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HomeMy WebLinkAbout10-2240GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. M.CKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 Plaintiff VS. KATHLEEN P. FLANNERY Mortgagor and Record Owner 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant 2910 AN -5 19 PEiyk,ayY--'V 10A OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term tb -AA40 N1 CIVIL AC-ff6N: V0RTGAGE I&1 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 `Z ga.00 P4S AY'rl 5&q usq 01-QR 891 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.orp/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 homeretentionkgoldbecklaw.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 96287FC. 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 FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES, 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17101. 2. The names and addresses of the Defendant is KATHLEEN P. FLANNERY, 925 Greenbriar Drive, Mechanicsburg, PA 17050, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On April 30, 1992 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to CENTRAL PENNSYLVANIA SAVINGS ASSOCIATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#: 1066, Page 79. The mortgage has been assigned to: FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 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"). 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 ....................................................................................$35,563.59 Interest from 05/01/2009 through 03/31/2010 at 7.5600% .......................$2,502.45 Per Diem interest rate at $7.47 Reasonable Attorney's Fee .................................................................$2,000.00 Late Charges from 06/01/2009 to 03/31/2010 .............................................$334.10 Monthly late charge amount at $33.41 Costs of suit and Title Search (Estimated) ...................................................$900.00 Escrow .......................................................................................................... $550.61 Monthly Escrow amount $170.84 $41,850.75 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required. time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $41,850.75, together with interest at the rate of $7.47, 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 S*riff's Sale of the Property. By: BECK MCCAFFERTY &MCKEEVER Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF VERIFICATIQN I, , 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: #96287FC - KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 Prepared by: U.S. Bank National Association c/o PHFA-Legal Division 211 North Front Street, P.O. Box 8029 Harrisburg, Pennsylvania 17105-8029 717-780-3845 or 1-800-346-3597 ext. 3845 Return to: same as above Property Parcel Number: 38161064030 Above space Is intentionally left blank for recording data ASSIGNMENT OF MORTGAGE For value received, PENNSYLVANIA HOUSING FINANCE AGENCY (" PHFA" ), with offices located at 211 North Front Street, Harrisburg, PA 17101 does hereby grant, sell, convey, assign and deliver unto FEDERAL NATIONAL MORTGAGE ASSOCIATION (FNMA), with offices located at 3900 Wisconsin Avenue, N.W., Washington, D.C. 20016-2899, its successors and assigns, the following described Mortgage, together with the Note secured thereby: Name of Original Mortgagor(s): KATHLEEN P. FLANNERY Secured by the real property located at: 925 GREENBRIAR DRIVE, MECHANICSBURG, PA 17050 Tax Parcel Identification Number: 38161064030 Municipality: MECHANICSBURG Original Principal Amount of Mortgage: $95,000.00 County Recorded in: CUMBERLAND Mortgage Recording Date: MAY 11, 1992 Record Book 1066 Page 79 Last Assignment to: Pennsylvania Housing Finance Agency Record Book 418 Page 373 IN WITNESS WHEREOF, the undersigned has caused this Assignment of Mortgage to be executed by its duly authorized officer. DATED: NOVEMBER 13, 2009 PENNSYLVANIA HOUSING FINANCE AGENCY Series: I " VIA ot", vo- 11 let - PHFA Anthony J. J n Director of Acco ting an Loan Servicing COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF DAUPHIN On this, the day of ? 