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Home My WebLink About10-5610GOLD13ECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM RLED-0 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. MARK A. THOMPSON BOBBI JO THOMPSON Mortgagors and Record Owners 11 Donald Street Mechanicsburg, PA 17050 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1o- Ito Cti??t T+?i, CIVIL ACt®N: MORTGAGE P WL08URE 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 G 8 Irvine Row $ga.oo P p AThJ Carlisle, PA 17013 0,1 tOt377(o 717-243-9400 a Qg74S(o AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO-PUEDE, PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE 1NFORMACION 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.DTBT 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 h -p://www.t)hfa.org/consumers/homeowners/real.4Vx. 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.Dhiladelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongizoldbecklaw.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: 21.5-825-6418. Please reference our Attorney File Number of 100267FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is GMAC MORTGAGE, LLC, 3451 Hammond Avenue, Waterloo, IA 50702. 2. The names and addresses of the Defendants are MARK A. THOMPSON, 11 Donald Street, Mechanicsburg, PA 17050 and BOBBI JO THOMPSON, 11 Donald Street, Mechanicsburg, PA 17050, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On January 11, 2008 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GMAC MORTGAGE, LLC F/K/A GMAC MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Instrument # 200801747. The mortgage has been assigned to: GMAC MORTGAGE, LLC by assignment of Mortgage. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March 01, 2010 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 ..................................................................................$145,260.82 Interest from 02/01/2010 through 07/09/2010 at 6.6250% .......................$4,811.76 Per Diem interest rate at $26.37 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$7,263.04 Late Charges from 03/01/2010 to 07/09/2010 .............................................$562.70 Costs of suit and Title Search (Estimated) ...................................................$900.00 Property Inspection Fee .................................................................................$45.00 Speed Pay Fee ................................................................................................$12.50 Escrow ....................................................................................... •....................$47.53 Suspense ....................................................................................................... $590.11 Monthly Escrow amount $231.13 $159,493.46 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose has been sent to Defendants by certified mail, as required by Act 6 of 1974 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 Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983 or Act 160 of 1998. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $159,493.46, together with interest at the rate of $26.37, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: AZ GOLD ECK MC ERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 sa Lee Pa. ID 78020 ristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF P . VERIFICATION 1, Jef'AIQU , as the representative for the Plaintiff corporation within named do here y 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 the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: /O LLC 'ewe', Stephan I,im w Signing Officer #I 00267FC - MARK A. TROMPS, 11 Donald Street Mechanicsburg, P. Ey?Fi6itA Title No. 01898 SCHEDULE C 10-20-1842-034 11 Donald Street, Cumberland Hampden Township, Cumberland County LEGAL DESCRIPTION ALL THAT CERTAIN piece or panel of land with the buildings and improvements thereon ereeted, situate in Hampden Township, Cumberland Cowin PennsYlvania, being known as Lot No. 29 on the Plan of NoU Acres, which Plan is recorded in Phut Book 9, Pages 41 and being more fUlly bounded and described according to a plan ofsarvcy made by D. P- Raffenspcrgcr, R.S., dated June 13,1959. as follows, to wit: SEGITiNING at o point on the Southeastern side of Donald Sveer 50 fcct wide, said point being 167-53 feet southwest%%wdly from the intersection of the southeastern side of Donald StTCCt with the southwcstcm side of William Drive: abo at the