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Home My WebLink About10-5824GOLDBECK 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 RJLF-D- ? r'C (? (,.; r" r J C lr tr `-k r`i 1 P i i 2 FANNIE MAE 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff vs. MATTHEW C. SULLIVAN AIIVIEE L. SULLIVAN Mortgagors and Record Owners 2 Patricia Drive Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendants I CIVIL ACTION: MORTGAGE NOTICE FORECLOSURE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 0S 717-243-9400 4g9L.00 PIN" 0 * 6%14-7 AVISO R c2g8053 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 demands 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 provisiones 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 SERVCCO. 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 INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud. ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.gWx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org?foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&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 101699FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FANNIE MAE, 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. The names and addresses of the Defendants are MATTHEW C. SULLIVAN, 2 Patricia Drive, Enola, PA 17025 and AIMEE L. SULLIVAN, 2 Patricia Drive, Enola, PA 17025, who are the mortgagors and record owners of the mortgaged premises hereinafter described. On May 15, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR FIRST HORIZON HOME LOAN CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1951 Page 1389. The mortgage has been assigned to: FANNIE MAE 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 April 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 ..................................................................................$160,777.80 Interest from 03/01/2010 through 08/20/2010 at 6.8750% .......................$4,595.10 Per Diem interest rate at $30.28 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$8,038.89 Late Charges from 04/01/2010 to 08/20/2010 .............................................$110.36 Costs of suit and Title Search (Estimated) ...................................................$900.00 Escrow ........................................................................................................ ($239.67) Monthly Escrow amount $387.48 $174,182.48 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 Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $174,182.48, together with interest at the rate of $30.28, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with reis of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure t rtgage and Sheriff s Sale of the Property. V v - Y= GOLAErtCK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 /"avid Fein Pa. ID 82628 ?/ Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF GOLDBECK 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 FANNIE MAE 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254 Plaintiff vs. MATTHEW C. SULLIVAN AIMEE L. SULLIVAN Mortgagors and Record Owners 2 Patricia Drive Enola, PA 17025 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si 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 defenses 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 continuer 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 INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www. hp fa.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.philadelphiafed.ordforeclosure/ 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 homeretention@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 101699FC. 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 FANNIE MAE, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254. 2. The names and addresses of the Defendants are MATTHEW C. SULLIVAN, 2 Patricia Drive, Enola, PA 17025 and AIMEE L. SULLIVAN, 2 Patricia Drive, Enola, PA 17025, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On May 15, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR FIRST HORIZON HOME LOAN CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1951 Page 1389. The mortgage has been assigned to: FANNIE MAE 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 April 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 .............................................................................. Interest from 03/01/2010 through 08/20/2010 at 6.8750%.... Per Diem interest rate at $30.28 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 04/01/2010 to 08/20/2010 ....................... Costs of suit and Title Search (Estimated) ............................. Escrow .................................................................................... Monthly Escrow amount $387.48 $160,777.80 ....$5,238.44 .................$8,038.89 ....................