15AV X009, before me, the undersigned officer, personally Anthony Julian, Director of Accounting and Loan Servicing, an authorized officer of the Pennsylvania Housing Finance Agency, and acknowledged that he, being authorized to do so, executed the foregoing instrument for the purposes therein contained. In witness whereof, I have hereunto set my hand and official seal. CERTIFICATE OF RESIDENCE hereby certify that the principal place of business and complete post office address o as follows, AND AFTER RECORDATION, THIS ASSIGNMENT IS TO BE MAILED TO: FEDERAL NATIONAL MORTGAGE ASSOCIATION (FNMA) c/o PENNSYLVANIA HOUSING FINANCE AGENCY Accounting and Loan Servicing Division 211 North Front Street Harrisburg, PA 17101 J6? Authoriz Notary Public ti' ^n UPMA_A[ TFi OF PENNSYLVANIA Notarial Seal Kimberley A, Av,, Notary Public CsY ? tiarrislxara, ?ai> ?y ttAyCArnrv ?M r,?tres.lan.t5,2011 on rat of Notaries ExthibitA searmixua at a Point In the Ke9ters line of geembriar Drive (50 feet via*), which sald polat is in the division llrre b*t GQft bOts M03. 99 and 100 an the harain4fter mentioned Plan of LOtst thpncs extending along the western lino oEOte*nbrlar Ocivo, South LO degrees 18 r#lautas Cant 101.0 feet to a ,point in the division line between LOM pi and 99 on acid Platt; thence along the divialan 111 batwtom Lots Nos. 9e and 99 an said Plaal thence slang the aieisiom line between Coto Was. 98 and 99 South 79 degrees 92 minrtew Hest 141.0 fact to a loipL In ner thetl?ift& of foreatly lands o:tht10 deegerees lghernae minutes wat 107.0 Eeeh to A Point in the division line between TAts 99 and 100 on 4410 V1an0 aforameatAon®dt tbence along the division line between Lola 99 anA 20a Worth 79 dogreen 42 mivgtas Cast 141.a fart to a point in the w*ateirn Sine of Grsenb%jac Drive, aforementioned, at the Volat and place of RMIN INC. BURC Lot go. 99 on Flan N4. 1 of Bunker Bill$I vbiak aaU plan 1s coverded in the Cumberland Cvantj ReCOGe OK19 Office in Plan Book M. 22, page 101. NRVlvc tbareon created s dxo111ng knOWn ana numbatld nit 923 peeonbsiar Drive, electtat?ia4hur4, pennapl?atnia. 131IM9 THE MP VIMM7S" WlHxCB tiele 0. Ming*ft and Darla R, Wingert, husband and wife, panted and aonveted ant* lathlee:n P. rjAonerYr single moan, by deed intending to be reecP0*d simuthane0041y herewith. Eytohi6it B Date: 8/06/2009 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help 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 guestions, 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 an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT691 LR/dwidocs/ALSW . HOMEOWNER'S NAME(S): KATHLEEN P. FLANNERY PROPERTY ADDRESS: 925 GREENBRIAR DR MECHANICSBURG, PA 17050-1916 LOAN ACCOUNT NO.: 52373 CURRENT LENDER/SERVICER: Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 15051 Harrisburg, PA 17105-5057 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 HOMEOWNERS' 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 Consumer Credit Counseling Agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. H 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 set forth at the end of this Notice. It is only necessary to schedule one 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 Homeowners' Emergency Mortgage Assistance Program. To do so you must fill out, sign and file a completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated Consumer Credit Counseling ACT691 LR/dtrndocs/ALSW Agencies listed at the end of this Notice. Only Consumer Credit Counseling Agencies have applications for the Program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH 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: 925 GREENBRIAR DR, MECHANICSBURG, PA 17050-1916, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months June, 2009 thru the first of August, 2009 in the amount of $2,517.00 plus late charges that have accrued in the amount of $66.82. THE TOTAL AMOUNT DUE IS $2,583.82. This includes all payments, fees and expenses due, less any funds we are holding in suspense. 