dividing line of Lots Nos28 and 29 on the hcreiiubefore mentioned Plum of Lots, thence along said dividing line South 66 degrees 52 minutes East, 125 feet to a point at the dividing line between Lm Nov. 24 and 25: thence along the same and also along Lot No. 24 South 23 degruo 08 minutes West 70 feet io a point at the dividing line between Lou Nos. 29 and 30 on said Plau; thence along tho game North 66 degrees 51 mint+tes West 125 feet to a point on the southeastern 9idc of Donald Sftm ftnec along the some North 23 degrees 08 minutes East. 70 feet to a point, the ptace of BEGINNING- HAVING THEREON ERECTED a single frame ranch house known and numbered as h 1 Donald Strot:4 Mechunlesburg, Pcnnsylvaei3- BEING THE SAME PREMISES which Mark A_ Thompson and Bobbi Jo Miller, deed dated October 30, 2006 and recorded in the Recorder of Deeds Office in and for Cumberland County Pennsylvania on November 9, 2006 in Record Book 277, Page 2626, granted and conveyed unto Mark A. Thompson and Bobbi Jo Thompson, grantors herein. Y: . 1 ' .f Exhibit B THOMPSON, BOBBI JO BOBBI JO THOMPSON 11 Donald Street Mechanicsburg, PA 17050 File #: 100267FC Sale date: County: Cumberland Property: 11 Donald Street Mechanicsburg, PA 17050 inunm Name and Address of Sender Check type of mat or service: Affix Stamp Here 3OLDBEC K ? Candied ? Recorded Delivery (International) (if issued as a certificate of mating ;UIUITE 5000 ? COD ? Registered , or for additional oc0es MARKET STREET ? Delivery Confirmation ? Return Receiptfor Merchandise or tats bit 'HILADELPHIA, PA ? Express Mail ? Signature Confirmation Post-rk end 9106-1532 U Insured Date of Receipt Handling Actual Value Insured Due Sender DC SC SH RD RR Arifde Number - Addressee (Narre, atree, City, state, &. ZIP Owe) Postage Fee Qharoe if i Vayie_ if CO 1. BOBBI JO THOMPSON 11 Donaid Street Mechanicsburg, PA 17050 2 3. 5 - - 6. - - - 8. Total Number o Pieces Total Number of Pieces Postmaster, Per (Name of receiving employee) Listed by Sender Received at Post Office See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) Complete by Typewriter, Ink, or Ball Point Pen ACT LETTER 100267FC Cumberland County GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 07/22/2010 Certified Mail No. PROPERTY: 11 Donald Street, Mechanicsburg, 17050 LOAN NO.: MORTGAGEE: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GMAC MORTGAGE, LLC F/K/A GMAC MORTGAGE CORPORATION CURRENT LENDER/SERVICER: GMAC MORTGAGE CORPORATION TO: BOBBI JO THOMPSON 11 Donald Street Mechanicsburg, PA 17050 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 INTENTION TO FORECLOSE MORTGAGE under Section 403 of Penna. Act No. 6 of 1974 (READ ALL PAGES OF THIS NOTICE CAREFULLY) The MORTGAGE held by the above named CURRENT LENDER/SERVICER (hereinafter referred to as we, us, or ours) is the holder of the first mortgage on your property described above. The mortgage is in SERIOUS DEFAULT because you have not made the monthly payments as noted below under (a) and/or because you have failed to comply with or perform the other provisions of the mortgage obligation, if any, as noted below under (d). Previous late charges under (b) and other charges, if any under (c) noted below, have also accrued to this date. THE TOTAL AMOUNT NOW REQUIRED TO CURE THIS DEFAULT, OR IN OTHER WORDS, GET CAUGHT UP IN YOUR PAYMENTS AS OF THE DATE OF THIS LETTER, IS NOTED BELOW UNDER (e). (a) Monthly payment from 03/01/2010 thru 07/22/2010 (5 mos. at $1,182.74/month) $5,913.70 (b) Late charges from 03/0112010 thru 07/22/2010 (5 mos. at $47.30/month) $236.50 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $6,150.20 You may cure this default within THIRTY (30) DAYS of this letter by paying to us the amount under (e) above, plus any additional monthly payments and late charges (and other charges) WHICH MAY FALL DUE DURING THIS PERIOD. Such payment must be made either by CASH, CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER made payable to - (Attention:) GMAC MORTGAGE CORPORATION, 3451 Hammond Avenue, Waterloo, IA 50702 If you do not cure the default with THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately, and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. Also, we may sue you personally for the unpaid principal balance, and all other sums due under the mortgage- If you have not cured the default within the thirty day period, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such Sheriffs Sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. . This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs Sale, a lawsuit could be started to evict you_ You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST.) YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Contact Person: Phone Number CERTIFIED MAIL - RETURN RECEIPT REQUESTED Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 Fax (215) 627-7734 GMAC Mortgage, LLC PO Box 780 Waterloo , IA 50704-0780 ACT 6 NOTICE Date: 06/03/10 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgaee 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. HOMEOWNER S NAME(S): MARK A. THOMPSON ADDRESS: 11 DONALD STREET MECHANICSBURG PA 17050-0000 LOAN ACCT. NO.: 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. 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: I 1 DONALD STREET MECHANICSBURG PA 17050-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 03/01/10 through 06/01/10. See attached Exhibit for payment breakdown. Monthly Payments $ 4730.96 Late Charges $ 704.60 NSF $ 0.00 Inspections $ 45.00 Other (Default Expenses and Fees) $ 12.50 Optional Insurance $ 0.00 Suspense $ 590.11 TOTAL AMOUNT PAST DUE: $ 4902.95 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 $ 4902.95, 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 or certified check made oavable and sent to: GMAC Mortgage, LLC ATTN: Payment Processing PO Box 780 Waterloo , IA 50704-0780 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 morteaee 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 morteaEed 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 attorney s fees actually incurred by the lender even if they exceed $50.00. Any attorney s fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYS 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 Sheriff s 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 Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF S SALE DATE -- It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately six (6) 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: Name of Lender ATTN: Address: Phone Number: Fax Number: Contact Person: GMAC Mortgage, LLC Loss Mitigation 2711 North Haskell Ave Suite 900 Dallas, TX 75204 888-714-4622 866-709-4744 Collection Department EFFECT OF SHERIFF S SALE You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishing and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE You MAY or MAY NOT sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney s fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ENCLOSED Applicable law requires us to inform you we are attempting to collect a debt and any information you provide will be used for that purpose. If you disagree with our assertion that a default has occurred with your mortgage loan, please contact our office immediately at 888-714-4622 and speak with one of our loan counseling representatives. Thank you for your prompt response concerning this matter. Collection Department Loan Servicing 5037 EXHIBIT 03/01/10 through 06/01/10 Mo. Pmt. Amt. $ 1182.74 Ex, (idit C Prepared By and Return To., Referral Department GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 GMM File Number: 100267FC Parcel ID#: 20-1842-0034-0000000-10 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GMAC MORTGAGE, LLC F/K/A GMAC MORTGAGE CORPORATION (Assignor), for and inconsideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to GMAC MORTGAGE, LLC. GMAC MORTGAGE, LLC (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed MARK A. THOMPSON and BOBBI JO THOMPSON, Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GMAC MORTGAGE, LLC F/K/A GMAC MORTGAGE CORPORATION. Bearing date of. January 11, 2008; Amount Secured: $148,616.00; Recorded on January 16, 2008; in Instrument #200801747; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: I1 Donald Street, Mechanicsburg, PA 17050 AS FURTHER DESCRIBED IN EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate corporate officers, as a cuted and sealed with its corporate seal this Assignment of Mortgage on this d-a day of 2010. MORTGAGE ELECTRONIC (Affix Corporate Seal) ss: STATE OF COUNTY OF REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GMAC MORTGAGE, LLC F/K/A GMAC MORTGAGE CORPORATION Vi President (SEAL) Name-.