$110.36 .................... $900.00 .................. ($239.67) $174,825.82 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. Plaintiff is not seeking a judgment of personal liability (or an "in persona m" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $174,825.82, together with interest at the rate of $30.28, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accord it rms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the for to e ortgage and Sheriff's Sale of the Property. By: GOLDBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 rlbavid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF VERIFICATION The undersigned attorney for Plaintiff is authorized to make this verification and states that the facts set forth in the foregoing Complaint are true and correct to the best of his or her knowledge, information and belief. The undersigned understands that statements made in this verification are subject to the penalties of 18 Pa.C.S.A. §4904. Date: By: GOLD#ECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Pavid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff #101699FC MATTHEW C. SULLIVAN and AIMEE L. SULLIVAN 2 Patricia Drive Enola, PA 17025 ExhibitA First American Title Insurance Company Commitment Number: 06222 SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point on the eastern line of Patricia Drive at the dividing line between Lots No. 10 and 11 on the herelnafser mentioned Plan of Lots; thence by the dividing iine between Loft No. 10 and 11 on sold Plan, North 42 degrees 33 minutes East, 122.81 feet lo a point thence North 45 degrees 09 minutes 30 seconds West, 85.44 feet to a point; thence by the d'nriding line between Lacs No. 11 and 12 on said Plan, South 49 degrees 30 minuses 0,00 seconds West, 114.97 feet to a point In the eastern line of Patricia Drive; Owes by the eastern line of Patricia Drive, South 40 degrees 30 minutes East, 100.00 feet to a point, the place of BEGINNING.- BEING Lot No. 11 in the Plan of Lots of Sherwood Park, Section 1 which Plan is of record in the Cumberland County Reoorder°s Office in Plan Book 12, page 29. The Plan of Sherwood Park is the same Plan of Lots laid out by Theodore E. Sgrignoli, at ux, and designated as Nola Ames, which plan was not recorded. HAVING THEREON erected a one story dwelling house known as 2 Patricia Drive, Enola, Pennsylvania. BEING THE SAME PREMISES which Danielle T. Plessi and Perry C. Plessi, wife and husband; and Deborah J. Stroheaer and Kevin R. Sbuhedcer, by their deed dated April 26, 2001 and recorded in the Cumberland County Recorder of Deeds Office on May 3, 2001 In Deed Book 244. Page 5, granted and conveyed to Michael P. Sanderson. 1 Certify this;. In Cumberland County PA Recuraer of Deeds ALTA Com mfterrt Schedule C (0622J0622y19) x1951PGIitos ?hibit (B AM&- L B P S- Lender Business Process Services 14523 SW Millikan Way; Suite 200; Beaverton, OR 97005 Business Hours (Pacific Time) Mon-Thu 5:00am to 9:00pm; Fri 5:00am to 6:00pm Sat 6:00am to 12:00pm, Sun 11:00am to 5:00pm May 19, 2010 Payments P.O. Box 105468; Atlanta, GA 30348-5468 Correspondence CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL PO Box 4121; Beaverton, OR 97076-4121 Phone L1781 866.570.5277 SULLIVAN, AIMEE L 2 PATRICIA DR Fax 666.578.5277 ENOLA, PA 17025 Website www.lbps.com RE: Loan No. "WIN ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the CoUcction Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Bmverton, OR. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 717-780-1869). SULLIVAN, AIMEE L Loan No.: Page 2 May 19, 2010 LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: SULLIVAN, AIMEE L 2 PATRICIA DR ENOLA, PA FIRST HORIZON HOME LOAN CORPORATION Lender Business Process Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE.THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAI V/ A. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR SULLIVAN, AIMEE L Loan No.: Page 3 May 19, 2010 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAPAPPLICATION AS SOONAS POSSIBLE. IF YOU HAVE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STARTING A FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORAR YSTA Y OF FORCLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL YAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW MilUan Way, Beaverton, OR SULLIVAN, AIMEE L Loan No.: Page 4 May 19, 2010 HOW TO CURE YOUR MORTGAGE DEFAULT Bring it ua to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 2 PATRICIA DR ENOLA PA IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Your loan is delinquent for the following months: March 2010, April 2010, May 2010 Past Due Installments: Totals Principal $547.59 Interest 2,763.36 Escrow Installment 923.40 Other Open Charges: Late Charges Property Inspections Less Suspense (Balance) TOTAL Prior Servicer Charges $110.36 15.00 LBPS Charges $4,234.35 $0.00 $110.36 0.00 15.00 $125.36 $0.00 $4,359.71 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 4,359.71, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Lender Business Process Services P.O. Box 105468 Atlanta, GA 30348-5468 (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADGATTORNEY ENERAi V/ A. NEW YORK CrrY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR SULLIVAN, AIMEE L Loan No.: Page 5 May 19, 2010 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 will exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $ 50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the 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 Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately eight (8) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW M H&an Way, Beaverton, OR SULLIVAN, AIMEE L Loan No.: Page 6 May 19, 2010 HOW TO CONTACT THE SERVICER: Name of Servicer: Lender Business Process Services, Inc. Address: PO Box 4121; Beaverton, OR 970764121 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Person(s): Holli Jennings or David Solomon E-Mail Address: loanworkoutgeneral@lbps.