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HomeMy WebLinkAbout10-4955t Phelan Hallinan & Schmieg LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 / Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 243941 GOLDMAN SACHS MORTGAGE COMPANY 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 Plaintiff v. LISA L. DELANEY WILLIAM E. DELANEY, IV 801 5TH STREET NEW CUMBERLAND, PA 17070-1825 Defendants -„ _ r , = t- , ;; ;r r ~~ ~, D$ i ~~1~,~ ~~ 'J~`a- . rr1~.~~11,A e~ ~~ ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ~C- t~Q~ CivitTerm CUMBERLAND COUNTY CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE ~ga•oo Pa aT,~y ~~ R~8 04S ~d459~~0 File #: 243941 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 this 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 claimed in the Complaint or 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, 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 (800)990-9108 File #: 243941 1. Plaintiff is GOLDMAN SACHS MORTGAGE COMPANY 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 2. The name(s) and last known address(es) of the Defendant(s) are: LISA L. DELANEY WILLIAM E. DELANEY, IV 801 5TH STREET NEW CUMBERLAND, PA 17070-1825 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 05/04/2001 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EQUITY ONE ,INC. DBA POPULAR FINANCIAL SERVICES which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1703, Page 556. By Assignment of Mortgage recorded 12/22/2008 the mortgage was assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. which Assignment is recorded in Assignment of Mortgage Instrument No. 200840229. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 243941 5. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/09/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $88,392.49 Interest $13,376.18 02/09/2009 through 07/19/2010 (Per Diem $25.43) Attorney's Fees $650.00 Cumulative Late Charges $691.52 05/04/2001 to 07/19/2010 Costs of Suit and Title Search $550.00 Escrow Deficit $2,196.99 TOTAL $105,857.18 7 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 243941 Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $105,857.18, together with interest from 07/19/2010 at the rate of $25.43 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SC~II~IIEG, LLP By: ^ Lawren .Phelan, Esq Id. No. 32227 ^ Franc' S. allinan, Es ., Id. No. 62695 ^ Daniel G. mie sq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ hrisovalante P. Fliakos, Esq., Id. No. 94620 ~oshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 243941 LEGAL DESCRIPTION All that certain tract or parcel of land and premises, situate, lying and being in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the north side of Fifth Street, at the northwest corner of Fifth and Poplar Avenues; thence along the north side of Fifth Street north 80 degrees 45 minutes 25 seconds West a distance of 88.86 feet to a point at the dividing line between Lots 1 and 2 on the hereinafter mentioned plan of lots; thence along said dividing line north 9 degrees 14 minutes 35 seconds East a distance of 88.89 feet to a point at line of land now or late of Margaret J. Reed; thence along said property line south 80 degrees 45 minutes 25 seconds East a distance of 42.68 feet to a point on the west side of Poplar Avenue; thence along the west side of Poplar Avenue south 18 degrees 12 minutes 27 seconds East a distance of 100.17 feet to a point at the northern line of Fifth Street, the place of BEGINNING. BEING Lot No. 1 on the subdivision plan of New Cumberland Homes, recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania in Plan Book 41, Page 50. PREMISES BEING: 801 5TH STREET PARCEL NO: 25-24-0811-198 HAVING THEREON erected a brick dwelling house known and numbered as 801 Fifth Street, New Cumberland, Pennsylvania 17070. BEING part of the same premises which Donald E. Slike and Rose Marie Slike, his wife, by their deed dated July 2, 1985, recorded in Cumberland County Deed Book 31-I, Page 745, granted and conveyed unto Donald E. Slike and Rose Marie Slike, his wife, grantors herein Fi{e #. 243941 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: '!~ File #: 243941 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOiiCltOl' ~~a„tr st +Cumbrrt,~~~ -{: :.- f~f ~C$ OF THE SHEF€IFF ~a, a_,_~ t~'i~ AI1~ 13 pM ~~ 1~- ~~.~ ~ i- _ . ;~' Goldman Sachs Mortgage Company vs. William E. Delaney, IV (et al.) Case Number 2010-4955 SHERIFF'S RETURN OF SERVICE 08/11/2010 05:53 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 11, 2010 at 1753 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: William E. Delaney IV, by making known unto himself personally, at 1160 Brockton Circle, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~ RYAN BURGETT, DE 08/11/2010 05:53 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 11, 2010 at 1753 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Lisa L. Delaney, by making known unto William E. Delaney IV, Husband of defendant at 1160 Brockton Circle, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~ RYAN BURGETT, DEPUTY 08/12/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lisa L. Delaney, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosire as not found as to the defendant Lisa L. Delaney. Request for service at 801 5th Street, New Cumberland, PA 17070 is vacant. Lisa L. Delaney is currently residing at 1160 Brockton Circle, New Cumberland, PA 17070. 