-- J0 rCet7 Title: Anistant SOCrLgwy BE IT REMEMBERED, that on this r2Oday of 2010, Notary Public personally appeared of a Resolution of its Board of Directors. I hereby certify the address of the Assignee is: 3451 Hammond Avenue, Waterloo, IA 50702 Notary Public COMMMWEALTH OF PENNSYLVAMA before me, the subscriber, r ? My commission expires: NOTARIAL. SEAL Cindy A. Stewart, -N-nary Public Upper Dublin Tm), tstiniagomery County M commission expo cs October 19, 2013 Case #: 100267FC GMAC MORTGAGE CORPORATION officers of Assignor, who I am satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary act and deed of such corporation made by virtue SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~~^'''"~~~ ~3 Sheriff ~} ~;~~,;,~;~,, r'y~'+!~'~ ~ ~r'`~Y Jody S Smith ~`~ Chief Deputy ,r~ ~~p ~ 4 ~~"~ ~Q' ~~ Richard W Stewart Solicitor ~ ,- •J '~~~~~ CI~I~J~~~S ,~~Vr'~`W PEN~v I(a' GMAC Mortgage, LLC I Case Number vs. 2010-5610 Mark A. Thompson (et al.) SHERIFF'S RETURN OF SERVICE 09!10/2010 04:32 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on September 10, 2010 at 1632 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mark A. Thompson, by making known unto himself personally, at 11 Donald Street, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. MICHELLE GU SHA ,DEPUTY 09/10/2010 04:37 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on September 10, 2010 at 1637 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bobbi Jo Thompson, by making known unto herself personally, at 4G Kevin Street, 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. MICHELLE GU ALL, PUTY SHERIFF COST: $62.00 September 13, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF is In the Court of Common Pleas of Cumberland County GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagor(s) and Record Owner(s)) 11 Donald Street Mechanicsburg, PA 17050 Defendant(s) PRAECIPE FOR JUDGMENT No. 10-5610 CIVIL'T" rIT1 CID r -77 --q 73 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 BOBBI JO THOMPSON and MARK A. THOMPSON by default for want of an Answer. Assess damages as follows: Debt Interest from 11 / 19/2010 to Date of Sale per diem at $26.37 Total (Assessment of Damages attached) $163,898.82 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: C CCAFFERTY & MC VER Michael e Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa ID 82628 Thomas Puleo Pa. ID 27615 ' / Attorneys for Plaintiff AND NOW IUdV' do 16 , Judgment is entered in favor of GMAC MORTGAGE, LLC and against BOBBI JO THOMPSON and MA A.OMPSON by default for want of an Answer and damages assessed in the sum of $163,898.82 as per the above certi tt n. n pd'+?q-o M MN4,01 et4f SSa319 &*'gp5o? k lad #&& Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff vs. BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagors and Record Owner(s)) 11 Donald Street Mechanicsburg, PA 17050 Defendant(s) No. 10-5610 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PAIZ013 n 4 I //;'a// 0 By: Deputy If you have any questions concerning the above, please Michael T. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 100267FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 1, 2010 TO: BOBBI JO THOMPSON THOMPSON, BOBBI JO 11 Donald Street Mechanicsburg, PA 17050 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 vs. BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagor(s) and Record Owner(s)) 11 Donald Street Mechanicsburg, PA 17050 TO: BOBBI JO THOMPSON 11 Donald Street Mechanicsburg, PA 17050 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-5610 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 100267FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 1, 2010 TO: BOBBI JO THOMPSON THOMPSON, BOBBI JO 4G Kevin Street Mechanicsburg, PA 17050 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 vs. BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagor(s) and Record Owner(s)) I I Donald Street Mechanicsburg, PA 17050 TO: BOBBI JO THOMPSON 4G Kevin Street Mechanicsburg, PA 17050 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-5610 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 100267FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 1, 2010 TO: MARK A. THOMPSON THOMPSON, MARK A. 11 Donald Street Mechanicsburg, PA 17050 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 vs. BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagor(s) and Record Owner(s)) 11 Donald Street Mechanicsburg, PA 17050 TO: MARK A. THOMPSON 11 Donald Street Mechanicsburg, PA 17050 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-5610 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, BOBBI JO THOMPSON, is about unknown years of age, that Defendant's last known residence is 4G Kevin Street 