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of Consumer Credit Counseling Agencies serving your county. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. SULLIVAN, AIMEE L Loan No.: Page 7 May 19, 2010 Sincerely, Lender Business Process Services Enclosures: PHFA list of HENW-approved agencies, How to Avoid Foreclosure YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR AW&'-- L B P S Lender Business Process Services 14523 SW Milikan Way; Suite 200; Beaverton, OR 97005 Business Hours (Pacific Time) Mon-Thu 5:00am to 9:00pm; Fri 5:00am to 6:00pm Sat 6:00am to 12:00pm, Sun 11:00am to 5:00pm May 19, 2010 Payments P.O. Box 105468; Atlanta, GA 30348-5468 Correspondence CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL PO Box 4121; Beaverton, OR 97076-4121 L1781 Phone 866.570.5277 SULLIVAN, MATTHEW C 2 PATRICIA DR Fax 866.578.5277 ENOLA, PA 17025 Website www.lbps.com RE: Loan No. NEW ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWWCOLORADOATTORNEYGENERALGOV/ A. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call 717-780-1869). SULLIVAN, MATTHEW C Loan No.: Page 2 May 19, 2010 LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: SULLIVAN, MATTHEW C 2 PATRICIA DR ENOLA, PA FIRST HORIZON HOME LOAN CORPORATION Lender Business Process Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE.THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGE RAi V/ A. NEW YORK CrrY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. SULLIVAN, MATTHEW C Loan No.: Page 3 May 19, 2010 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAPAPPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STAR TING A FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORCLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL YAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW MiMan Way, Beaverton, OR SULLIVAN, MATTHEW C Loan No.: Page 4 May 19, 2010 HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 2 PATRICIA DR ENOLA PA IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Your loan is delinquent for the following months: March 2010, April 2010, May 2010 Past Due Installments: Totals Principal $547.59 Interest 2,763.36 Escrow Installment 923.40 $4,234.35 Prior Servicer Other Open Charges: Charges LBPS Charges Late Charges $110.36 $0.00 $110.36 Property Inspections 15.00 0.00 15.00 $125.36 Less Suspense (Balance) $0.00 TOTAL $4,359.71 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 4,359.71, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made eayable and sent to: Lender Business Process Services P.O. Box 105468 Atlanta, GA 30348-5468 (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW MilUan Way, Beaverton, OR. SULLIVAN, MATTHEW C Loan No.: Page 5 May 19, 2010 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 will exercise its rigbts to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within TIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable 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 (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. You may do so by paving the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately eight (8) 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/servicer. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CrrY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW MilUan Way, Beaverton, OR SULLIVAN, MATTHEW C Loan No.: Page 6 May 19, 2010 HOW TO CONTACT THE SERVICER: Name of Servicer: Lender Business Process Services, Inc. Address: PO Box 4121; Beaverton, OR 970764121 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Person(s): Holli Jennings or David Solomon E-Mail Address: loanworkoutgeneral@Ibps.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of Consumer Credit Counseling Agencies serving your county. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CrrY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR SULLIVAN, MATTHEW C Loan No.: Page 7 May 19, 2010 Sincerely, Lender Business Process Services Enclosures: PHFA list of HEMAP-approved agencies, How to Avoid Foreclosure YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMEITMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. NEW YORK CUY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. Eyt.hi6it C PELqjk'TSYLVANTA PREPARED BY & WHEN RECORDED RETURN TO: LBPS 14523 SW MMLUM PAY #200 BEAVERTON, OR 970 f5 ATTN cou= CUMBERLAND PARCEL No. 09-14-0836-163 POOL NO. LOAN No. (? ) (LB0064 J 111111 1111111101111 1 ASSIGNMENT OF MORTGAGE KNOW ALL MEN BY THESE PRESENTS, thaw 1s'l.FYTRl MUC RF MRATXCN SYSTEM, nC. AS AZIEUG E FaR FZF2ST BcRIZCrT jnwmw CJL?LPC??ATICN, located at 3300 S.W. 34TH AVRYW, SUITE 101, OCALA, FL 34474 hereinafter re- ferred to as Assignor, for and in con ideration of the sum of ONE DOLLAR ($1.00) lawful money of the United States of America together with other good and valuable consideration, to it in hand paid by FANNIE MAE (-FEDERAL NATIONAL MORTGAGE