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 $2,583.82 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: PENNSYLVANIA HOUSING FINANCE AGENCY 211 N FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105-5057 ACT691 LR/dtmdocs/ALSV/ IF YOU DO NOT CURE THE DEFAULT-- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' 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 any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth In this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFFS SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately three months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 717-780-3804 (FAX) Contact Person: KIMBERLEY AYALA Counseling Agencies: In addition to mailing Appendix B, Notice of Face-To-Face Meeting, please notify PHFA (when we are the first lien holder) of the face-to-face meeting and pending submission of application for HEMAP assistance by sending an e-mail to: Kayala@phfa.org. If you do not have access to e-mail, please call Kim Ayala at 717-780-1815 and advise of the face-to-face meeting. 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. (This does not apply if your mortgage was originated under the Home Start Program.) ACT691 LR/dtrndocs/ALSV/ 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY PHFA CCCS of Western PA 211 North Front Street 2000 Linglestown Road Harrisburg, PA 17110 Harrisburg, PA 17102 717.780.3940 886.511.2227 Community Action Commission of Capital Region Maranatha 1514 Derry Street 43 Philadelphia Avenue Harrisburg, PA 17104 Waynesboro, PA 17268 717.232.9757 717.762.3285 Adams County Interfaith Housing Authority Loveship, Inc. 40 E High Street 2320 North 5th Street Gettysburg, PA 17325 Harrisburg, PA 17110 717.334.1518 717.232.2207 ACT691 LR/dtmdocs/ALSW SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ~;~F~~ ,. rr` i:'~° Sheriff ~ ',~~ ~~~4ili~i o 17~~tL t t~ fr la;b Jody S Smith ~„ ,,_ Chief Deputy Z~~Q ~;~ ~„1 ~ ~-;ti `~` ~~ Edward L Schorpp ~~~~ ~~ ~ - ;t ~~~-~; Solicitor a ~~: .~ ..-. ,,rt ~u~'~'j~,~. Federal National Mortgage Association Case Number vs. 2010-2240 Kathleen P. Flannery SHERIFF'S RETURN OF SERVICE 04/08/2010 05:34 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 8, 2010 at 1734 hours, he served a true copy of the within Complaint in Mortgage Foreclosure upon the within named defendant, to wit: Kathleen P. Flannery, by making known unto herself personally, at 925 Greenbriar Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. _ L~~.~ NOAH CLINE, DEPUTY SHERIFF COST: $37.00 April 09, 2010 SO ANSWERS, "`"` RON R ANDERSON, SHERIFF .~rua'ySuRr She `I, 7e,ecs~ti. Irn;. In the Court of Common Pleas of Cumberland County FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 Plaintiff vs. KATHLEEN P. FLANNERY (Mortgagor(s) and Record Owner(s)) 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant(s) PRAECIPE FOR JUDGMENT No. 10-2240 CIVIL TERM N ca s ° -~ zx; c, ~ r .- E- - xy '~ w ~ ; ~ ~ rn ^ C? c THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against KATHLEEN P. FLANNERY by default for want of an Answer. Assess damages as follows: Debt Interest from 05/28/2010 to Date of Sale per diem at $7.47 Total (Assessment of Damages attached) $42,685.04 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default o d and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: GOLDBECK MCCAFFERTY & MCKEEVER Mic 1 McKeever Pa. ID 56129 G McCafferty Pa. ID 42386 Asa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa ID 27615 Attorneys for Plaintiff AND NOW oZ ~~ p2~/O ,Judgment is entered in favor of FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES and against KATHLEEN P. FLANNERY by default for want of an Answer and damages assessed in the sum of $42,685.04 as per the above certification. othonotary ~I~•oo Pp~Tt~! ~ 5.035 12~ a~3oly No~Ftce~.~A•~ac' Rule of Civil Procedure No. 236 -Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CNIL ACTION -LAW FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 Plaintiff No. 10-2240 CIVIL TERM vs. KATHLEEN P. FLANNERY (Mortgagors and Record Owner(s)) 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant(s) THIS LAW FIItM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. T~Owid D. 1~~tl Proth otary By: Deputy If you have any questions concerning the above, please contact: (o/a//O Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, KATHLEEN P. FLANNERY, is about unknown years of age, that Defendant's last known residence is 925 Greenbriar Drive Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: ` TIN BOSCHETTI VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, KATHLEEN P. FLANNERY, is about unknown years of age, that Defendant's last known residence is 925 Greenbriar Drive Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: ~J~ TINA BOSCHETTI GOLDBECK McCAFFERT'Y & McKEEVER BY: Michael T. McKeever Attorney LD. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATII A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 Plaintiff vs. KATHLEEN P. FLANNERY (Mortgagor(s) and Record owner(s)) 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 10-2240 CIVIL TERM Please enter Judgment in favor of FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES, and against KATHLEEN P. FLANNERY for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complain um of $42,685.04. By: G CK MCCAFFERTY & MCKEEVER Mich el McKeever Pa. ID 56129 ~3a~McCafferty Pa. ID 42386 a Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David. Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 and that the name(s) and last known address(es) of the Defendant(s) is/are KATHL EN P. FLANNERY, 925 Greenbriar Drive Mechanicsburg, PA 17050; By: GOLDBECK MCCAFFERTY & MCKEEVER Mi ael McKeever Pa. ID 56129 G McCafferty Pa. ID 42386 isa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 05/01/2009 through 05/27/2010 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 2 X $170.84 Escrow AND NOW, this aA~ day of ~,c,y~ $35,563.59 $2,928.24 $2,000.00 $400.92 $900.00 $341.68 $550.61 $42,685.04 By: GOLDBECK MCCAFFERTY & MCKEEVER Mic ael McKeever Pa. ID 56129 G McCafferty Pa. ID 42386 isa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 2010 damages are assessed as above. ~( o Pro PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff P.R.C.P 3180-3183 ~ o ~ ° c_ rn~ c ~~ z r~ U% `~° ~[.l N -~ ~ 3 .-11. A ~ w FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 Plaintiff vs. KATHLEEN P. FLANNERY Mortgagor(s) and Record Owner(s) 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 10-2240 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: O Amount Due ~a~-. oo ~~ Ar'l $rf . 00 ~F- Interest from ga.00 N 05/28/2010 to Date of fir{, Op ~~ Sale per diem at $7.47 a.so ~, (Costs to be added) Ila9.50 ~ PD A7)`1 $42,685.04 By: ~a. oo ~(o `50 I.L a~ 53'1035 P.,Eu~.~!-o~~~P GOLDBECK MCCAFFERTY & MCKEEVER M' hael McKeever Pa. ID 56129 ~ary McCafferty Pa. ID 42386 isa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff w a Ar ~z 0 w~ 'o ~ U U ~ ~-~o N (~ oa o~ z~ W x H z ¢~ ~w o~ H ¢c~~ o~~" ~~H Wwp w Paz a F- Q ~z~ ~ Q 0 003 QOM zHx ao~ wo wv z 0 F ~ c o W ~~ ~o >C W °~ o ~. ~~~a w~•~, ~ z~~~ 3 w ,-. w ~ C7 '~ x a~~~ x N U V O A ~-~~~ ~ ~ ~ a 0 W ~. a ~ ~ ~~ ~ ~~ U (~ w ~~ ~ O ~~ ~ IQ ~, ~ ~, ~U U ~ O ~_ ~~v]Q~cNn ~~ 'ate ~o~~~ ~Vr rN ~ N ~ iG rG O ~ N x ~ ;o a ~o b ~ ~ ~~ ALL THAT CERTAIN house and lot of ground situate in the Township of Silver spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the western line of Greenbrier Drive (50 feet wide), Which said point is in the division line between Lots NoS8 99 and 100 on the hereinafter mentioned Plan of Lots; thence extending along the western line of Greenbrier Drive, south 10 degrees 18 minutes East 107.0 feet to a point in the division line between Lots 98 and 99 on said Plan; thence along the division line between Lots Nos. 98 and 99 South 79 degrees 42 minutes West 141.0 feet to a point in the line of land now or formerly of Garret & Shelley; thence along the line of said last mentioned lands, North 10 degrees 18 minutes West 107.0 feet to a point in the division line between Lots 99 and 100 on said Plan, aforementioned: thence along the division line between lots 99 and 100 North 79 degrees 42 minutes East 141.0 feet to a paint in the western line of Greenbrier Drive, aforementioned, at the point and place of BEGINNING. BEING THE SAME PREMISES BY DEED DATED 04/23/1992, GIVEN BY DALE G. WINGERT AND DARLA R. WINGERT, HUSBAND AND WIFE TO KATHLEEN P. FLANNERY, SINGLE PERSON AND RECORDED 05/11/1992 IN BOOK 35 PAGE 1011. BEING KNOWN AS 925 GREENBRIAR DRIVE, MECHANICSBURG PA 17050 TAX PARCEL NO: 38-16-1064-030 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff i 1~ ~E~~~~~~ 2010 JUN -2 °M i : 4 3 CU~~15~~~~~~~~u t::jJEIYdTY P~NNS`tLV~,N#A FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 Plaintiff vs. KATHLEEN P. FLANNERY (Mortgagor(s) and Record Owner(s)) 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 10-2240 CIVIL TERM FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 925 Greenbriar Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE 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. TENANTS/OCCUPANTS 925 Greenbriar Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 27.2010 ' n' GOLDBEC McCAFFERTY & McKEEVER BY: TINAMARTF. BOSCHETTI GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF ~11.;E~~J1-r~CE t~ T~'1~ P~TN~I,n'AF~Y 10t0,1U1~ -2 PM I~ 43 P~#~1NSYLVA~flA FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 Plaintiff vs. KATHLEEN P. FLANNERY Mortgagor(s) and Record Owner(s) 925 Greenbrier Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2240 CNIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: GOLDBECK McCAFFERTY & McKEEVER Mi ael McKeever Pa. ID 56129 G McCafferty Pa. ID 42386 isa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 10-2240 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff ~~1~='tC~ t3F ?N~ P~~'r~!?~,1~~Af~tY 2QI0 JUG -2 ~'~! I ~ 4~ FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 vs. KATHLEEN P. FLANNERY Mortgagor(s) and Record Owner(s) 925 Greenbrier Drive Mechanicsburg, PA 17050 Plaintiff Defendants of Cumberland County CIVII, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2240 CNIL TERM 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: FLANNERY, KATHLEEN P. KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 Your house at 925 Greenbriar Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $42,685.04 obtained by FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 10-2240 CIVIL TERM 1. The sale will be cancelled if you pay to FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES, the back payments, late chazges, 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 attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may 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 compazed 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) aze 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.or~/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 Cazlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 10-2240 CIVIL TERM 717-243-9400 10-2240 CIVIL TERM 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.~ov 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://www.phfa.org/consumers/homeowners/real aux. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(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 96287FC. Para informacion en espanol puede communicarse con Loretta. al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2240 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISSTING UNDER THE LAWS OF THE UNITED STATES, Plaintiff (s) From KATHLEEN P. FLANNERY (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 $42,685.04 L.L.$.50 Interest from 5/28/10 to Date of Sale per diem at $7.47 Atty's Comm % Due Prothy $2.00 Atty Paid $165.50 Other Costs Plaintiff Paid Date: 6/2/10 / D. Buell, Prot onotary (Seal) By: REQUESTING PARTY: Name: LISA LEE, ESEQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Deputy Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever rn eft-?" rl? T?oV Attorney I.D.456129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff C nc?YL FEDERAL NATIONAL MORTGAGE ASSOCIATION. A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 150,57 Harrisburg, PA 17101 Plaintiff vs. KATHLEEN P. FLANNERY Mortgagor(s) and Record Owner(s) 925 Greenbriar Drive Mechanicsburg.. PA 17050 Defendant(s) Term No. 10-2240 CIVIL. TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/ceete tidtilt (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). 1; ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Keith C. Halili Legal Secretary 96287FC CF: 04/05/2010 SD: 09/08/2010 $42,685.04 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE 61, - der&? Q '. N m m L U ? ? ? m 61 O. 6 Env ??'n ? o LL U N a m 0 cf) d U LT O$? ? t G U G mIJ ti cct m ' E vm ER ?!? o Uu i rn ?' N ?D ? U I 1? c? r?n-- C dr ?' u- a '? Z p O- ffl O cl? L r C7 c' ` -L w "L7 N V. Q- z U? Qul m } °' Z m gy 1 ^ (? Q V U t d> Z o ?