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: Michelle Clarkson 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, MARK A. THOMPSON, is about unknown years of age, that Defendant's last known residence is 11 Donald Street 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. Dater 11o rff)(f KUCD Michelle Clarkson 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 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 vs. BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagor(s) and Record owner(s)) I I Donald Street Mechanicsburg, PA 17050 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW Defendant(s) ORDER FOR JUDGMENT ACTION OF MORTGAGE FORECLOSURE No. 10-5610 CIVIL TERM Please enter Judgment in favor of GMAC MORTGAGE, LLC, and against BOBBI JO THOMPSON and MARK A. THOMPSON for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint in the s $163,898.82. By: GOLBECK,MCCAFFERTN) & MCKEEVER Michael 29 / Gary Mc afferty 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 I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 and that the name(s) and last known address(es) of the Defendant(s) is/are BOBBI JO THOMPSON, 4G Kevin Street Mechanicsburg, PA 17050 and MARK A. THOMPSON, 11 Donald Street Mechanicsburg, PA 17050; Y? OLDBEC CCAFFER & MCKEEVER Mic cKeever Pa. ID 5 129 / Gary McCaffe 2386? Lisa 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 02/01/2010 through 11/18/2010 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 4 X $231.13 Property Inspection Fee Speedpay Fee Escrow Suspense AND NOW, this And day of l UUV $145,260.82 $8,292.60 $7,263.04 $562.70 $900.00 $924.52 $45.00 $12.50 $47.53 $590.11 $163,898.82 By: /If G BECK CAFFERTY & CKEEVER Michae ver Pa. ID 561 Gary McCafferty Pa. 386 Lisa 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. Pro Prothy PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 vs. Plaintiff BOBBI JO THOMPSON MARK A. THOMPSON Mortgagor(s) and Record Owner(s) 11 Donald Street Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 10-5610 CIVIL TERM. fV rv -"C7 _A -1- -r; --- r- 1.7 M CD Ca -'r1 C a t, :23 PRAECIPE FOR WRIT OF EXECUTION -CD TO THE PROTHONOTARY: :. Issue Writ of Execution in the above matter: Interest from 11/19/2010 to Date of Sale per diem at $26.37 Amount Due (Costs to be added) P !$163,898.82 pd a? Ub 1, y s9?.o? cow B? 5, "4 00 '1 G EC CCAFFERTY MCKEEVER Michael 29 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 / 9 `? SDr S 6 a d Attorneys for Plaintiff tal I.S>liM/ itJv?rl IrU1. By O H v w ? o w? Z a Z?O fir, TA W u O o c, -o „ .? p d O a? bD 00 0 0 ?p'? o? H a •t H? cad U y yU o w N C-A b? a? ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE BUILDINGS AND IMPROVEMENTS THEREON ERECTED SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING KNOWN AS LOT NO. 29 ON THE PLAN OF NOLL ACRES, WHICH PLAN IS RECORDED IN PLAN BOOK 8, PAGE 41 AND BEING MORE FULLY BOUNDED AND DESCRIBED ACCORDING TO A PLAN OF SURVEY MADE BY D.P. RAFFENSPERGER, R.S., DATED JUNE 13,1958, AS FOLLOWS TO WIT: BEGINNING AT A POINT ON THE SOUTHEASTERN SIDE OF DONALD STREET, 50 FEET WIDE, SAID POINT BEING 167.53 FEET SOUTHWESTWARDLY FROM THE INTERSECTION OF THE SOUTHEASTERN SIDE OF DONALD STREET WITH THE SOUTHWESTERN SIDE OF WILLIAM DRIVE; ALSO AT THE DIVIDING LINE OF LOTS NO. 28 AND 29 ON THE HEREINBEFORE MENTIONED PLANS OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 66 DEGREES 52 MINUTES EAST, 125 FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NOS. 29 AND 25; THENCE ALONG THE SAME AND ALSO ALONG LOT NO. 24 SOUTH 23 DEGREES 08 MINUTES WEST 70 FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NOS. 29 AND 30 ON SAID PLAN; THENCE ALONG THE SAME NORTH 66 DEGREES 51 MINUTES WEST 125 FEET TO A POINT ON THE SOUTHEASTERN SIDE OF DONALD STREET; THENCE ALONG THE SAME NORTH 23 DEGREES 08 MINUTES EAST, 70 FEET TO A POINT, THE PLACE OF BEGINNING. Parcel# 20-1842-0034-0000000-10 Property address: 11 Donald Street, Mechanicsburg, PA 17050 Being the same premises which Mark A. Thompson, a single man, Bobbi Jo Thompson, a single woman and Joan E. Miller by deed recorded 11/09/2006, in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 227 Page 2626, granted and conveyed unto Mark A. Thompson and Bobbi Jo Thompson, husband and wife. Goldbeck, McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff IN THE COURT OF COMMON PLEAS vs. BOBBI JO THOMPSON MARK A. THOMPSON Mortgagor(s) and Record Owner(s) 1 I Donald Street Mechanicsburg, PA 17050 of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) NO. 10-5610 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. By: GOLDB CCAFFERTY MCKEEVER Michael cKeever Pa. 6129 ?.s 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 ,t rv ?z CD _,., I CD -1 CD .J ? 