-0435-020A WRIT OF EXECUTION and/or ATTACHMENT COMMONW)ALTH OF PENNSYLVANIA) NO 09-8077 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP, f/k/a COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From MOLLY L. VOGELSONG and ROBERT L. VOGELSONG (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 $183,682.16 L.L. $.50 Interest from 1/5/10 to Date of Sale per diem at $29.41 -- To be Determined Atty's Comm % Due Prothy $Z.00 Atty Paid $172.00 Other Costs Plaintiff Paid Date: 1/OS/10 (Seal) REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 David D. Buell, rothonotary By: Deputy Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, Known and numbered as, 55 Glendale Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: ~(~~ eal Estate Coordinator b Z X01 d 9- Ntf C 6i0Z ~i' ~~jj k3NS 3~!I ~~~ ~ ~I~_, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law 3ournal, 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: April 16, April 23, and Apri130, 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. Lis Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 30 da of Aril 2010 Notary NOTARIAL SEAL DEBORAH A COILINS NoUry PubNc CARLISLE BOROUGH, CUM9ERLANO COUNTY M~- Commfsslon ExpitN Apr 26, 2014 wit lls. ~00~-16Y1"1 Citli BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP vs. Molly L. Vogelsong Robert L. Vogelsong Atty: Michael McKeever ALL THAT CERTAIN tract of land, situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron pin, four hundred and five-tenths (400.5) feet north of the centerline of Wertzville Road; thence along a dedicated right- of-way line situate twenty-five (25) feet from the centerline of Glendale Drive, as shown in the hereinafter mentioned Plan of Lots, North 9 de- grees 50 minutes 30 seconds East, two hundred twenty-three and thirty- eight hundredths (223.38) feet to an iron pin at the comer of other land now or formerly of Lester Vogelsong and wife, as shown in the hereinafter mentioned Plan of Lots; thence along said other lands now or formerly of Lester Vogelsong and wife, the follow- ing courses and distances, South 79 degrees 59 minutes 26 seconds East, two hundred twenty-one and thirty- nine hundredths (221.39) feet to an iron pin; thence South 12 degrees 23 minutes 25 seconds West, two hundred twenty-three and fifty-four hundredths (223.54) feet to an iron pin; thence North 80 degrees West, two hundred eleven and forty-five (211.45) feet to an iron pin, situate four hundred and five-tenths (400.5] feet North of the centerline of Wertz- ville Road, the place of BEGINNING. BEING THE SAME PREMISES which Lester L. Vogelsong and Helen M. Vogelsong, his wife, by their deed dated October 24, 1984 and recorded November 2,1984 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Book Y-30, Page 979 granted and con- veyed unto Robert Lee Vogelsong and Molly L. Vogelsong, his wife, Mortgagors herein. .~..,.~,...,.-.raa.~,:.......~.... . :z yi; h t .,. ,. ~, ~.. ,a .,w= .... ~.. ~ .. ,..,,+~. , . ,. The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, ~'A 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c71~e ~llahiot 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: 04/16/10 04/23/10 ~.,< ~ _ 04/30/10 .:2~-~~! ... ....... ..---~ ~~ Sworn to.~n subscribed befor `; this 8 ay of May, 2010 A.D. ~ ~~ ~~t~.~~ ,~~ ~ ~ -- Notary Public -- ~OMMONWLgl.7~ pp pENN5YLVANJq Noteri~l Sal Sherrie 1. Klsner, Nolery Publk Lower Paxton'rwp., DauphM County r'h' ComnMSSion r'e6 Nov. 26, 2011 Member, AennsyNanla A~sociatlon or Notaries wry ao. zoo~orr ctvH Term BAC Home Loans Servicing, LP FpUA Countrywide Home t.oans Setvlcing, LP Vs. Molly 4. Vogelsong Robeirt ~L. Vogelsong Arty: Mlchaet McKeever ALLTHAT CERTAINtract of land, situate inthe Township of Silver Spring, County of Cumberland and State of Penasylyania; bolmded and described as foliows, to wit; BEGWN4!IG at an iron pin,,four 4undred end five-tenths (440.5) feet north of the centerline of Wertzville""Road; thence along a dedicated rig~t- of-way line situate twenty-five (25) feet from the centerline of Glendale Drive, as shown in u the hereinafter mentioned Plan of Lots, North 9 degrees 50 minutes 34secoads East, two hundred twenty-three andthittyeighthundredths (223.38) fat to an iron pin az the comer of other land now or formerly of.Lester Vogelsong and w~'e, as shown in the hereinafter mantios~ed Plan of Lots; thence along said other lands now a formerly of Lester VogeIsong and wife, the following courses and distances, South 79 degltes 59 minutes 26 seconds East, two hundred twenty-one aced thitty- nine hundredths (221,39)-.fat to an iron pin; thence South 12 degroes 23 minutes 25 seconds West, two hundred twentythtee and fifty-four hundredths (223.54) feet to an iron pio; thence North 80. degrees West; two hunted eleven and forty-five (ZIi.45) feet to an imn pin, situate four hundredand, free-tenhs (400.5) feet North of the centeline of Wentzville Road, theplace of BEGINNING. BEING THE SAME PREd~1ISES which Castes L. Vogelsong and Helen M. Vogelsong; his wife, by their deed date October X4,1984 and recorded Novemba' 2,1984 in the Office of rho Reootder of Deeds of Cumberland Cotmty,. Peonsylwa»ia, in Deed Book Y 30, Page 974 gtaeted aced aato Robert La Vogelsopg aodblolly L.Yo¢i9ong, tiffs wife, Mortgages herein. GOLDBECK WCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I . D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 -Attorney-for, Plaintiff BAC HOME LOAN'S SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano TX 75024 Plaintiff vs. MOLLY L. VOGELSONG ROBERT L. VOGELSONG 55 Glendale Drive Mechanicsburg, PA 17050 Defendant(s) PRAECIPE TO VACATE JUDGMENT TG 7"11:E PF )THOTJOTA.RY: doto AOC6a3-' 0" d ; co No. 09-8077 Fi n(i i-y vac,?te the judgment upon payment Df your cosh r.1 }r --L '_U- MICHAEL T. MC'KEEVER., ESQUIFE 4 0o .Op P f_s Axr" ef 546184 i ?g7188 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY GOLDBECK WCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney 1 D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia. PA 19106-1532 215-825-6121 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive P'T,X C-35 Plano. TX 75024 aoiv AO6 a-3 pv ,9.o,a IN THE COURT OF COlVI ION PLEAS OF CUMBERLAND O )LINTY Plaintiff Vs. No. 09-8077 MOLLY L. VOGELSONG ROBERT 1. VOGELSONG 55 Glendale Drive Mechanicsbur(y. PA 17050 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kind],,,,, mark the above case Discontinued and Ended upon payment of your costs only. Michael T. McKeever, Esquire Attorney for Plaintiff