- N m rz 4Q?taJl1LO 0 Fi v ? d c o E Sl 4 V 7 .y a ON a C 4 a. l9 O C m u 1?- m r w U n Cl. € 6Y G U O V ? N b o ° m o7 cfl M hi - to W N `p o a n? Z ? m ? 0 r? I I N.. I ? 1 1.0 lzr 1 I' co r- g ? Z I O r N r; R ? O CD U N 11 CT ? Q ui LU E N ? a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?a it, 4t caszatFrrirg WIDE of "ME S.: RIFF Federal National Mortgage Association Case Number vs. Kathleen P. Flannery 2010-2240 SHERIFF'S RETURN OF SERVICE 062612010 11:48 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at X hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kathleen P. Flannery, located at, 925 Greenb6ar Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 0612612014 11:48 AM Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 1135 hours, she 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: Kathleen Flannery, by making known unto, Kathleen Flannery, personally, at, 925 Greenbriar Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $898.92 July 02, 2010 Coy Ywte Snetf. TeiwsoB, Iqc. SO ANSWERS, RON RANDERSON, SHERIFF GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff FEDERAL NATIONAL. MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 21 I North Front Street P.O. Box 15057 Harrisburg, PA 17101 vs. KATHLEEN P. FLANNERY Mortgagor(s) and Record Owner(s) 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-2240 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 925 Greenbriar Drive Mechanicsburg, PA 17050 I.Name and address of Owner(s) or Reputed Owner(s): KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Plaintiff KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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. TENANTS/OCCUPANTS 925 Greenbriar Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August-25,2010 GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SH~,RIF~'S OFFICE OF CUMBERLAND COUNTY t Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~ti 1tlP 4~ ~IU[i~~~,~~~~ a, ~~ . ~ .; . ~; _. C~~It;~~;F -k€ s.~:,wF~ Fii ~~~-~~'FtCE OF ~-, ,,~..~,C~CTARY 4 J .~ 1 i_ .i ( i~~ I ~I. ~~ ,,..~~' Federal National Mortgage Association vs. Case Number Kathleen P. Flannery 2010-2240 SHERIFF'S RETURN OF SERVICE 06/26/2010 11:48 AM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at X hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kathleen P. Flannery, located at, 925 Greenbriar Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 06/26/2010 11:48 AM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 1135 hours, she 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: Kathleen Flannery, by making known unto, Kathleen Flannery, personally, at, 925 Greenbriar Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 09/08/2010 As directed by Thomas Puleo, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/3/2010 10/28/2010 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 10/26/10 SHERIFF COST: $1,443.72 October 28, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ~~oo ~. ~. . S~ LL ~d ` ~~ 7~~if (ct GounhfSuite SFenff. TeleosoR, Irr,. .~ Goldbeck McCafferty 8i McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. BOX 15057 Harrisburg, PA 17101 vs. KATHLEEN P. FLANNERY (Mortgagor(s) and Record Owner(s)) 925 Greenbriar Drive Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 10-2240 CIVII. TERM AFFIDAVIT PURSUANT TO RULE 3129 FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 925 Greenbriar Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 i t 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 laiowledge who has any record interest in the property which maybe affected by the sale. ' 7. Name and address of every other person of whom the plaintiff has lrnowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 925 Greenbriar Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal imowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 27, 2010 ' ~~ GOLDBECK McCAFFERTY & McKEEVER BY: TINA,MARIE BOSCHETTI .~ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 10-2240 CIVIL TERM FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNTIED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 vs. KATHLEEN P. FLANNERY Mortgagor(s) and Record Owner(s) 925 Greenbriar Drive Mechanicsburg,l'A 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff Term No. 10-2240 CTVII, TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE LS 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: FLANNERY, KATHI.EIN P. KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 Your house at 925 Greenbriar Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $42,685.04 obtained by FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TffiS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: r 10-2240 CIVIL TERM 1. The sale will be cancelled if you pay to FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you 6. You maybe 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.orgJforeclosure/ 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 FIl1D OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Eberly Avenue Cazlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ALL THAT CERTAIN house and lot of ground situate in the Township of Silver spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the western line of Greenbriaz Drive (50 feet wide), Which said point is in the division line between Lots NoS8 99 and 100 on the hereinafter mentioned Plan of Lots; thence extending along the western line of Greenbriaz Drive, south 10 degrees 18 minutes East 107.0 feet to a point in the division line between Lots 98 and 99 on said Plan; thence along the division line between Lots Nos. 98 and 99 South 79 degrees 42 minutes West 141.0 feet to a point in the line of land now or formerly of Garret & Shelley; thence along the line of said last mentioned lands, North 10 degrees 18 minutes West 107.0 feet to a point in the division line between Lots 99 and 100 on said Plan, aforementioned: thence along the division line between lots 99 and 100 North 79 degrees 42 minutes East 141.0 feet to a paint in the western line of Greenbriaz Drive, aforementioned, at the point and place of BEGINNING. BEING THE SAME PREMISES BY DEED DATED 04/23/1992, GIVEN BY DALE G. WINGERT AND DARLA R. WINGERT, HUSBAND AND WIFE TO KATHLEEN P. FLANNERY, SINGLE PERSON AND RECORDED 05/11/1992 IN BOOK 35 PAGE 1011. BEING KNOWN AS 925 GREENBRIAR DRIVE, MECHANICSBURG PA 17050 TAX PARCEL NO: 38-16-1064-030 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-2240 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISSTING UNDER THE LAWS OF THE UNITED STATES, Plaintiff (s) From KATHLEEN P. FLANNERY (1) You aze 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 $42,685.04 L.L.$.50 Interest from 5/28/10 to Date of Sale per diem at $7.47 Atty's Comm % Due Prothy $2.00 Atty Paid $165.50 Other Costs Plaintiff Paid Date: 6/2/10 (Seal) REQUESTING PARTY: David D. Buell, P othonotary By: Deputy Name: LISA LEE, ESEQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 On June 14, 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, 925 Crreenbriar Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: 1 ea Estate Coor inator - f~ ~ (~~? ~~ ~; PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVAI~IIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal; a-legal periodical published in the Borough of Cazlisle in the County and.State aforesaid, was established Januazy 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 regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 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 ai, '. character of publication aze true. 'sa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 30 da of Jul 2010 Notary NOTARIAL BEAL DEBORAH A COLLINS NoNry PubNc CARLI8LE BOROUGH, CUMBERLAND COUNTY My Commktion Expires Apr 28, 2014 '~d w:<t 1[0. X010-~40 CMi Federal National Mortgage Association vs. Kathleen P. Flannery Atty.: Thomas Puleo ALL THAT CERTAIN house and lot of ground situate in the Township of Silver spring, County of Cumberland and Commonwealth of Pennsylvania, bounded sad described as follows: BEGINNING at a point in the western line of Greenbrier Drive (50 feet wide), Which said point is in the division line between Lota No38 99 and 100 on the hereinafter men- tioned Plan of Lota; thence extending along the western line of Greenbrier Drive, south 10 degrees 18 minutes East 107.0 feet to a point in the divi- sion line between Lota 98 and 99 on said Plan; thence along the division line between Lots Nos. 98 and 99 South 79 degrees 42 minutes West 141.0 feet to a point in the line of land now or formerly of Garret 8s Shelley; thence along the line of said last mentioned lands, North 10 de- grees 18 minutes Weat 107.0 feet to a point in the division line between Lots 99 and 100 on said Plan, afore- mentioned: thence along the division line between Iota 99 and 100 North 79 degrees 42 minutes East 141.0 feet to a paint in the western line of Greenbrier Drive, aforementioned, at the point and place of BEGINNING. BEING THE SAME PREMISES by deed dated 04/23] 1992, given by Dale G. Wingert and Darla R. Win- gert, husband and wife to Kathleen P. Flannery, single person and recorded 05/ 11 / 1992 in Book 35 Page 1011. BEING KNOWN AS 925 GREEN- BRIAR DRIVE, MECHANICSBURG PA 17050. TAX PARCEL NO: 38-16-1064- 030. :i!t~s~9 j~1Gt<.iix YTVt:+!?3 atpAJA3'.ihklSO ,ki."s.r: Sl~lt? ~ IZi k?A'3 "r~ ~7: ,SS i~; Bs~:~X~ ,~o~ae:.mrna:l a~A~! The Patriot-News Co. 2020 Techno{ogy Pkv~cy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~e patriot-News Now you know 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 Holly Blain, 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: 07/09/10 07/16/10 07/23/10 .....`.r~.~. .. ............ ~ ~ r,.~- Sworn to ahd subscribed before m ~ this 05 ~ .of August, 2010 A.D. ,~ _ _ r ~ ~~ ,. -. ~, ,. Notary Public C©MMpNWEAl1`Fi ()~ ~'ENNSYILVAN.IA Ncatarfa! deal ~~-~ Sherr2 L. Kdsner', 7dotar,~ AuUli: Lower Paxton Twp., Dauphin County My Commisslon Expires Nov. 26, 2011 Membt r, b'cnnsy?vanla Assaciaticn of N~tsriss Writ No. 2010-2240 Civil Term Federal National Mortgage Association Vs Kathleen P. Flannery Atty:thomas Puleo ALL THAT CERTAIN house and lot of ground situate in the Township of Silver spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the westem line of Greenbriaz Drive (50 feet wide), Vyhich said point is in the division line between Lots NoSB 99 and 100 on the hereinafter mentioned Plan of Lots; thence extending along the westem line of Greenbriaz Drive, south ]0 degrees 18 minutes East 107.0 feet to a point in the division line between Lots 98 and 99 on said Plan; thence along the division line between Lots Nos. 98 and 99 South 79 degrees 42 minutes West 141.0 feet to a point in the fine of land now or formerly of Gatret & Shelley; thence along the line of said last mentioned ]ands, North 10 degrees 18 minutes West ]07.0 feet to a point in the division line between Lots 99 and 100 on said Plan, aforementioned: thence along tfle division line between lots 99 and 100 North 79 degrees 42 minutes East 141.0 feet to a paint in the westem line of Greenbriaz Drive, aforementioned, at the point and place of BEGINNING. BEING THE SAME PREMISES BY DEED DATED 04/23/1992, GIVEN BY DALE G. WIN~rERT AND DARLA R. WINGERT, HUSBAND AND WIFE TO KATHLEEN P. FLANNERY, SINGLE PERSON AND RECORDED 05/11/1992 IN BOOK 35 PAGE 1011. BEING KNOWN AS 925 GREENBRIAR DRIVE, MECHANICSBURG PA 17050 TAX PARCEL NO: 38-16-1064-030 GOLDBECK McCAFFERTY & McKEEVER Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 Attorney for Plaintiff FILED-OFFICE OF THE PROTHONOTARY 2010 DEC -3 PM 2: 17 CUPENNSYLVAN A ' FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. Box 15057 Harrisburg, PA 17101 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. No. 10-2240 CIVIL TERM KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Settled, Discontinued and Ended upon payment of your costs only. BECK AFFERTY 8 M KEENER Michae r Pa. ID 5612 / Gary McCafferty Pa. I ./ Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6312 THELPROTHO TARP 2010 DEC -3 PM 2: 17 CUMBERLAND COUNT' PENNSYLVANIA Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES 211 North Front Street P.O. BOX 15057 Harrisburg, PA 17101 Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 10-2240 CIVIL TERM KATHLEEN P. FLANNERY 925 Greenbriar Drive Mechanicsburg, PA 17050 Defendant PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. By: GOL CCAFFERTY MCKEEVER Michael Mc ee 6129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ?? asp