ASSOCIATION-) located at 14221 rAZAS FAY, SCARS 1000 ZIALLAB, TK 75254 hereinafter referred to as Assignee, at or before the delivery of these presents, the receipt of which is hereby acknowledged, has granted, bargained, sold, assigned, transferred, conveyed and set over unto said Assignee, its successors and assigns, all of its right, title and interest in and to that certain Mortgage dated the 15th day of MAY '2006 made and executed by MATTHEW C. SULLIVAN AND AIMEE L. SULLIVAN , Mortgagor, to Z430GRM ffC RM=RA't'TCK SYr72M, IW. AS NGMI11'[E'6 FM FZRS'1' RM W HCMB LOAN C73tPOP?.yTI011T Mortgagee, covering premises situated in the County CUMBERLAND Commonwealth of Pennsylvania, more particularly described therein and commonly known as: TOWNSHIP OF EAST PENNSBORO PROPERTY ADDRESS: 2 PATRICIA DR, ENOLA, PA 17025 Said Mortgage was duly recorded on the 19th day of MAY 2006 in the office of the Register, Clerk of Recorder of Deeds of CUMBERLAND County, in Book 1951 at Page 1389 or Document No. of the Official Records of said Register, Clerk of Recorder of Deeds together with that certain Note of even date and secured thereby in the principal amount of CM RMCM SIXTY-ETWT TROClraaAM and BO/100 ----- , ( 168, 000.00 ) made and executed by mortgagor and payable to the order of the aforementioned Mortgagee. As previously recorded from to in Book from to _ in Book from at Page at Page and to _ in Book (NMRI.PA.PA) at Page J=LB8040110AI.s.01340 on at Document No. on at Document No. on at Document No. and Page 1 of 2 Loan No. ) (LB0064) TO HAVE AND TO HOLD the same unto said Assignee, its successors and assigns to its and their proper use and benefit forever. IN WITNESS WHMEOF, the said AURTGPIGN RLECTRCAUC REGLTM7TC U SYSTOW, nur;. AS AXICUM MM FIRST BUR'I7,W RCW LQW CCP_UCR=CK has caused these presents to be duly executed by its proper officer this 315t day of AUGUST 2010 but made effective JUNE 1, 2010 1 E ECTR=C RR?IS"TRATICkV SYSTEM, n C. AS A13CU S FER FIST BCFUYA T RCW LOW CCPPCRATICN BY BY CARMEN RIVERA KRYSTAL lftZl ASSISTANT SECRETARY ASSISTANT SECRETARY SPATE OF IDAHO CoLum OF BONNEVILLE on AUGUST 31, 2010 before me, VICKIE SORG , personally appeared KRYSTAL HALL and CARMEN RIVERA personally known to me (or proved to me on the basis of satisfactory evidence) to be the persons who execute the within instrument as ASSISTANT SECRETARY and ASSISTANT SECRETARY on behalf of BOWURM ECTR hTC R ATICYIT SYSTEM, INC.'. AS bXIG DES FCR FIRST ECRI71W now LOW G ATTCW anndaac' wledged to me that the Corporation executed it. VICKIE SORG VICKIE S G (COMMISSION EXP. 08-18-11) NOTARY PUBLIC Notary Public STATE OF IDAHO -------------------------------------------------- -------------------------- I DO HEREBY CERTIFY THAT THE PRECISE ADDRESS OF THE ASSIGNEE RESIDENCE IS: FANNIE_MAS_(-FEDERAL -NATIONAL MORTGAGE ASSOCIATION"1---------------- ------------------------------------------------------------------------------ ------------------------------------------------------------------------------ ------------------------------------------------------ ------------------ _14221_DALLA_S_ PARKWAY,-SUITE 1000DALLAS,-TX-75254----------------- --- ---------------- AASSSISTANT SECRETARY 14523 SW MILLIKAN WAY, #200 BEAVERTON, OR 97005 ATTN P=5.002. 00085.34 BW 100085200576236139 AERS PROW: 1-888-679-6377 (NM :E.PA.2) C=5.375. 0001 J=LB8040110AI. s. 01340 Page 2 of 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson EILIED -OFF ICE Sheriff 0 e 4E P.R-TH)0N0TARY Jody S Smith ,? Chief Deputy 701'0 4?, C 0 PM 2: 2 7 Richard W Stewart DE ;, At2 C0UttfTY Solicitor OFF?r a _aro?eSY IDv?AM Fannie Mae Case Number vs. Matthew C. Sullivan (et al.) 2010-5824 SHERIFF'S RETURN OF SERVICE 09/16/2010 02:51 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 16, 2010 at 1451 hours this Complaint in Mortgage Foreclosure upon defendant Matthew C. Sullivan is returned not served per request from Attorney Michael T. McKeever. 09/16/2010 02:51 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 16, 2010 at 1451 hours this Complaint in Mortgage Foreclosure upon defendant Aimee L. Sullivan is returned not served per request from Attorney Michael T. McKeever. SHERIFF COST: $44.00 September 17, 2010 SO ANSWERS, RbNIN? R ANDERSON, SHERIFF (os CountySuile Sneraf. i eleaso`t. Inc GOLDBECK McCAFFERTY & N jeKEE'VER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 i?NOTA' 2011 APR -6 t'm 11. us AND COUNTY FANNIE MAE 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254 Plaintiff VS. MATTHEW C. SULLIVAN AIMEE L. SULLIVAN 2 Patricia Drive Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 10-5824 CIVIL TERM PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. By: OLDBECK M FFERTY MCKEEVER Micha er 6129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254 Plaintiff vs. MATTHEW C. SULLIVAN AP84EE L. SULLIVAN 2 Patricia Drive Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-5824 CIVIL TERM CERTIFICATE OF SERVICE Natasha Perez, 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 9 [q J 11 MATTHEW C. SULLIVAN 2 Patricia Drive Enola, PA 17025 AIMEE L. SULLIVAN 2 Patricia Drive Enola, PA 17025 Byffi AA P Jcz? Goldbeck McCafferty & McKeever Natasha Perez, Legal Assistant NPerez@goldbecklaw.com 215-825-6384 (Direct Phone)