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 GMAC MORTGAGE, LLC 3451 Hammond Avenue IN THE COURT OF COMMON PLEAS Waterloo, IA 50702 Plaintiff of Cumberland County vs. BOBBI JO THOMPSON CIVIL ACTION - LAW MARK A. THOMPSON (Mortgagor(s) and Record Owner(s)) 11 Donald Street ACTION OF MORTGAGE FORECLOSURE Mechanicsburg, PA 17050 Defendant(s) No. 10-5610 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 GMAC MORTGAGE, LLC, 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: 11 Donald Street Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): - C -) r? C 'n BOBBI JO THOMPSON 4G Kevin Street w?rr; st Mechanicsburg, PA 17050 =n r='` = - ?'" rri MARK A. THOMPSON 11 Donald Street C? 1 Mechanicsburg, PA 17050 - - _ rr 2. Name and address of Defendant(s) in the judgment: C :D BOBBI JO THOMPSON 1 4G Kevin Street Mechanicsburg, PA 17050 MARK A. THOMPSON 11 Donald Street 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: r 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 CUMBERLAND VALLEY SCHOOL DISTRICT 6746 Carlisle Pike Mechanicsburg, PA 17050 4. Name and address of the last recorded holder of every mortgage of record: BELCO COMMUNITY CREDIT UNION 403 North 2nd Street Harrisburg, PA 17101 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 11 Donald Street 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: November 18, 2010 Tw?? A GOLDBECK McCAFFERTY & Mc EVER BY: Michelle Clarkson 10-5610 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 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff VS. BOBBI JO THOMPSON MARK A. THOMPSON Mortgagor(s) and Record Owner(s) 11 Donald Street Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 10-5610 CIVIL TERM Defendant(si THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO e - E 7 COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO kn 5 COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE-< USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: THOMPSON, BOBBI JO BOBBI JO THOMPSON 4G Kevin Street Mechanicsburg, PA 17050 iv N Your house at 11 Donald Street, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $163,898.82 obtained by GMAC MORTGAGE, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to GMAC MORTGAGE, LLC, 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. c? ---• i M ?i 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. 10-5610 CIVIL TERM 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orwforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-5610 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.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.oriz/consumers/homeowners/real.gMx. 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 10026717C. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 11 Donald Street Mechanicsburg, PA 17050 SOLD as the property of BOBBI JO THOMPSON and MARK A. THOMPSON TAX PARCEL #20-1842-0034-0000000-10 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5610 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE, LLC Plaintiff (s) From BOBBI JO THOMPSON AND MARK A. THOMPSON (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$163,898.82 L.L.$.50 Interest FROM 11/19/2010 TO DATE OF SALE PER DIEM AT $26.37 Atty's Comm % Atty Paid $194.50 Plaintiff Paid Date: November 22, 2010 (Seal) REQUESTING PARTY: Deputy Name GARY MCCAFFERTY, ESQ. 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. 42386 Due Prothy $2.00 Other CostsTO BE ADDED i Davi . Buell, Prothonkuy By: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 Mellon Independence Center 701 Market Street J - ; ; r IT, Philadelphia, PA 19106-1532 215-627-1322??? 2 ti? 3 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 vs. BOBBI JO THOMPSON MARK A. THOMPSON Mortgagor(s) and Record Owner(s) 11 Donald Street Mechanicsburg, PA 17050 Plaintiff Defendant(s) 100267FC CF: 08/30/2010 SD: 03/02/2011 $163,898.82 VANI A IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-5610 C1VIL, TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) ERIC KEENAN, an employee of Goldbeck McCafferty & McKeever, counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by. Personal Service by the Sheriffs Office/cu, opy 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). ( ) 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. Respe lly rub 'tte BY: ERIC KEEN Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor vq??yttS of 44ribp,?ah4 Sv,j..., OPPiCE OF'TKE SFkERIFF GMAC Mortgage, LLC vs. Case Number Bobbi Jo Thompson (et al.) 2010-5610 SHERIFF'S RETURN OF SERVICE 01/07/2011 12:11 PM - Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action upon the property located at 11 Donald Street, Mechanicsburg, PA 17050, Cumberland County. 