08/12/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: William E. Delaney IV, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosire as not found as to the defendant William E. Delaney IV. Request for service at 801 5th Street, New Cumberland, PA 17070 is vacant. William E. Delaney IV is currently residing at 1160 Brockton Circle, New Cumberland, PA 17070. SHERIFF COST: $116.60 SO ANSWERS, August 12, 2010 RON R ANDERSON, SHERIFF (c) CountySuite Shenfl. Teleosoft. Inc. FILED-OFFICE T4 1E PROTHONOTARY 23! 1 AM 10: ?5 "UMBER' AND COUNTY PENi,?1'LVANIA Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GOLDMAN SACHS MORTGAGE COMPANY VS. LISA L. DELANEY WILLIAM E. DELANEY, IV Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-4955-CIVIL-TERM oe p't aay -*N' Ind Y SSS /t4?- zWyo I 243941 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against LISA L. DELANEY, and WILLIAM E. DELANEY, IV, Defendant(s) for failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $105,857.18 Interest - 07/20/2010 to 09/15/2010 $1,474.94 TOTAL $107,332.12 I hereby certify that (1) the Defendant's last known addresses are 1160 BROCKTON CIR, NEW CUMBERLAND, PA 17070-2247, and the mortgaged premises 801 5TH STREET, NEW CUMBERLAND, PA 17070-1825 and (2) that notice has been given in accordance with Rule 237. 1, copy attached. 1,//-\ 1 I U Lawre c T. Phelan, sq., Id. No. 32227 ? Franc' Hallinan, sq., Id. No. 62695 ? Dan i G Schmie , Esq., Id. No. 62205 ? Michele NLBradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 E] Sheetal R. Shah-Jani, Esq., Id. No. 81760 E] Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 El Vivek Srivastava, Esq., Id. No. 202331 E] Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 RJoshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: l7 ml6 PHS # 243941 PROTHON ARY 243941 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GOLDMAN SACHS MORTGAGE COMPANY VS. LISA L. DELANEY WILLIAM E. DELANEY, IV : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-4955-CIVIL-TERM 243941 VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant LISA L. DELANEY is over 18 years of age and her last known addresses are 1160 BROCKTON CIR, NEW CUMBERLAND, PA 17070-2247, and the mortgaged premises 801 5TH STREET, NEW CUMBERLAND, PA 17070-1825. (c) that defendant WILLIAM E. DELANEY, IV is over 18 years of age and his last known addresses are 1160 BROCKTON CIR, NEW CUMBERLAND, PA 17070-2247, and the mortgaged premises 801 5TH STREET, NEW CUMBERLAND, PA 17070-1825. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: lD ? Lawr ce . Phelan, q., Id. No. 32227 ? Fran s S. allinan, q., Id. No. 62695 ? Daniel G. chmieg sq., Id. No. 62205 ? Michele 1. a rd, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 hrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff 243941 (Rule of Civil Procedure No. 236) - Revised GOLDMAN SACHS MORTGAGE COMPANY : CUMBERLAND COUNTY VS. LISA L. DELANEY WILLIAM E. DELANEY, IV COURT OF COMMON PLEAS CIVIL DIVISION • No. 10-4955-CIVIL-TERM Notice is given that a Judgment in the above captioned matter has been entered against you on S l 7, 016 By: If you have any questions concerning this matter please contact: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 R Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIEN AGAINST PROPERTY. ** 243941 GOLDMAN SACHS MORTGAGE COMPANY V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4955-CIVIL-TERM LISA L. DELANEY WILLIAM E. DELANEY, IV Defendant(s) TO: WILLIAM E. DELANEY, IV 801 5TH STREET NEW CUMBERLAND, PA 17070-1825 DATE OF NOTICE: September 1, 2010 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 243941 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: L <ence T. Phelan, Esq., Id. No. 322 7 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 2067'9 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 243941 GOLDMAN SACHS MORTGAGE COMPANY v Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4955-CIVIL-TERM LISA L. DELANEY WILLIAM E. DELANEY, IV Defendant(s) TO: WILLIAM E. DELANEY, IV 1160 BROCKTON CIRCLE NEW CUMBERLAND, PA 17070-2247 DATE OF NOTICE: September 1, 2010 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS 4 243941 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: fl?rence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 20677 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 243941 GOLDMAN SACHS MORTGAGE COMPANY V. Plaintiff LISA L. DELANEY WILLIAM E. DELANEY, IV Defendant(s) TO: LISA L. DELANEY 1160 BROCKTON CIRCLE NEW CUMBERLAND, PA 17070-2247 COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4955-CIVIL-TERM CUMBERLAND COUNTY DATE OF NOTICE: September 1, 2010 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 243941 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: J ence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 / Courtenay R. Dunn, Esq., Id. No. 2067791 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 243941 GOLDMAN SACHS MORTGAGE COMPANY V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4955-CIVIL-TERM LISA L. DELANEY WILLIAM E. DELANEY, IV Defendant(s) TO: LISA L. DELANEY 801 5TH STREET NEW CUMBERLAND, PA 17070-1825 DATE OF NOTICE: September 1, 2010 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 243941 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By wrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 243941