01/07/2011 12:11 PM - Deputy Amanda Cobaugh, being duly swom according to law, attempted service to the Defendant, to wit: Mark A. Thompson at 11 Donald Street, Hampden Township, Mechanicsburg, PA 17050. The Defendant was found to have moved. 01/07/2011 12:20 PM - Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Bobbi Jo Thompson at 4G KEVIN STREET, Hampden Township, Mechanicsburg, PA 17050, Cumberland County. 01/10/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Mark A. Thompson, but was unable to locate the Defendani in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 01/26/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of York County upon Mark A. Thompson, personally, at 180 Ridge Road, Etters, PA 17319. So Answers: Richard Keuerleber, Sheriff. SHERIFF COST: $908.94 January26, 2011 SO ANSWERS, RS^wff. T'xi=osoH, Inr. n o r- 3 aV O z ? U 6 14V a. N t cn 4 ps U- Ln U- 00 d [f O SQd1M(? G o ? r, Z V Z Q !- m w U) to c o m U H O Z m R p r oa?° to Z m? a [1 E mv= ?c? ??? y Um e Em p LL c a U` 7 m2o5 m O" < o Q N of p L o e C L m a° OU Z !Lo mdOT C Q 0 c ZUv m w?.2 C m p Z ? m P n sU U ? Of L H m ?i w K ~ N m w 4) p c 7766 o6 ? ? ? d' U J O ???? U O 00 m c a U _ a W ? cn o Z 0 a 1 N v es O LL O 0. L 0 E m c` H c+7 m H 7 ` J Q m ? Q a m L Z 0t `o °- U Na ?w a m a m U)i? x a N c 0 :7 W `m. ?C10? wzm p m" m -0 E mm ? OD OOO m , Q tt v QUaU mZ T Um 8 m F-- m W 2 ? ?a o v)Q Q QYCD WQ- UoY-iM ' ? )Qp caU m E zO?0 Cb N C7cntin - d E 0 EE Z 9 m 1-6- ? 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N y Q 00 ?a o c o Y Of Em U z co a m U O _ N I Q N (D O [o E co 2 a` 7 U ) O `a a v 00 U = O E M LL Za a 0 m N m m rp d F J LL co O O O a - CO GOIA110 ceAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 vs. BOBBI JO THOMPSON MARK A. THOMPSON Mortgagor(s) and Record Owner(s) 11 Donald Street Mechanicsburg, PA 17050 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-5610 CIVIL TERM SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 GMAC MORTGAGE, LLC, 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: 11 Donald Street Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): BOBBI JO THOMPSON 4G Kevin Street Mechanicsburg, PA 17050 MARK A. THOMPSON 11 Donald Street Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: BOBBI JO THOMPSON 4G Kevin Street Mechanicsburg, PA 17050 MARK A. THOMPSON 11 Donald Street 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 CUMBERLAND VALLEY SCHOOL DISTRICT 6746 Carlisle Pike Mechanicsburg, PA 17050 NOLL ACRES COMMUNITY ASSOCIATION 5 DONALD STREET MECHANICSBURG, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: BELCO COMMUNITY CREDIT UNION 403 North 2nd Street Harrisburg, PA 17101 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 11 Donald Street 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: February 10, 2011 4 - GOLD BECK McCA ERTY & MCKEEVER BY: ERIC KEENAN Legal Secretary KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff ILED-OFFICE HE PROTHONOTARY 2D12 JAN I 1 AM I1: 02 ww. PCh 4-tYLVAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagor(s) and Record owner(s)) 11 Donald Street Mechanicsburg, PA 17050 No. 10-5610 CIVIL TERM Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Sobs ?t Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: _Iichael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 -Lisa Lee Pa. 1D 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 -Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff GMAC MORTGAGE, LLC 3451 Hammond Avenue Waterloo, IA 50702 VS. Plaintiff BOBBI JO THOMPSON MARK A. THOMPSON (Mortgagor(s) and Record Owner(s)) 11 Donald Street Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 10-5610 CIVIL TERM CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on / -/D- l BOBBI JO THOMPSON 4G Kevin Street Mechanicsburg, PA 17050 MARK A. THOMPSON 11 Donald Street Mechanicsburg, PA 17050 BOBBI JO THOMPSON 11 Donald Street Mechanicsburg, PA 17050 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: A gels M. Smith, Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone)