The URL can be used to link to this page

Home My WebLink About11-2985A' i. 1. Plaintiff is WELLSW??NK, N.A., AS TRUSTEE FOIE@UIUIEW HOME LOAN RAT ?. 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 20 16ftl, 4650 Regent Blvd,.L - ng, TX 75063. 2. The names and addresses of the Defendants are SHARON A. LAWRENCE, 5405 Joshua Road, Mechanicsburg, PA 17050 and RANDY L. LAWRENCE, 5405 Joshua Road, Mechanicsburg, PA 17050, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On February 23, 2007 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to OPTION ONE MORTGAGE CORPORATION, A CALIFORNIA CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on March 01, 2007 as Book 1983 Page 3866. The mortgage has been assigned to: WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES SERIES 2007-OPT1 by assignment of Mortgage recorded on February 8, 2011 as Instrument # 201104748. 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 July 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 ..................................................................................$444,166.77 Interest from 06/01/2010 through 08/31/2010 at 6.8750% ............................................$7,634.13 09/01/2010 through 12/31/2010 at 7.1250% ..........................................$10,548.96 Late Charges from 07/01/2010 to 12/31/2010 ..........................................$3,590.73 Monthly Escrow amount $93.42 Escrow Advance ......................................................................................$3,156.79 Total Fees .......................................................................................................$30.00 NSF Charges ................................................................................................$150.00 Recoverable Balance ....................................................................................$313.00 Reasonable Attorney's Fee .......................................................................$1,300.00 $470,890.38 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. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 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 $470,890.38, together with interest at the rate of $86.70, 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: GOLD CK M AFFER & MCKEEVER Michael Mc 56129 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 VERIFICATION Harold Nord, III , as the representative American Home Mortgage Servicing, Inc, for the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ? A ON( 011 Hamid Nord, III Am can Ho ortga a Servicing, APAistant Secretary #10663017C - SHARON A. LAWRENCE and RANDY L. LAWRENCE 5405 Joshua Road Mechanicburg, PA 17050 EythibitA 01-04-'11 11:58 FROM- SCHEDULE C LEGAL DESCRIPTION T-430 P0021/0025 F-294 Title No. 01608 10-19-1602-108 5405 Joshua Road. Mechanicsburg Hampden Township; Curmbedand County ALL 609 &oWh plcee. Vocal of k c of lmd, 10206W wick iraptavemads, situmed in tlarapdetn Township. Cwnb dmA C xly. Prantylwnis. cad boaodsd sad dacribad as follows: 91OfNN NG as a point on Waaran 'M'si? llas 909d Drive (50.00 foot wide), said poW bobs located m 6a Sau6mlam aotswc of Im No. 201; 6ne slam weld . wngr 1100 as dw we of a Ditch eJmft to do lek haViag a=40 ei42SA0 f C4 and an ate lt%& of 7.71 kt% to a point; lwcn Sosth 14 dW ms 14 minum 47 awo0ato Real, fan a dislows of 49.10 far, b a point on to ere Of a ek* aawisr to qn 414 pavi* a ted w of 25.00 6cot, and sw an kno of 3S.lx fear, to a point os the Nosilsaoa tyiK a-9w Use afJoshm Road (90.00 fief wWe);0= dooS said ti*4-ofrwv lino on dw am eta oitde emwihe to dew kA. lwving a mdia of 475 0l1 icon, mW an at Icntptt of 92-,4 foes, m s poilm. am Saudi S6 &V= 46 vshwi a 43 mar aeds West, ad tltro%h-61 S l10 toot wide **W moot for s diaanae of 13.51 feel, to a point In Um Of pmpoxd P%m VII: dwaa nkft WA Froptmmsl Plmmi WT. and goal d+s ee wroc of maid 15.00 hot wide dadaps aswaeaf„ No* 33 doom 13 pdantca 17 setaede WaaL far s drauerc of 106:8p fiat to a pow it a c faring isow Pk dint Nw* 10 de fleas 43 miautea S7 aoeo ado PAsy for s disum o[56.9S fwL w a p 4o u dw Coaapmemm coiner of La Me. 201; &a stork the Saudwn to mAny Iron of Lot No. 701-%" 72 dipaaos 16 osi wm 00 sstoola Espy fir a d wm of3i"fast, to a point; then Nbaah-13 dqp@IS 54 m4wt.a 311 ssc" Eat, for a disrseco of O.eo f lk w a polm and the Flaw of B NO. This piem pones of lot of lead aoomim gvroxiO w dy 15.43621 elaarw $ at of laid, Ivw w ad?era of 3185 laahea Reed. Lsaltssieabur;, Psrglvneis i70fS. and is Terranaa atl mnmlraod as Lot No. 202 oa dw %ad >Ra-S "vWm Mia br OOod E6pw Fees Sam6 -plwe: N - Lot Ala. 201 otd M. wtdt:k is tecoded in L%mbmind Coaoey id Rm-beek 11. Pops 66. BEING THE SAME PREMISES which The MCNaghton C"t"", dead d0ed SeptswAw 29.2000 end reoonded in the, Recorder of Deeds Ofte in NW for Cwtabwbrd Coo W, ftw"hanrrs on October 2,200D in Record Book 230. Pape 51, gravded and conveyed unto Randy L. Lawrence and Slum A. Lowrenoe, graMors hereit. 8K i 983PG3876 Exhibit (B AHMM 09/22/2010 1 0 0 6 6 4 7 Sharon A Lawrence 5405 Joshua Rd Mechanicsburg, PA 17050 (Rev. 9/2008) Date: September 22, 2010 8T ?E AR OM ?ON RECLOSUYOUR RE 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. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ONPAGE FOUR The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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. HOMEOWNER'S NAME(S): Sharon A Lawrence PROPERTY ADDRESS: 5405 Joshua Rd Me?, PA 17050 LOAN ACCT. NO.: ? ORIGINAL LENDER: OPTION ONE MORTGAGE CORPORATION CURRENT SERVICER: American Home Mortgage Servicing, Inc. CURRENT LENDER: Wells Fargo Bank, N.A., as Trustee for Soundview Home Loan Trust 2007-OPT I, Asset-Backed Certificates, Series 2007-OPTI Page two HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE 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. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender fromfiling 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 HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - 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 YOUARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMA TION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS ANATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page three 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: 5405 Joshua Rd, Mechanicburg, PA 17050 IS SERIOUSLY IN DEFAULT because: A. YOUHAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 07/01/20 10: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 09/22/2010: $9,366.36 $3,032.64 $443.80 $0.00 $12,842.80 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $12,842.80, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other 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: American Home Mortgage Servicing, Inc. 1525 S. Beldine Rd. Coppell, TX 75019 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right 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) DA Yperiod, 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) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE 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 five (5) 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. Page four HOW TO CONTACT THE LENDER Name of Lender: American Home Mortgage Servicing, Inc. Address: 1525 S. Beltline Rd. Coppell, TX 75019 Telephone Number: 1-877-304-3100 Fax Number: 1-866-497-1263 Contact Person: Brandon Wirth, Michael Heath E-mail Address: brandon.wirth@ahmsi3.com, michael.heath@ahmsi3.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 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. YOUMAYALSO HAVE THE RIGHT. ° TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ° TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ° TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ° TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES S-7. American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debtor a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, American Home Mortgage Servicing, Inc. American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019, 1-877-304-3100 Action-Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh, PA 15219 800.792.2801/412.281.2102 www.acbonhousing.org 'Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence - Philadelphia 1628 JFK Blvd-8 Penn Ctr, STE 2210 Philadelphia, PA 19103 215.218.4342 www.afinow.org 'Philadelphia Advocates for Financial Independence - Ridley Park 202 E Hinkley Ave Ridley Park, PA 19078 215.218.4342 www.afinow.org 'Chester, Delaware Alliance for Building Communities 830 Hamilton Mall Allentown, PA 18101 610.439.7007 'Lehigh, Northampton, Schuylkill American Credit Alliance, Inc. 2 S Delmorr Ave; STE 501 Morrisville. PA 19067 800.501.7526/215.295.7195 www.501plan.com 'Bucks, Montgomery Armstrong County Community Action Agency 705 Butler Rd Kittanning, PA 16201 724.548.3408 www.armstrongcap.com 'Armstrong Asociaci6n Puertorriquef)os an Marche, Inc. (APM) 600 W Diamond St Philadelphia, PA 19122 7215.235.6070 www.apmphila.orgm 'Delaware, Philadelphia BASE, Incorporated 447 S. Prince St Lancaster, PA 17603 717.392.5467 www.baseinc.org 'Lancaster Bayfront Neighborhood Action Team Organization, Inc. 312 Chestnut St Erie, PA 16507 814.459.2761 'Erie Blair County Community Action Agency 2100 6th Ave; STE 102 Altoona, PA 16602 800.238.9763 / 814.946.3651 '81air Barks Community Action Program, Inc. 247 N Fifth St Reading, PA 19601 610.375.7866 www.racc.edL#SocialService/bOgO.aspx 'Barks, Schuylkill, Montgomery * Indicates Counties Serviced Bucks County Housing Group CCCS of Delaware Valley - 2324 Second St Pike; STE 17 Philadelphia Wrightstown, PA 18940 4400 North Reese St 866.866.0280 / 215.598.3566 Philadelphia, PA 19140 www.bchg.org 800.989.2227 / 215.563.5665 'Bulks www.cccsdv.org Building United of Southwestern PA 'Bucks, Chester, Delaware, Montgomery, Philadelphia 801 N Homewood Ave, STE 201 Pittsburgh, PA 15208 412.281.4422 'Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland Campbell Street Family Youth and Community Association 600 Campbell St Williamsport, PA 17701 570.322.5515 www.campbelistreeteenter.org 'Lyceming Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 'Delaware, Montgomery, Philadelphia Cambria Community Development Corporation 401 Candlelight Dr Ebensburg, PA 15931 814.472.6711 'Blair, Cambria, Delaware, Indiana, Somerset CCCS of Delaware Valley - Bristol 1230 Veterans Hwy; STE F1 Bristol, PA 19007 800.989.2227 / 215.563.5665 'Bulks CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; 10th FL Philadelphia, PA 19103 800.989.2227 / 215.563.5665 www.cccsdv.org 'Chester, Philadelphia CCCS of Delaware Valley - Chinatown 901-A Wood St Philadelphia, PA 19107 800.989.2227/215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - Coatesville 1001 East Lincoln Hwy; Suite 102 Coatesville, PA 19320 800.989.2227 / 215.563.5665 www.cccsdv.org 'Chester, Delaware CCCS of Delaware Valley - Jenkintown 261 Old York Rd; The Pavillion #401 Jenkintown, PA 19046 800.9892227 / 215.563.5665 www.ccasdv.org 'Montgomery CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 800.989.2227 / 215.563.5665 www.occsdv.org 'Delaware CCCS of Delaware Valley - Philadelphia 7340 Jackson St Philadelphia, PA 19136 800.989.2227 1215.563.5665 www.occsdv.org 'Philadelphia CCCS of Delaware Valley - West Chester 770 E Market St; STE 190 West Chester, PA 19382 800.989.2227 / 215.563.5665 www.cccsdv.org 'Chester. Delaware CCCS of Lehigh Valley - Pottstown 1954 E High St Pottstown, PA 19464 866.889.9347 www.consumercredifv.org 'Chester, Montgomery CCCS of Lehigh Valley - Quakertown 127 S. 5th St; STE 155 Quakertown, PA 18951 866.889.9347 www.consumercreditiv.org 'Bucks CCCS of Lehigh Valley - Whitehall 3671 Crescent Court E Whitehall, PA 18052 866.889.9347 www.consumercreditlv.org 'Carbon, Lancaster, Lehigh, Schuylkill CCCS of Lehigh Valley - Wyomissing 833 N Park Rd, M; STE 103 Wyomissing, PA 18072 866.889.9347 www.consumercreditiv.org 'Barks, Northampton CCCS of Northeastern PA - By Appt. Only 214 W. Walnut St Hazleton, PA 18201 800.922.9537 www.eccsnepa.org 'Carbon CCCS of Western PA - Butler 112 Hollywood Dr; STE 101 Butler, PA 16001 888.511.2227/888.511.2227 www.cccspa.org 'Armstrong, Beaver, Butler, Clarion, Jefferson, Lawrence CCCS of Western PA - Erie 4402 Peach St; Lower Level Erie, PA 16509 888.511.2227/888.511.2227 www.occspa.org 'Crawford, Elk, Erie, McKean, Mercer, Union, Venango, Warren CCCS of Western PA - Greensburg 1 N Gate Sq Greensburg, PA 15601 888.511.2227 / 888.511.2227 www.cccspa.org 'Indiana, Westmoreland CCCS of Western PA - Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg, PA 17110 888.511.2227 1888.511.2227 www.cccspa.org 'Dauphin, Juniata, Lebanon, Mifflin, Northumberland, Perry, Union CCCS of Western PA - Pittsburgh 2403 Sidney St; STE 400; River Park Commons Pittsburgh, PA 15203 888.511.2227/888.511.2227 www.cccspa.org 'Allegheny, Cameron CCCS of Western PA - York 55 Clover Hill Road Dallastown, PA 17313 888.511.2227 / 888.511.2227 www.cecspa.org 'Adams, Cumberland, Franklin, Lancaster, Lebanon, York Center for Family Services, Inc. 213 W Center St Meadville, PA 16335 814.337.8450 www.thecenter-nwpa.org 'Crawford, Mercer, Venango Center in the Park CCCS of Northeastern PA - Pittston 5818 Germantown Ave 401 Laurel St Philadelphia, PA 19144 Pittston, PA 18640 215.849.5100 800.922.9537 / 570.602.2227 www.centerinthepark.org www.cccsnepa.org 'Philadelphia 'Bradford, Carbon, Centre, Clearfield, Luzeme, Clinton, Columbia, Elk, Juniata, Lackawanna Chester Community Improvement Project Lycoming,MifBin,Monroe,Montour,Northumbedand 412 Ave of the States Pike, Potter, Schuylkil, Snyder, Sullivan Chester, PA 19013 Susquehanna,Tioga,Union,Wayne,Wyoming 610.876.8663 'Chester, Delaware. Montgomerv_ Philadelnhin CCCS of Northeastern PA - State College 202 W Hamilton Ave Stale College, PA 16801 800.922.9537 1814.238.3688 www.cccsnepa.org 'Blair CCCS of Northeastern PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA 18360 800.922.9537 / 570.602.2227 www.cccsnepa.org 'Monroe CCCS of Western PA - Altoona 917A Logan Blvd; Royal Remax Plaza Altoona, PA 16602 888.511.2227 / 888.511.2227 www.cccspa.org 'Bedford, Blair, Cambria, Centre, Clearfield, Fulton, Huntingdon, Juniata, Somerset Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717.232.9757 www.cactricounty.org 'Cumberland, Dauphin, Perry Community Action Partnership of Mercer County 75 S Dock St Sharon, PA 16146 724.342.3532 www.capmercer.org 'Mercer Retrieved August 14, 2010, from httpl,'A w.phfa.orgMormsicounseling egenciesthci agencies/chci.pdf " Indicates Counties Serviced Community Action Southwest Washington County 150 W Beau St; STE 304 Washington, PA 15301 877.814.0788/724.852.2893 www.caswg.org `Washington Community Action Southwest - Waynesburg/Greene 58 E Greene St Waynesburg, PA 15370 877.814.0788/724.225.9550 www.ceswg.org 'Fayette, Greene, Huntingdon. Westmoreland Commission on Economic Opportunity - Wilkes-Barre 165 Amber Lane Wilkes-Barre, PA 18702 800.822.03591570.826.0510 www.ceopeoplehelpingpeople. org `Carbon, Columbia, Luzeme, Monroe Fair Housing Partnership of Greater Pittsburgh, Inc. 2840 Liberty Ave; STE 205 Pittsburgh, PA 15222 412.391.2535 www.pittsburghfairhousing.org 'Allegheny Fayette Co. Community Action Agency, Inc. 108 N Beeson Blvd Uniontown, PA 15401 800.427.4636 / 724.437.6050 www.fccaa.org 'Fayette, Somerset, Westmoreland Garfield Jubilee Association 5138 Penn Ave Pittsburgh, PA 15224 412.665.5204 `Allegheny Genesis Housing Corporation 208 DeKalb St; #212 Norristown, PA 19401 Community Action Committee of the Lehigh Valley 610.275.4357 1337 E Fifth St www.genesishousing.org Bethlehem, PA 18015 'Bucks, Chester, Delaware, 610.691.5620 Montgomery, Philadelphia www.ca v.org 'Barks, Carbon, Lehigh, Monroe, Northampton CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 www.congreso.net 'Philadelphia Council of Spanish Speaking Organization (CONCILIO) 705-09 N Franklin St Philadelphia, PA 19123 215.627.3100 elconcilio.net 'Philadelphia Credit Counseling Center 832 2nd St Pike Richboro, PA 18954 877.900.4222/215.396.1880 www.occ-credit.com 'Bucks, Delaware, Montgomery, Philadelphia Credit Counseling Center 408 Mill St Bristol, PA 19007 www.ccc-credit.oom 'Bucks, Delaware, Montgomery, Philadelphia Da-Network Housing Ministries, Inc. 1529 N. 7th St Philadelphia. PA 19122 215.927.3227 www.danetworkhousing.org 'Philadelphia Diversified Community Services @ Dixon House 1920 S 20th St Philadelphia, PA 19145 215.336.3511 wwwAcsphila.org 'Bucks, Delaware, Philadelphia Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 www.gernantown.org 'Delaware, Montgomery, Philadelphia Grace Neighborhood Development Corporation 5200 Oxford Ave Philadelphia, PA 19124 215.535.3885 'Philadelphia Greater Ede Community Action Committee 18 W 9th St Ede, PA 16501 814.459.4581 www.geeac.org 'Erie, McKean, Venango, Warren Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717.238.9540 'Cumberland, Dauphin, Perry Hispanic Association of Contractors and Enterprise (HACE) Philadelphia 167 W Allegheny Ave; STE 200 Philadelphia, PA 19140 215.426.1151 'Philadelphia Housing Alliance of York 35 S Duke St York PA 17401 717.854.1541 www.housingallianceofyork.com 'Adams, York Housing and Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle, PA 17013 866.683.5907 1717249.0789 www.cchra.com 'Cumberland Housing Development Corporation of Northeastern PA 163 Amber Ln Wilkes Barre, PA 18702 570.824.4803 'Luzeme, Wyoming Housing Opportunities of Beaver County 282 East End Ave Beaver, PA 15009 724.728.7511 www.hobcinfo.org `Beaver, Butler, Lawrence Housing Authority of the County of Butler 114 Woody Dr Butler, PA 16001 800.433.6327/724.287.6797 www.housingauthority, .com/Homeownership_Program.html 'Allegheny, Armstrong, Beaver, Butler, Clarion, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 www.housingpartnershipec.com `Chester, Delaware, Montgomery Indiana County Community Action Program, Inc. 827 Water St Indiana, PA 15701 724.465.2657 www.iccap.net 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 www.ifsinc.org 'Delaware, Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.8830 www.koreanoenter.org 'Delaware, Philadelphia Lancaster Housing Opportunities Partnership 44 N Christian St; STE 300 Lancaster, PA 17602 717.291.9945 www.lhop.org 'Lancaster Housing Association of Delaware Valley (HADV) - Lawrence County Community Action Housing Association Information Program (HAIP) Partnership (LCCAP) 658 N Watts St 241 W Grant St Philadelphia, PA 19123 New Castle, PA 16101 215.978.0224 888.252.5104 / 724.658.7258 www.hadv.org www.lccap.org/h.php 'Delaware, Philadelphia `Lawrence Lebanon County Housing and Redevelopment Authority 303 Chestnut St Lebanon, PA 17042 717.273.9326 www.lebanoncountyhousing.com `Lebanon Liberty Resources, Inc. (Serving Allentown and Philadelphia) 714 Market St; STE 100 Philadelphia, PA 19106 888.634.2155/215.634.2000 www.libertyresources.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Loveship, Inc. 2320 N 5th St Harrisburg, PA 17110 717.232.2207 'Cumberland, Dauphin, Perry Media Fellowship House, Inc. 4302 S Jackson St Media, PA 19063 610.565.0434 www.mediafellowshiphouse.org 'Chester, Delaware, Montgomery Mon Valley Initiative 305 E Eighth Ave Homestead, PA 15120 412.464.4000 www.monvalleyinitiative.com 'Allegheny, Armstrong, Beaver, Butler, Fayette, Greene, Indiana, Washington, Westmoreland Mt. Airy USA 6703 Germantown Ave; STE 200 Philadelphia, PA 19119 215.844.6021 www.mtairyusa.org 'Philadelphia Nazareth Housing Services (HE and C) 320 Brownsville Rd Pittsburgh, PA 15210 412.381.6925 www.mtnazamthcenter.org/nazareth_housing.htmI 'Allegheny Neighborhood Housing Services of Lackawanna County 709 E Market St Scranton, PA 18509 570.5582490 www. nhslackawannapa.org 'Lackawanna, Pike, Wayne Neighborhood Housing Services of Philadelphia 121 N Broad St; #5 Philadelphia, PA 19107 215.476.4205 www.phillynhs.org 'Philadelphia Neighborhood Housing Services Greater Barks 213 N 5th St; STE 1030 Reading, PA 19601 610.372.8433 www.nhsreading.org `Barks Retrieved August 14, 2010, from httpJAw .phfa.orgforms/counseling_agenciesrchci agencies?bhci.pdf Neighborworks Western PA 710 Fifth Ave; STE 1000 Pittsburgh, PA 15219 412.281.9773 www.nwwpa.org 'Allegheny, Armstrong, Beaver, Butler, Cambria, Fayette, Greene, Washington, Westmoreland New Kensington Community Development Corp.(NKCDC) 2515 Frankford Ave Philadelphia, PA 19125 215.427.0350 www.nkcdc.org 'Philadelphia NID-Housing Counseling-Philadelphia 3212 W. Cheltenham Ave Philadelphia, PA 19150 267.385.7624 'Delaware, Montgomery, Philadelphia Northern Cambria Community Development Corp. (NORCAM Group) 4200 Crawford Avenue Suite 200 Northern Cambria, PA 15714 888.676.8781 / 814.948.4444 'Bedford, Blair, Cambria, Cameron, Centre, Clearfield, Elk, Erie, Huntingdon, Jefferson, Somerse Northern Tier Community Action Corp. 135 West 4th Street Emporium, PA 15834 814.486.1161 'Cameron, Elk, McKean, Potter Northwest Counseling Service. Inc. 5001 North Broad Street Philadelphia, PA 19141 215.324.7500 'Bucks, Chester, Delaware, Montgomery, Philadelphia The Partnership CDC 4020 Market St; STE 1 DO Philadelphia, PA 19104 215.662.1612 www.thepadnershipcdc.org 'Philadelphia * Indicates Counties Serviced Pittsburgh Community Reinvestment Group St. Martin Center, Inc. (PCRG) 1701 Parade St 1901 Centre Avenue; STE 200 Erie, PA 16503 Pittsburgh, PA 15219 814.452.6113 412.391.6732 www.stmartincenter.org www.pcrg.org 'Centre, Crawford, Erie, McKean, 'Allegheny Mercer, Venango, Warren Schuylkill Community Action Step, Inc. (a.k.a. Lycoming-Clinton Counties 225 N Center St Commission for Community Action) Pottsville, PA 17901 2138 Lincoln St 570.622.1995 Williamsport, PA 17701 www.schuylidlicommunityaction.com 800.346.3020 / 570.326.0587 'Barks, Carbon, Lebanon, Lehigh, Luzeme, www.stepcorp.org Northumberland, Schuylkill 'Centre, Clinton, Lycoming, Union Shenango Valley Urban League 601 Indiana Ave Farrell, PA 19121 724.981.5310 www.svul.org 'Butler, Crawford, Lawrence , Venango South of South Neighborhood Association, Inc. (SOSNA) 1901 Christian St Philadelphia, PA 19146 215.732.8446 www.southofsouth.org 'Philadelphia South Philadelphia HOMES, Inc. (SPHINC) 1444 Point Breeze Ave Philadelphia, PA 19146 800.349.5904 / 215.334.4430 www.sphinc.com 'Philadelphia Southwest Community Development Corporation 6328 Paschall Ave Philadelphia, PA 19142 215.729.0800 www.southwestcdc.org 'Delaware, Philadelphia Southwestern PA Legal Services Fayette County. 48 E Main St Uniontown, PA 15401 888.855.3873 / 724.439.3591 Pathstone Corporation Pennsylvania www.splas.org 1625 North Second St 'Fayette Harrisburg, PA 17102 Southwestern PA Legal Services - 717'234.6616 Greene County www.ruralisc.org/pathstone_pa.htm 63 S Washington St 'Adams, Barks, Cambria, Chester, Clearfield, Waynesburg, PA 15370 Cumberland, Dauphin, Franklin, Somerset 688.855.3873 / 724.627.3127 Pennsylvania Interfaith Community Programs, Inc. www.splas.org Adam's County Housing Authority (ACHA) 'Greene 40 E High St Southwestern PA Legal Services - Gettysburg, PA 17325 Somerset County 717.334.1518 132 E. Catherine St ams g Somerset, PA 15501 *Adams 'Adams, Franklin, , 800.855.38731814.443.4615 Cumberland, Lackawanna, York www.splas.org Philadelphia Council for Community Advancement (PCCA) 1617 JFK Blvd; STE 1550 Philadelphia, PA 19103 215.567.7803 www.pcphousing.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Southwestern PA Legal Services - Washington County 10 W Cherry Ave Washington, PA 15301 888.855.3873 1724.225.6170 www.splas.org 'Washington Tableland Services Inc./Community Action Partnership for Somerset Cnty 535 E Main St Somerset, PA 15501 800.452.0148 / 814.445.9628 www.capfsc.org 'Bedford, Cambria, Fayette, Somerset, Westmoreland TABOR Community Services, Inc. 308 E King St Lancaster, PA 17608 800.788.5062 / 717.397.5182 www.tabomet.org 'Chester, Lancaster, Lebanon TREHAB Center, Inc. 703 S Elmer Ave; STE 104 Sayre, PA 18840 800.982.4045 / 570.888.0412 www.trehab.org 'Bradford TREHAB Center, Inc. 10 Public Ave Montrose, PA 18801 800.982.4045 / 570.278.3338 www.trehab.org 'Susquehanna TREHAB Center, Inc. - Tioga County 52 Plaza Ln Wellsboro, PA 16901 866.656.7788 / 570.724.5252 www.trehab.org 'Tioga United Communities Southeast Philadelphia 2029 S 8th St Philadelphia, PA 19148 215.467.8700 www.ucsep.org 'Philadelphia United Neighborhood Centers of Northeastern PA 410 Olive St Scranton, PA 18505 570.343.8835 'Lackawanna Universal Companies - Universal Community Homes 800 S 15th St Philadelphia, PA 19146 215.732.6518 'Philadelphia Urban League of Philadelphia 121 S Broad St; 9th FL Philadelphia, PA 19107 215.985.3220 www.urbardeaguephila.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4163 www.ulpgh.org 'Allegheny Voices for Independence 1107 Payne Ave Erie, PA 16503 866.407.0064 / 814.874.0064 www.voicesforindependence.org • Clarion, Elk, Erie, McKean, Mercer, Venango Warren-Forest Counties I Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, W Warren, PA 16365 800.231.1797 1814.726.2400 www.wfcaa.org 'Crawford, Forest, McKean, Warren West Oak Lane Community Development Corporation (CDC) 6259 Limekiln Pike Philadelphia, PA 19141 215.224.0880 'Montgomery, Philadelphia Westmoreland Community Action 226 S Maple Ave Greensburg, PA 15601 800.816.0022 / 724.834.1260 www.westmorelandca.org 'Westmoreland Women's Opportunity Resource Center (WORC) 2010 Chestnut St Philadelphia, PA 19103 215.564.5500 www.worc-pa.com 'Philadelphia Retrieved August 14, 2010, from http:Owww.phfa.org#orms/counseling_agencies&hci agenciesichci.pdf A LUMM 09/22/2010 1Randy L Lawrence 5405 Joshua Rd Mechanicsburg, PA 17050 (Rev. 9/2008) Date: September 22, 2010 OEOMN NOTICELOSUR TAKE 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. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCYMORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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. HOMEOWNER'S NAME(S): Randy L Lawrence PROPERTY ADDRESS: 5405 Joshua Rd Mechanicburg, PA 17050 LOAN ACCT. NO.: ORIGINAL LENDER: OPTION O MORTGAGE CORPORATION CURRENT SERVICER: American Home Mortgage Servicing, Inc. CURRENT LENDER: Wells Fargo Bank, N.A., as Trustee for Soundview Home Loan Trust 2007-OPTI , Asset-Backed Certificates, Series 2007-OPTI Page two HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE 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 IODATE . THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - 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 CURRENTL Y PROTECTED BY THE FILING OFA PETITION IN BANKR UPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMA TION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page three 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: 5405 Joshua Rd, Mechanicburg, PA 17050 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 07/01/2010: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 09/22/2010: $9,366.36 $3,032.64 $443.80 $0.00 $12,842.80 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $12,842.80, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other 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: American Home Mort ggage Servicingg,, Inc. 1525 S. Beltline Rd. Coppell, TX T5019 IF YOUDO NOT CURE THE DEFAULT - Ifyou do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right 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.Ifyou cure the default within the THIRTY (30) DAYperiod, 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) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE 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 five (5) 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. Page four HOW TO CONTACT THE LENDER Name of Lender: American Home Mortgage Servicing, Inc. Address: 1525 S. Beltline Rd. Coppell, TX 75019 Telephone Number: 1-877-304-3100 Fax Number: 1-866-497-1263 Contact Person: Brandon Wirth, Michael Heath E-mail Address: brandon.wirth@ahmsi3.com, michael.heath@ahmsi3.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may 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. YOUMAYALSO HAVE THE RIGHT. ° TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ° TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ° TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ° TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ° TO SEEK. PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES 5-7. American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, American Home Mortgage Servicing, Inc. American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019,1-877-304-3100 Action-Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh, PA 15219 800.792.2801/412.281.2102 www.actionhousing.org 'Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence - Philadelphia 1628 JFK Blvd-8 Penn Ctr, STE 2210 Philadelphia, PA 19103 215.218.4342 www.afinow.org 'Philadelphia Advocates for Financial Independence - Ridley Park 202 E Hinkley Ave Ridley Park, PA 19078 215.218.4342 www.afinow.org 'Chester, Delaware Alliance for Building Communities 830 Hamilton Mall Allentown, PA 18101 610.439.7007 'Lehigh, Northampton, Schuylkill American Credit Alliance, Inc. 2 S Delmorr Ave; STE 501 Morrisville, PA 19067 800.501.7526/215.295.7195 www.501plan.com 'Bucks, Montgomery Armstrong County Community Action Agency 705 Butler Rd Kittanning, PA 16201 724.548.3408 www.armstrongcap.com 'AnnsVOng Asociaci6n Puertoriquefios en Marche, Inc. (APM) 600 W Diamond St Philadelphia, PA 19122 7215.235.6070 www.apmphila.orgm 'Delaware, Philadelphia BASE, Incorporated 447 S. Prince St Lancaster, PA 17603 717.392.5467 www.baseinc.org `Lancaster Bayfront Neighborhood Action Team Organization, Inc. 312 Chestnut St Erie, PA 16507 814.459.2761 'Ede Blair County Community Action Agency 2100 6th Ave; STE 102 Altoona, PA 16602 800.238.9763/814.946.3651 'Blair Barks Community Action Program, Inc. 247 N Fifth St Reading, PA 19601 610.375.7866 www.racc.edu/SocalSemice/b090.aspx 'Barks, Schuylkill, Montgomery " Indicates Counties Serviced Bucks County Housing Group CCCS of Delaware Valley - 2324 Second St Pike; STE 17 Philadelphia Wrightstown, PA 18940 4400 North Reese St 866.866.0280 / 215.598.3566 Philadelphia, PA 19140 www.bchg.org 800.989.2227 1215.563.5665 'Bulks www.cccsdv.org 'Bucks, Chester, Delaware, Building United of Southwestern PA Montgomery, Philadelphia 801 N Homewood Ave; STE 201 Pittsburgh, PA 15208 412.281.4422 `Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland Campbell Street Family Youth and Community Association 600 Campbell St Williamsport, PA 17701 570.322.5515 www.campbelistreetcenter.org 'Lycoming Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 'Delaware, Montgomery, Philadelphia Cambria Community Development Corporation 401 Candlelight Or Ebensburg, PA 15931 814.472.6711 'Blair, Cambria, Delaware, Indiana, Somerset CCCS of Delaware Valley - Bristol 1230 Veterans Hwy; STE F1 Bristol, PA 19007 800.989.2227/215.563.5665 `Bulks CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; 10th FL Philadelphia, PA 19103 800.989.2227/215.563.5665 www.cccsdv.org 'Chester, Philadelphia CCCS of Delaware Valley - Chinatown 901-A Wood St Philadelphia, PA 19107 800.989.2227/215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - Coatesville 1001 East Lincoln Hwy; Suite 102 Coatesville, PA 19320 800.989.2227/215.563.5665 www.ccksdv.org 'Chester, Delaware CCCS of Delaware Valley - Jenkintown 261 Old York Rd; The Pavillion #401 Jenkintown, PA 19046 800.989.2227 1215.563.5665 www.occsdv.org 'Montgomery CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 800.989.2227/215.563.5665 www.ocmdv.org 'Delaware CCCS of Delaware Valley - Philadelphia 7340 Jackson St Philadelphia, PA 19136 800.989.2227/215.563.5665 www.occsdv.org 'Philadelphia CCCS of Delaware Valley - West Chester 770 E Market St; STE 190 West Chester, PA 19382 800.989.2227 / 215.563.5665 www.occsdv.org 'Chester, Delaware CCCS of Lehigh Valley - Pottstown 1954 E High St Pottstown, PA 19464 866.889.9347 www.oonsumercreditIv.org 'Chester, Montgomery CCCS of Lehigh Valley - Quakertown 127 S. 5th St; STE 155 Quakertown, PA 18951 866.889.9347 www.consumercrediUv.org 'Bulks CCCS of Lehigh Valley - Whitehall 3671 Crescent Court E Whitehall, PA 18052 866.889.9347 www.consumercredigv.org 'Carbon, Lancaster, Lehigh, Schuylkill CCCS of Lehigh Valley - Wyomissing 833 N Park Rd, M; STE 103 Wyomissing, PA 18072 866.889.9347 www.consumercreditlv.org 'Berks, Northampton CCCS of Northeastern PA - By Appt. Only 214 W. Walnut St Hazleton, PA 18201 800.922.9537 www.cccsnepa.org 'Carbon CCCS of Northeastern PA - Pittston 401 Laurel St Pittston, PA 18640 800.922.9537/570.602.2227 www.occsnepa.org 'Bradford, Carbon, Centre, Clearfield, Luzeme, Clinton, Columbia, Elk, Juniata, Lackawanna Lycoming, MifBin,Mon roe, Montour, Northumbeda Pike, Potter, Schuylkil, Snyder, Sullivan Susquehanna,Tioga,Union, Wayne,Wyoming CCCS of Northeastern PA - State College 202 W Hamilton Ave State College, PA 16801 800.922.9537/814238.3688 www.cccsnepa.org 'Blair CCCS of Northeastern PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA 18360 800.922.9537 / 570.602.2227 www.occsnepa.org 'Monroe CCCS of Western PA - Altoona 917A Logan Blvd; Royal Remax Plaza Altoona, PA 16602 888.511.2227/888.511.2227 www.cccepa.org 'Bedford, Blair, Cambria, Centre, Clearfield, Fulton, Huntingdon, Juniata, Somerset CCCS of Western PA - Butler 112 Hollywood Dr; STE 101 Butler, PA 16001 888.511.2227 / 888.511.2227 www.occspa.org 'Armstrong, Beaver, Butler, Clarion, Jefferson, Lawrence CCCS of Western PA- Erie 4402 Peach St; Lower Level Erie, PA 16509 888.511.2227 / 888.511.2227 www.cccspa.org 'Crawford, Elk, Erie, McKean, Mercer, Union, Venango, Warren CCCS of Western PA - Greensburg 1 N Gate Sq Greensburg, PA 15601 888.511.2227 / 888.511.2227 www.cccspa.org 'Indiana, Westmoreland CCCS of Western PA - Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg, PA 17110 888.511.2227/888.511.2227 www.Qccspa.org 'Dauphin, Juniata, Lebanon, Mifflin, Northumberland, Perry, Union CCCS of Western PA - Pittsburgh 2403 Sidney St; STE 400; River Park Commons Pittsburgh, PA 15203 888.511.2227 / 888.511.2227 www.ccmpa.org 'Allegheny, Cameron CCCS of Western PA - York 55 Clover Hill Road Dallastown, PA 17313 888.511.2227 / 888.511.2227 www.cccspa.org `Adams, Cumberland, Franklin, Lancaster, Lebanon, York Center for Family Services, Inc. 213 W Center St Meadville, PA 16335 814.337.8450 www.thecenter-nwpa.org 'Crawford, Mercer, Venango Center in the Park 5818 Germantown Ave Philadelphia, PA 19144 215.849.5100 www.centerinthepark.org 'Philadelphia Chester Community Improvement Project nd 412 Ave of the States Chester, PA 19013 610.876.8663 'Chester, Delaware, Montgomery, Philadelphia Community Action Commission - Capital Region 1514 Deny St Harrisburg, PA 17104 717.232.9757 www.cectricounty.org 'Cumberland, Dauphin, Perry Community Action Partnership of Mercer County 75 S Dock St Sharon, PA 16146 724.342.3532 www.capmercer.org 'Mercer Retrieved August 14, 2010, from http.IAvww.phfa.orgHormsrcounseling agencies/chci_agencies/chci.pdf * Indicates Counties Serviced Community Action Southwest - Washington County 150 W Beau St; STE 304 Washington, PA 15301 877.814.0788/724.852.2893 www.caswg.org 'Washington Community Action Southwest - Waynesburg/Green 58 E Greene St Waynesburg, PA 15370 877.814.0788/724.225.9550 www.ceswg.org 'Fayette, Greene, Huntingdon, Westmoreland Commission on Economic Opportunity - Wilkes-Barre 165 Amber Lane Wilkes-Barre, PA 18702 800.822.0359 / 570.826.0510 www.ceopeoplehelpingpeople.org 'Carbon, Columbia, Luzeme, Monroe Fair Housing Partnership of Greater Pittsburgh, Inc. 2840 Liberty Ave; STE 205 Pittsburgh, PA 15222 412.391.2535 www.pittsburghfairhousing.org 'Allegheny Fayette Co. Community Action Agency, Inc. 108 N Beeson Blvd Uniontown, PA 15401 800.427.4636!724.437.6050 www.fcGaa.org 'Fayette, Somerset, Westmoreland Garfield Jubilee Association 5138 Penn Ave Pittsburgh, PA 15224 412.665.5204 'Allegheny Genesis Housing Corporation 208 DeKalb St; #212 Norristown, PA 19401 Community Action Committee of the Lehigh Valley 610.275.4357 1337 E Fifth St www.genesishousing.org Bethlehem, PA 18015 *Bucks, Chester, Delaware, 610.691.5620 Montgomery, Philadelphia www.cadv.org •Berks, Carbon, Lehigh, Monroe, Northampton CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 www.congreso.net 'Philadelphia Council of Spanish Speaking Organization (CONCILIO) 705-09 N Franklin St Philadelphia, PA 19123 215.627.3100 elooncilio.net 'Philadelphia Credit Counseling Center 832 2nd St Pike Richboro, PA 18954 877.900.4222/215.396.1880 www.ccc-credit.com 'Bucks, Delaware, Montgomery, Philadelphia Credit Counseling Center 408 Mill St Bristol, PA 19007 www.occ-credit.com 'Bucks, Delaware, Montgomery, Philadelphia Da-Network Housing Ministries, Inc. 1529 N. 7th St Philadelphia, PA 19122 215.927.3227 www.danetworkhousing.org 'Philadelphia Diversified Community Services @ Dixon House 1920 S 20th St Philadelphia, PA 19145 215.336.3511 w Acsphila.org 'Bucks, Delaware, Philadelphia Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 www.germantown.org *Delaware, Montgomery, Philadelphia Grace Neighborhood Development Corporation 5200 Oxford Ave Philadelphia, PA 19124 215.535.3885 'Philadelphia Greater Erie Community Action Committee 18 W 9th St Erie, PA 16501 814.459.4581 www.gecac.org 'Erie, McKean, Venango, Warren Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717.238.9540 `Cumberland, Dauphin, Perry Hispanic Association of Contractors and Enterprise (HACE) Philadelphia 167 W Allegheny Ave; STE 200 Philadelphia, PA 19140 215.426.1151 'Philadelphia Housing Alliance of York 35 S Duke St York PA 17401 717.854.1541 www.housingailianceofyork.com 'Adams, York Housing and Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle, PA 17013 866.683.5907 / 717.249.0789 www.cchra.com 'Cumberland Housing Development Corporation of Northeastern PA 163 Amber Ln Wilkes Barre, PA 18702 570.824.4803 *Luzeme, Wyoming Housing Opportunities of Beaver County 282 East End Ave Beaver, PA 15009 724.728.7511 www.hobcinfo.org 'Beaver, Butler, Lawrence Housing Authority of the County of Buller 114 Woody Dr Butler, PA 16001 800.433.6327 / 724.287.6797 www.housingauthority .conVHomeownership_Progrem.html 'Allegheny, Armstrong, Beaver, Butler, Clarion, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 www. housingpartnershi pcc.oom *Chester, Delaware, Montgomery Indiana County Community Action Program, Inc. 827 Water St Indiana, PA 15701 724.465.2657 www.iceap.net 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 www.ifsinc.org *Delaware, Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.8830 www.koreancenter.org 'Delaware, Philadelphia Lancaster Housing Opportunities Partnership 44 N Christian St; STE 300 Lancaster, PA 17602 717.291.9945 www.lhop.org 'Lancaster Housing Association of Delaware Valley (HADV) - Lawrence County Community Action Housing Association Information Program (HAIP) Partnership (LCCAP) 658 N Watts St 241 W Grant St Philadelphia, PA 19123 New Castle, PA 16101 215.978.0224 888.252.5104/724.658.7258 www.hadv.org www.lccep.org/h.php 'Delaware, Philadelphia 'Lawrence Lebanon County Housing and Redevelopment Authority 303 Chestnut St Lebanon, PA 17042 717.273.9326 www.lebanoncountyhousirvg.com 'Lebanon Liberty Resources, Inc. (Serving Allentown and Philadelphia) 714 Market St; STE 100 Philadelphia, PA 19106 888.634.2155/215.634.2000 www.libertyresources.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Loveship, Inc. 2320 N 5th St Harrisburg, PA 17110 717.232.2207 *Cumbedand, Dauphin, Perry Media Fellowship House, Inc. 4302 S Jackson St Media, PA 19063 610.565.0434 www.mediafellowshiphouse.org *Chester, Delaware, Montgomery Mon Valley Initiative 305 E Eighth Ave Homestead, PA 15120 412.464.4000 www.monvalleyinitiative.com 'Allegheny, Armstrong, Beaver, Butler, Fayette, Greene, Indiana, Washington, Westmoreland Mt. Airy USA 6703 Germantown Ave; STE 200 Philadelphia, PA 19119 215.844.6021 www.mtairyusa.org 'Philadelphia Nazareth Housing Services (HE and C) 320 Brownsville Rd Pittsburgh, PA 15210 412.381.6925 www. mtnazarethcenler. org/nazareth_housing.html 'Allegheny Neighborhood Housing Services of Lackawanna County 709 E Market St Scranton, PA 18509 570.558.2490 www.rihslackawannapa.org 'Lackawanna, Pike, Wayne Neighborhood Housing Services of Philadelphia 121 N Broad St; #5 Philadelphia, PA 19107 215.476.4205 www.phillynhs.org *Philadelphia Neighborhood Housing Services Greater Barks 213 N 5th St; STE 1030 Reading, PA 19601 610.372.8433 www.nhsmading.org 'Barks Retrieved August 14, 2010, from http.IAw .phfa.org4bims1counseling-agencies/chci_agencies/chci.pdf Neighborworks Western PA 710 Fifth Ave; STE 1000 Pittsburgh, PA 15219 412.281.9773 www.nwwpa.org 'Allegheny, Armstrong, Beaver, Butler, Cambria, Fayette, Greene, Washington, Westmoreland New Kensington Community Development Corp.(NKCDC) 2515 Frankford Ave Philadelphia, PA 19125 215.427.0350 www.nkodc.org 'Philadelphia NID-Housing Counseling-Philadelphia 3212 W. Cheltenham Ave Philadelphia, PA 19150 267.385.7624 'Delaware, Montgomery, Philadelphia Northern Cambria Community Development Corp. (NORCAM Group) 4200 Crawford Avenue Suite 200 Northam Cambria, PA 15714 888.676.9781 / 814.948.4444 `Bedford, Blair, Cambria, Cameron, Centre, Clearfield, Elk, Erie, Huntingdon, Jefferson, Somerse Northern Tier Community Action Corp. 135 West 4th Street Emporium, PA 15834 814.486.1161 `Cameron, Elk, McKean, Potter Northwest Counseling Service, Inc. 5001 North Broad Street Philadelphia, PA 19141 215.324.7500 'Bucks, Chester, Delaware, Montgomery, Philadelphia The Partnership CDC 4020 Market St; STE 100 Philadelphia, PA 19104 215.662.1612 www.thepartnershipcdc.org 'Philadelphia " Indicates Counties Serviced Pittsburgh Community Reinvestment Group St. Martin Center, Inc. (PCRG) 1701 Parade St 1901 Centre Avenue; STE 200 Erie, PA 16503 Pittsburgh, PA 15219 814.452.6113 412.391.6732 www.stmartincenter.org www.pcrg.org 'Centre, Crawford, Ede, McKean, 'Allegheny Mercer, Venango, Warren Schuylkill Community Action Step, Inc. (a.k.a. Lycoming-Clinton Counties 225 N Center St Commission for Community Action) Pottsville, PA 17901 2138 Lincoln St 570.6221995 Williamsport, PA 17701 www.schuylkillcemmunityaction.com 800.346.3020 1570.326.0587 `Barks, Carbon, Lebanon, Lehigh, Luzeme, www.stepoorp.org Northumberland, Schuylkill 'Centre, Clinton, Lycoming, Union Shenango Valley Urban League 601 Indiana Ave Farrell, PA 19121 724.981.5310 www.svul.org 'Butler, Crawford, Lawrence , Venango South of South Neighborhood Association, Inc. (SOSNA) 1901 Christian St Philadelphia, PA 19146 215.732.8446 www.southofsouth.org 'Philadelphia South Philadelphia HOMES, Inc. (SPHINC) 1444 Point Breeze Ave Philadelphia, PA 19146 800.349.5904/215.334.4430 www.sphinc.oom 'Philadelphia Southwest Community Development Corporation 6328 Paschall Ave Philadelphia, PA 19142 215.729.0800 www.southwestodc.org 'Delaware, Philadelphia Tableland Services Inc./Community Action Partnership for Somerset Cnty 535 E Main St Somerset, PA 15501 800.452.0148/814.445.9628 www.capfsc.org 'Bedford, Cambria, Fayette, Somerset, Westmoreland TABOR Community Services, Inc. 308 E King St Lancaster, PA 17608 800.788.5062/717.397.5182 www.tabometorg 'Chester, Lancaster, Lebanon TREHAB Center, Inc. 703 S Elmer Ave; STE 104 Sayre, PA 18840 800.982.4045/570.888.0412 www.trehab.org 'Bradford TREHAB Center, Inc. 10 Public Ave Montrose, PA 18801 800.982.40451570.278.3338 www.trehab.org 'Susquehanna Southwestern PA Legal Services - Fayette County. 48 E Main St Uniontown, PA 15401 888.855.3873 / 724.439.3591 Pathstone Corporation Pennsylvania www.splas.org 1625 North Second St 'Fayette Harrisburg, PA 17102 Southwestern PA Legal Services - 717234'6616 Greene County www.ruralisc.org/pathstonepa.htm 63 S Washington St 'Adams, Barks, Cambria, Chester, Clearfield, Waynesburg, PA 15370 Cumberland, Dauphin, Franklin, Somerset 888.855.38731724.627.3127 Pennsylvania Interfaith Community Programs, Inc. www.splas.org Adam's County Housing Authority (ACHA) `Greene 40 E High St Southwestern PA Legal Services - burg, PA 17325 Somerset County 717.334.1518 132 E. Catherine St www.adamsc ams g Somerset, PA 15501 'Adams `Adams, Franklin, , 800.855.3873 / 814.443.4615 Cumberland, Lackawanna, York www.splas.org '.Cmm?renf Philadelphia Council for Community Advancement(PCCA) 1617 JFK Blvd; STE 1550 Philadelphia, PA 19103 215.567.7803 www.pccahousing.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Southwestern PA Legal Services Washington County 10 W Cherry Ave Washington, PA 15301 888.855.3873 / 724.225.6170 www.splas.org 'Washington TREHAB Center, Inc. - Tioga County 52 Plaza Ln Wellsboro, PA 16901 866.656.7788/570.724.5252 www.trehab.org 'Tioga United Communities Southeast Philadelphia 2029 S 8th St Philadelphia, PA 19148 215.467.8700 www.ucsep.org 'Philadelphia United Neighborhood Centers of Northeastern PA 410 Olive St Scranton, PA 18505 570.343.8835 'Lackawanna Universal Companies - Universal Community Homes 800 S 15th St Philadelphia, PA 19146 215.732.6518 'Philadelphia Urban League of Philadelphia 121 S Broad St; 9th FL Philadelphia, PA 19107 215.985.3220 www.urbanleaguephila.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4163 www.ulpgh.org 'Allegheny Voices for Independence 1107 Payne Ave Erie, PA 16503 866.407.0064/814.874.0064 www.voicesforindependence.org Clarion, Elk, Erie, McKean, Mercer, Venango Warren-Forest Counties I Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, W Warren, PA 16365 800.231.1797/814.726.2400 www.wfcaa.org 'Crawford, Forest, McKean, Warren West Oak Lane Community Development Corporation (CDC) 6259 Limekiln Pike Philadelphia, PA 19141 215.224.0880 `Montgomery, Philadelphia Westmoreland Community Action 226 S Maple Ave Greensburg, PA 15601 800.816.0022/724.834.1260 www.westmorelandca.org 'Westmoreland Women's Opportunity Resource Center (WORC) 2010 Chestnut St Philadelphia, PA 19103 215.564.5500 www.worc-pa.com `Philadelphia Retrieved August 14, 2010, from http-,IA w .phfa.org/formslcounsefing_agenciesbhci agencies/chci.pdf SHERIFF'S OFFICE OF CUMBERLAND COUNTY'-_ Ronny R Anderson Sheriff mm'' Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF Wells Fargo Bank NA vs. Randy L. Lawrence (et al.) Case Number 2011-2985 SHERIFF'S RETURN OF SERVICE 03/15/2011 09:09 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 15, 2011 at 2109 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Randy L. Lawrence, by making known unto himself personally, at 5405 Joshua Road, 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. RYAN BURG M, DEPUTY 03/15/2011 09:09 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 15, 2011 at 2109 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sharon A. Lawrence, by making known unto Randy Lawrence, Husband of Defendant at 5405 Joshua Road, 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. SHERIFF COST: $54.00 March 16, 2011 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF to! Coun?ySuite Sheriff. Teieosoft. Inc. In the Court of Common Pleas of Cumberland County -, WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT I, ASSET- BACKED CERTIFICATES, SERIES 2007-OPT1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. SHARON A. LAWRENCE RANDY L. LAWRENCE (Mortgagor(s) and Record Owner(s)) 5405 Joshua Road Mechanicsburg, PA 17050 Defendant(s) PRAECIPE FOR JUDGMENT j?' No. 2011-29854' r " 7i 17 p Ac _ ?r 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 SHARON A. LAWRENCE and RANDY L. LAWRENCE by default for want of an Answer. Assess damages as follows: Debt Interest from 04/28/2011 to Date of Sale per diem at $83.66 Total (Assessment of Damages attached) $488,832.66 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 LDB C MCCAFF TY & MCKEEVER Mic 56129 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 otv?k ek wSi.4899 9.4 ZS! 7SI AND NOW (9-6 / ( , Judgment is entered in favor of WELLS FARGO BANK, N.A., ASTRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT I, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1 and against SHARON A. LAWRENCE and RANDY L. LAWRENCE by default for want of an Answer and damages assessed in the sum of $488,832.66 as per ve certification. ro 0 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1 Plaintiff vs. SHARON A. LAWRENCE RANDY L. LAWRENCE Defendant(s) NO. 2011-2985 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SOLDIERS' AND SAILORS' CIVIL RELIEF ACT OF 1940 AS AMENDED 1. The undersigned attorney with Goldbeck McCafferty & McKeever, as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, SHARON A. LAWRENCE, has a last known residence of 5405 Joshua Road, Mechanicsburg, PA 17050. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: 4/27/2011 By: G05tME K CAFFERTY MCKEEVER Michael c 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 Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Apr-27-2011 11:01:41 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency LAWRENCE SHARON Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Nay A. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL httn://www.defenselink.mil/fag/yis/PC09SLDR html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 407001 1 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:8760DVVQV2 https://www.dmdc.osd.mil/appj/scra/popreport.do 4/27/2011 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1 Plaintiff vs. SHARON A. LAWRENCE RANDY L. LAWRENCE Defendant(s) NO. 2011-2985 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SOLDIERS' AND SAILORS' CIVIL RELIEF ACT OF 1940 AS AMENDED 1. The undersigned attorney with Goldbeck McCafferty & McKeever, as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, RANDY L. LAWRENCE, has a last known residence of 5405 Joshua Road, Mechanicsburg, PA 17050. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: 4/27/2011 By: GOLD C AFFERTY MCKErE i R Michael Mc eeve 129 - (ary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Apr-27-2011 10:59:57 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency LAWRENCE RANDY Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Aftt A 4AOJ--A?? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL httr)://www.defenselink.mil/fag/Dis/PC09SLDR.htrnl. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 4/27/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCR,4 is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:QR0I29NJO https://www.dmdc.osd.mil/appj/scra/popreport.do 4/27/2011 GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT I, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT1 4650 Regent Blvd Irving, TX 75063 Plaintiff VS. SHARON A. LAWRENCE RANDY L. LAWRENCE (Mortgagor(s) and Record owner(s)) 5405 Joshua Road Mechanicsburg, PA 17050 Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 2011-2985 Please enter Judgment in favor of WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1, and against SHARON A. LAWRENCE and RANDY L. LAWRENCE 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 th Complaint, in the sum of $488,832.66. B CK CAFFER & MCKEEVER Michael Mc . 6129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPTI 4650 Regent Blvd Irving, TX 75063 and that the name(s) and last known address(es) of the Defendant(s) is/are SHARON A. LAWRENCE, 5405 Joshua Road Mechanicsburg, PA 17050 and RANDY L. LAWRENCE, 5405 Joshua Road Mechanicsburg, PA 17050; By GOLDBECK WCAFFER Y & MCKEEVER 1Gffci eever Pa. ID 6129 Gary McCafferty Pa. 42386?? 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 06/01/2010 through 04/27/2011 Reasonable Attorney's Fee Late Charges Escrow Payments Due 4 X $93.42 Escrow Advance Total Fees NSF Charges Recoverable Balance AND NOW, this day of $444,166.77 $35,751.69 $1,300.00 $3,590.73 $373.68 $3,156.79 $30.00 $150.00 $313.00 $488,832.66 By: - G ECK M AFFERTY & CKEEVER Michael c 561 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 , 2011 damages are assessed as above. Qrothy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N011-2985 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPTI ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1 Plaintiff (s) From SHARON A. LAWRENCE and RANDY L. LAWRENCE (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 $488,832.66 L.L.$.50 Interest from 4/28/2011 to Date of Sale per diem at $83.66 Atty's Comm % Due Prothy $2.00 Atty Paid $186.50 Plaintiff Paid Date: 5/4/11 Other Costs (Seal) REQUESTING PARTY: Name: GARY MCCAFFERTY, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 uepury Supreme Court ID No. 42386 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. SHARON A. LAWRENCE RANDY L. LAWRENCE Mortgagor(s) and Record Owner(s) 5405 Joshua Road Mechanicsburg, PA 17050 Defendant(s) TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 2011-2985 L. l PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: LJ awA $au.oo f d at S4•ov cap 9-a-00 4 a. $o u,. .5,84.5o pbl Q,? Amount Due Interest from 04/28/2011 to Date of Sale per diem at $83.66 (Costs to be added) ? C $488,832.66 - By: GOL MCCAFFERTY MCKEEVER Michael Mc . I 29 Gary McCafferty Pa. ID 42386r,--" Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ?ta? ? 4c e'e. ?r , $p LG rr,?as87s! (v .c- G -F3 a a z 0 0 00 N o C) N oa O U x H z H w ?¢ a ?Oo N O ? O W Q?Dw z?W xQQ U z¢0w OW Q U w 3 A > U ?A¢ 0 ry) z zz° ° p old oa ,¢ b1V) ¢en a Q¢? bq G4 GG Ed w yw?^? N 0 a 10 U E 4 ?r+ ? _ O rC O 9 N z S . bb 0 Pro a? CJ ¢ p4 '? o ? x a' c ? P, ALL that certain piece, parcel or lot of land together with improvements, situated In Hampden Township, Cumberland County Pennsylvania and bounded and described as follows: BEGINNING at a point On Western right-of-way line of Joel Drive (50.00 Ret wide) said point being located at the Southeastern comer of Lot No.20 I; then along said. right-of-way line on the arc of a circle curving to the left, having a radius of 425.00 feet, and an arc length of 7.78 feet, to a point; then South 14 degrees 19 minutes 47 seconds East, for a distance of 49.30 feet, to a point on the arc of a circle curving to the right, having a radius of 25.00 feet, and an arc length of 35.88 feet, to a point on the Northern right-of-way line of Joshua Road (50.00 feet wide); then along said right-of-way line on that arc of a circle curving to the left, having a radius of 475.00 feet and an arc length of 92.24 feet. to a point; Then South 56 degrees 46 minutes 43 seconds West, and through a 15.00 foot wide drainage easement, for a distance of 13.58 feet, to a point in line of proposed Phase VIII; then along said proposed Phase VII, mid along the centerline of said 15.00 foot wide drainage easement, North 33 degrees 13 minutes 17 seconds West for a distance of 105.00 feet, to a point in an existing iron pin; then North 10 degrees 43 minutes 57 seconds East, for a distance of 56.95 feet, to a point at the Southwestern comer of Lot No, 20 I; then along the Southern boundary line of Lot No. 201 South 72 degrees 16 minutes 00 seconds East, for a distance of 58.89 feet to a point; then North 83 degrees 54 minutes 38 seconds East, for a distance of 85.00 feet to a point and the place of BEGENNINING This piece, parcel or lot of land contains approximately 15,436.21 square feet ofland, has an address of 5405 Joshua Road Mechanicsburg, Pennsylvania 17055, and is known and numbered as Lot No. 202 on the Final Re-Subdivision Plan for Good Hope Farms South Phase IV - Lot Nos. 20 I and 202, which is retarded in. Cumberland County in Plan Book 81, Page 66. Parcel# 10-19-1602-108 Property address: 5405 Joshua Road, Mechanicsburg, PA 17050 Being the same premises which McNaughton Company, by Deed dated 09/29/2000 and recorded 10/02/2000, in the Recorder's Office of Cumberland County, in Deed Book 230 Page 51, granted and conveyed unto Randy L. Lawrence and Sharon A. Lawrence, husband and wife. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. SHARON A. LAWRENCE RANDY L. LAWRENCE (Mortgagor(s) and Record Owner(s)) 5405 Joshua Road Mechanicsburg, PA 17050 1 L) j- j7 AoG:m PND UVViV i'PJ CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 2011-2985 WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT I, ASSET- BACKED CERTIFICATES, SERIES 2007-OPT1, Plaintiff in the above action, by counsel, 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: 5405 Joshua Road Mechanicsburg, PA 17050 LName and address of Owner(s) or Reputed Owner(s): SHARON A. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SHARON A. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 PENNS IN THE COURT OF COMMON PLEAS of Cumberland County 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 5405 Joshua Road 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 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: ADril 27.2011 By: L G DBECK M AFFERTY & CKEEVER Michae TXM? 561 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 2011-2985 r GOLDBECK McCAFFERTY & McKEEVER Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff In"IDLRLAND C?I" WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT I, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT1 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. SHARON A. LAWRENCE RANDY L. LAWRENCE Mortgagor(s) and Record Owner(s) 5405 Joshua Road Mechanicsburg, PA 17050 Defendant(s,' Docket No. 2011-2985 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LAWRENCE, SHARON A. SHARON A. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 Your house at 5405 Joshua Road, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courtjudgment of $488,832.66 obtained by WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT I, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 2011-2985 1. The sale will be cancelled if you pay to WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I . 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: ft://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 2011-2985 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 aWx. 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 homeretentionkgoldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 10663017C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 for Plaintiff SY04 WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT1 4650 Regent Blvd Irving, TX 75063 VS. SHARON A. LAWRENCE and RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 OF Cumberland COUNTY No. 2011-2985 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: Plaintiff is the holder of a mortgage upon the premises 5405 Joshua Road, Mechanicsburg, PA, 17050, hereinafter, the "mortgaged premises". Defendants, SHARON A. LAWRENCE and RANDY L. LAWRENCE, are the mortgagors and real owners of the mortgaged premises. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, Jill P. Jenkins, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that Defendant, Randy L. Lawrence has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact Defendant, Randy L. Lawrence to request his concurrence. IN THE COURT OF COMMON PLEAS The last known address of Defendant, Randy L. Lawrence, is 234 Fox Drive, Mechanicsburg, PA 17055, from our investigative search. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant, Randy L. Lawrence, at the property address, 5405 Joshua Road, Mechanicsburg, PA 17050. The Sheriff's return states Defendant, Randy L. Lawrence moved and left no forwarding address. Service was also attempted at 234 Fox Drive, Mechanicsburg, PA 17055, without success. Per the Process Server he spoke with John Doe who refused his name and refused to accept service; John Doe stated he never heard of Defendant, Randy L. Lawrence and that the home belongs to a Lisa. Defendant, Randy L. Lawrence worked at Lawrence Chevrolet, Inc. located at 6445 Carlisle Pike, Mechanicsburg, PA 17055, several years ago but no other information was provided. A Freedom of Information Act inquiry was conducted and no new addresses were found for Defendant, Randy L. Lawrence, per our investigative search. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Randy L. Lawrence. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Randy L. Lawrence, by posting the premises and certified and regular mail to the Defendant's last known address. I dh I, A A A-, By: KML LA GRO , P.C. Michael cKeev Pa. ID 56129 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 Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 106630FC Attorney/Law Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: RANDY L. LAWRENCE Property Address: Street: 5405 Joshua Road City: Mechanicsburg State: PA Zip: 17050 Skip Results: Date of Birth: ProVest File Number: 3003283 Last Known Address (as of 8/4/2011) Street: 5405 Joshua Rd City: Mechanicsburg State: PA Zip: 17050 7228 Death Record Search As of 08/04/2011, the Social Security Administration has no death record on file for RANDY L. LAWRENCE Social Security Number [X] Verifed [ ] Not Verified SSN# XXX-XX-XX89 Employment Search (717) 766-0284: Called possible business, LAWRENCE CHEVROLET, female stated defendant hasn't worked there in several years. (717) 691-8520: Called possible business, HOP DRIVE-IN CAFE, number is not in service. (717) 795-2717: Called possible business, LAWRENCE PRE-OWEND, number is not in service. (717) 795-0785: Called possible business, YOUR HAIR AFFAIR, number is not in service. Business Records Search THE HOP DRIVE-IN CAFE, INC. 675 WILLIAMS GROVE RD MECHANICSBURG PA 17055-0 THOMAS R MARTIN President 234 FOX DR MECHANICSBURG PA 17055-21 RANDY L LAWRENCE Treasurer 234 FOX DR MECHANICSBURG PA 17055- 21 LAWRENCE CHEVROLET, INC. Active 6445 CARLISLE PIKE MECHANICSBURG PA 17055-0 GARY LAWRENCE President 6445 CARLISLE PIKE MECHANICSBURG PA 17055-21 JOAN LAWRENCE Secretary 6445 CARLISLE PIKE MECHANICSBURG PA 17055-21 JOAN LAWRENCE Treasurer 6445 CARLISLE PIKE MECHANICSBURG PA 17055-21 RANDY LAWRENCE Vice President 6445 CARLISLE PIKE MECHANICSBURG PA 17055-21 Creditor Header Inquiry The latest address from the credit header info is: Address: 5405 JOSHUA RD, MECHANICSBURG, PA 17050 7228 Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Vehicle Records Search' Drivers License Information Search No current records found. Governmental**+ Non-governmental Professional Licenses Search No current records found. Freedom Of Information Act Inquiry The following addresses were sent to the United States Postal inspector at the Made to U.S. Postal Service zip code listed with no return information to date: 5405 JOSHUA ROAD MECHANICSBURG I PA 1170501 CUMBERLAND COUNTY Military Search BASED ON THE INFORMATION YOU HAVE FURNISHED, THE DMDC DOES NOT POSSESS ANY INFORMATION INDICATING THE INDIVIDUAL STATUS. Inquiry of Relatives, (717) 691-1556: Called possible relative, HAZEL QUIGLEY, there was no Neighbors. & Friends answer. (717) 791-9921: Called possible relative, GARY LAWRENCE, female does no have a phone number or address for the defendant. Comments: (717) 877-1753: Called possible number of defendant, RANDY L. LAWRENCE, left message, no response. Uata not available in AL, AR, CA, HI, NH, OR, PA, VA, WA. " Historical data in CO, DE, ID, IL, KY, LA, MD, MA, MS, MO, NH, NO, SC, Wv. + Data available in CO, CT, DE, FL, ID, IL, KY, LA, ME, MD, MA, MI, MN, MS, MO, NH, NO, OH, SC, TN, TX, WV, WI, WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities. Under penalties of perjury, I declare that I have read the foregoing affidavit and that the facts stated in it are true. ?- Qij Heather Winchell Provest Services LLC 8/4/2011 NOTARY PUBLIC-STATE OF FLORIDA • Anastasia Kappiris MiIler Commission #DD712204 %;i.'` Expires: SEP. 06, 2011 BONDED THRD ATLAMC BONDn1G COy INQ STATE OF FLORIDA AUG OUNTY OF HILLSBOROUGH G U 4 2011 Sworn to or affirmed and signed before eon this _ day of _, (Seal) Signature of Notary Public Printed Name of otary Public P onally Known ( ) Produced as identification SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?otr at t?ambrr???fd P + e! 11, 441 n _'` t a 0-MCE OF THE $tiSFnFF Wells Fargo Bank NA vs. Randy L. Lawrence (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2011-2985 06/20/2011 12:08 PM - 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: Sharon A. Lawrence, but was unable to locate the Defendant in his bailiwick. He therefore retums the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 5405 Joshua Road, Mechanicsburg, PA 17055. Defendant does not reside at adress stated. 06120/2011 12:08 PM - Deputy Stephen Bender, being duly sworn according to law, states service was perforrned by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 5405 Joshua Road, Mechanicsburg, PA 17050, Cumberland County. 07/12/2011 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: Sharon A. Lawrence, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/26/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Adams County upon, Sharon A. Lawrence, personally, at 3009 Market Street Road, Harrisburg, PA 1710; on 7/18111 at 11:44 a.m.. So Answers: W. Conway, Deputy Sheriff. 07/29/2011 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: Randy L. Lawrence, but was unable to locate the Defendan in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 5405 Joshua Road, Mechanicsburg, PA 17050, Defendant Moved did not leave a forwarding address at post office. SHERIFF COST: $1,045.94 July 29, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CouMySuft SW.fl. Telea%*. Ir. IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPTI, ASSET- BACKED CERTIFICATES, SERIES 2007-OPT1; et seq. Plaintiff (Petitioner) V. SHARON A. LAWRENCE; et al. Defendant (Respondent) CASE and/or DOCKET No.: 2011-2985 Sheriffs Sale Date: 9/7/2011 AFFIDAVIT OF NON-SERVICE Complaint Summons f Other: NOTICE OF SHERIFF'S SALE I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I attempted to serve RANDY L. LAWRENCE the above process on the 23 day of August, 2011, at 8:30 o'clock, PM, at 234 FOX DRIVE MECHANICSBURG, PA 17055, County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: Moved Unknown No Answer Vacant Other: SPOKE WITH A W/M/45/67195/13ROWN, HE REFUSED HIS NAME AND REFUSED TO ACCEPT SERVICE, HE STATED "HE NEVER HEARD OF RANDY, THAT THIS IS LISA'S HOUSE." PA HPH-8360. Service was attempted on the following dates/times: 2) Commonwealth/State of 1d County of Stn, s ) SS: 3) Before me, the undersigned notary public, this day, personally, appeared A; wr• M*.-^ jr _ to me known, who being duly sworn according?o law, deposes the following: I hereby swear or affin# i#t the facts set forth in the foregoing Affidavit of Non-Service are true and correct. of Affiant) File Number:106630FC Subscribed and s efore me this ? day r -, 20Aq COMMONWEALTH OF PENNSYLVANIA Notary Public (-Notarial Seal Edc M. Afflerbach, Notary Public Washington Twp., Berks County ,MY Commission Expires Nov. 18, 2013 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1 4650 Regent Blvd Irving, TX 75063" vs. SHARON A. LAWRENCE and RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 2011-2985 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Notice of Sheriff's Sale against Defendant, Randy L. Lawrence, which the Sheriff has been unable to personally serve upon Defendant, Randy L. Lawrence. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Notice of Sheriff's Sale upon Defendant, Randy L. Lawrence, by posting the premises and certified mail and regular mail to the Defendant's last known address. By: KML A OUP, P.C. Mich 1 Mc eever Pa. ID 56129 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 3065881/ Attorneys for Plaintiff KN[L Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPTI, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT I 4650 Regent Blvd Irving, TX 75063 vs. SHARON A. LAWRENCE RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 CERTIFICATE OF SERVICE of Cumberland County No. 2011-2985 Lourdes Geena, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, Randy L. Lawrence thisay of September, 2011, by first class mail, postage prepaid. RANDY L. LAWRENCE 234 Fox Drive Mechanicsburg, PA 17055 RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 By: KML Law Group, P. . Lourdes Gerena, Legal Secretary Direct Phone: 215-825-6338 IN THE COURT OF COMMON PLEAS KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 WELLS FARGO BANK, N.A., AS TRH SOUNDVIEW HOME LOAN TRUST 200 - T, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT1 4650 Regent Blvd Irving, TX 75063 Plaintiff VS. SHARON A. LAWRENCE RANDY L. LAWRENCE Mortgagor(s) and Record Owner(s) 5405 Joshua Road Mechanicsburg, PA 17050 Defendant(s) LVANIA CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P 3129.2 (c) (2) Term No. 2011-2985 Rachael Klaus, an employee of KML Law Group, P.C., 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/competent adult (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. Premises was posted by "`W-@?/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. e ectf 1 bmitted, ach {taus Legal Assistant 106630FC CF: 03/10/2011 SD: 12/07/2011 $488,832.66 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 10 a r o ? o T 0 s foe V g rn 0 [G m u- ? m N ???IIIIII??? fV ¢: d?nun o ? 0 e o g ?e w V a CL (n m m m -? m V x Z m m E c v ? CL o m EfOmvo Z) N a-> X V p W V` LL O 0 ZS Qc $$ ao mL r d) -3 LO C W d CD a ? ,.. O _ ?0 Z no m O m $R I a v ffi r W N W m J 'N W C M WX m m ? E'w C) f, Ir co U mE U 20 ???? 0 LL - J0 Ir O U aW r IO o - = o ° ' Z LL O - C 's > - p m o € F- M O Q m F 7 m o O o 0 L) 2 W z U) W w ?? I F- E `Q a - - U NQ a ' VI Q ? O a f rd m 000 U? F m Q O C a ???? W Z a1 2:) m'- W W L+ 0 m- N C m 0000 E oUaU mmm z 0 a. O p E 16 M'z Z.a V ° F `c w z E - w a m s ?a a 9 Q D 3 3: N C) W a- 04 [Up YJ w Lo CD < 10 o E QQ DaH?_70 za v O d m CS U) N c (i V L 6 ( 6 C 6 ? E 1 $ ° c 01 a e (L m `o Y C C a E U N O m a N °o N M L co a 0 N O 0 a C 7 0 U C lD N E U U LL 0 m (O (O O r- W U Z w g J } Z Q w U Z w Q J Q Z O Q S WELLS FARGO BANK, N_A_, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPTI, ASSET-BACKED CERTIFICATES, SERIES 2007-OPTI 4650 Regent Blvd Irving, TX 75063 vs. SHARON A. LAWRENCE and RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 ORDER 2011-2985 AND NOW, this day of W 2011, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff s good faith efforts to ascertain the present whereabouts of Defendant, Randy L. Lawrence, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff's Sale upon Defendant, Randy L. Lawrence, by posting a copy of the Notice upon the premises 5405 Joshua Road, Mechanicsburg, PA, 17050, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 234 Fox Drive, Mechanicsburg, PA 17055, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Randy L. Lawrence, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: - 14 U. L J., I Distribution list: Michael T. McKeever, Esquire, Suite 5000 - BNY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 RANDY L. LAWRENCE, 234 Fox Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Form 3877 Page: 1 Mailer's Name and Address: Permit Number: MA ert er. Num. Goldbeck McCafferty & McKeever 969005937 SendSuite - MAC v6.25 .6.25.L 701 Market Street Sequence Number: PHILADELPHIA, PA 19106 0001407 Pc ID #1 Addressee Name Postage ES ES Insured Due Total Article # Delivery Address Type Fee qc ?4 t Vd d,H Value Sender Charge 100003JC1-27 9171999991703075876333 COLON, JESENIA 2402 West Emmaus Avenue 0.640 C 02.8 AL. ° ERR 01 1 0.00 4.640 Allentown, PA 18103 i 1? r a , 00.1 100189AB2-13 BRITTAIN, ANGELA C. 0.640 C 02.850,'t 0.00 4 640 9171999991703075876432 2981 Balsa Street ERR ?1.15b . , ---'' . York, PA 17404 100189KB2-13 BRITTAIN, KENNETH A. 0.640 C 02.850 0 00 4 640 9171999991703075876418 2981 Balsa Street ERR 01.150 . . York, PA 17404 101206DK12-9 KEMMERLE, DONNA L. 0.640 C 02.850 0.00 4 640 9171999991703075876470 162 Eberts Lane ERR 111.150 . Lehighton, PA 18235 101731YG1-10 GALIBOV, YAKOV 0.640 C 02.850 0.00 4 640 9171999991703075876210 11990 Dumont Road ERR -71.150 . Philadelphia, PA 19116 102858PN1-10 NAGREM, PAMELA L. 0.640 C 02.850 0 00 4 640 9171999991703075876227 3512 Gloucester Lane ERR 01.150 . . Philadelphia, PA 19114 103134G612-9 BROWN, GREGORY D. 0.640 C 02.850 0.00 4 640 9171999991703076745249 343 Schuylkill Avenue ERR 01.150 . Reading, PA 19601 103134KB12-9 BROWN, KEVIN D. 0.640 C 02.850 0 00 4 640 9171999991703076745232 3915 E. Camelback Rd, Apt. 207 ERR 01.150 . . Phoenix, AZ 85018 103134KB12-9.2 BROWN, KEVIN D. 0.640 C 02.850 0 00 4 640 9171999991703076745256 343 Schuylkill Avenue ERR 111.150 . . Reading, PA 19601 103134SB12-9 The Unknown Heirs of Shirley M 0.640 C 02.850 0 00 4 640 9171999991703076745225 343 Schuylkill Avenue ERR 01.150 . . Reading, PA 19601 103940DD2-16 DECKER, DAVID L. 0.640 C 02.850 0 00 9171999991703075876272 42 N.19th Street ERR 01.150 . 4.640 Kenilworth, NJ 07033 105675BG1-10 GREEN, BRIAN M. 0.640 C 02.850 0 00 9171999991703075876203 4237 Salem Street ERR 01.150 . 4.640 Philadelphia, PA 19124 106630RL11-2 LAWRENCE, RANDY L. 0.640 C 02.850 0 00 9171999991703075876500 234 Fox Drive ERR 01.150 . 4.640 Mechanicsburg, PA 170 106630RL11-2.2 LAWRENCE, RANDY L. 0.640 C 02.850 0 00 9171999991703076166334 5405 Joshua Road . ERR 01.150 . 4.640 Mechanicsburg, PA 17050 107096AG1-10 GIUNTA, ANGELA 0.640 C 02.850 0 00 9171999991703075876326 2612 South 17th Street ERR 01.150 N . 4.640 Philadelphia, PA 19145 a ° Page Totals: 15 9.600 60.000 69.600 Cum Totals: 68 43.520 272.000 315.520 Form 3877 (Facsimile) SendSuite - MAC v6.25.6.25.L WELLS FARCO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET- BACKED CERTIFICATES, SERIES 2007-OPT1; et seq. Plaintiff (Petitioner) V. SHARON A. LAWRENCE; et al. Defendant (Respondent) CASE and/or DOCKET No.: 2011-2985 Sheriff's Sale Date: 11/2/2011 AFFIDAVIT OF SERVICE Complaint Summons ' Other: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I attempted to serve RANDY L. LAWRENCE the above process on the 13 day of October, 2011, at 9:30 o'clock, PM, at 5405 Joshua Road Mechanicsburg, PA 17050, County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: d By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 2) Commonwealth/State of /A ) SS: County of A6wV ) 3) Before me, the undersigned notary public, this day, personally, appeared I&JIL, Af wwtc1 to me known, who being duly sworn according to law, deposes the following: I hereby swear or affirm Subscribed ands o before me this let day 20 If cr-i Notary Public _ !?2Jv. -7 7-??AVANIA c^mSitl ,, T, `,y ? 13 set forth in the foregoing Affidavit of Service are true and correct File Number.106630FC SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sherr/f OOM 01 C4[ rrL Jody S Smith Chief Deputy L 7b i3. Richard 1111 Stewart > ,.. Solicibr 4rcc2 OF T*4j Sr:a1FF Wells Fargo Bank NA vs. Case Number Randy L. Lawrence (et al.) 2011-2985 SHERIFF'S RETURN OF SERVICE 06/20!2011 12:08 PM - 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: Sharon A. Lawrence, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above tided anion, as "Not Found" at 5405 Joshua Road, Mechanicsburg, PA 17055. Defendant does not reside at adress stated- 0620/2011 12:08 PM - Deputy Stephen Bender, 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 5405 Joshua Road, Mechanicsburg, PA 17050, Cumberland County. 0711212011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within warned Defendant, to wit Sharon A. Lawrence, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/262011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Adams County upon, Sharon A. Lawrence, personally, at 3009 Market Street Road, Harrisburg, PA 1710E on 7118/11 at 11:44 a.m.- So Answers: W. Conway, Deputy Sheriff. 07/292011 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: Randy L. Lawrence, but was unable to locate the Defendan in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 5405 Joshua Road, Mechanicsburg, PA 17050, Defendant Moved did not leave a forwarding address at post office. SHERIFF COST: $1,045.94 July 29, 2011 SO ANSWERS, RCointys?ur ilwifr. TerooR Im. KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPTI, ASSET-BACKED CERTIFICATES, SERIES 2007- OPT I 4650 Regent Blvd Irving, TX 75063 vs. SHARON A. LAWRENCE RANDY L. LAWRENCE Mortgagor(s) and Record Owner(s) 5405 Joshua Road Mechanicsburg, PA 17050 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2011-2985 AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5405 Joshua Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): SHARON A. LAWRENCE 3009 Market Street Road Harrisburg, PA 17109 RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SHARON A. LAWRENCE 3009 Market Street Road Harrisburg, PA 17109 RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 5405 Joshua Road 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: October 27, 2011 Law Gro C. BY: Rachael Klaus Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ????itp of 4EUnbrrlriad ?. THE rt'lrlW x4,rr 2012 JAI, 12 AM 10• Q 1 Richard W Stewart Solicitor Wells Fargo Bank NA vs. Randy L. Lawrence (et al.) CIJMBERLANC COUNT\' FENS S`r'L`IA? IA Case Number 2011-2985 SHERIFF'S RETURN OF SERVICE 06/20/2011 12:08 PM - 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: Sharon A. Lawrence, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 5405 Joshua Road, Mechanicsburg, PA 17055. Defendant does not reside at adress stated. 06/20/2011 12:08 PM - Deputy Stephen Bender, 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 5405 Joshua Road, Mechanicsburg, PA 17050, Cumberland County. 07/12/2011 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: Sharon A. Lawrence, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/26/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Adams County upon, Sharon A. Lawrence, personally, at 3009 Market Street Road, Harrisburg, PA 1710 on 7/18/11 at 11:44 a.m.. So Answers: W. Conway, Deputy Sheriff. 07/29/2011 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: Randy L. Lawrence, but was unable to locate the Defendan in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 5405 Joshua Road, Mechanicsburg, PA 17050, Defendant Moved did not leave a forwarding address at post office. 09/02/2011 As directed by Gary McCafferty, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/2/2011 10/26/2011 As directed by Gary McCafferty, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/7/2011 12/07/2011 Ronny Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pa. on December 7, 2011 at 10 a.m. He sold the same for the sum of $1.00 to Attorney Gary McCafferty, on behalf of Wells Fargo Bank, N.A., as Trustee for Soundview Home Loan Trust 2007-OPT1, Asset-Backed Certificates, Series 2007-OPT1, 4650 Regent Blvd, Irving, TX 75063. Wells Fargo Bank, N.A., as Trustee for Soundview Home Loan Trust 2007-OPT1, Asset-Backed Certificates, Series 2007-OPTlbeing the buyer in this execution, paid to the Sheriff the sum of $1196.70. 01109/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. SHERIFF COST: $1,149.45 SO ANSWER'S, January 09, 2012 RON - R ANDERSON, SHERIFF y? ?//jj !c) GOurYySuite ShEm?f. iehcso?[. inc . , ? (/ (L- Goldbeck McCafferty 8i McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007- OPTI 4650 Regent Blvd Irving, TX 75063 Plaintiff vs. SHARON A. LAWRENCE RANDY L. LAWRENCE (Mortgagor(s) and Record Owner(s)) 5405 Joshua Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 2011-2985 AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET- BACKED CERTIFICATES, SERIES 2007-OPTl, Plaintiff in the above action, by counsel, 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: 5405 Joshua Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): SHARON A. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SHARON A. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 RANDY L. LAWRENCE 5405 Joshua Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 5405 Joshua Road 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 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: ADril 27, 2011 By: G DBECK M AFFERTY & CKEEVER Michae 561 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 CUMBERLAND LAW JOURNAL Writ No. 2011-2985 Civil Wells Fargo Bank NA vs. Randy L. Lawrence Sharon A. Lawrence Atty.: Gary McCafferty ALL that certain piece, parcel or lot of land together with improve- ments, situated In Hampden Town- ship, Cumberland County Pennsyl- vania and bounded and described as follows: BEGINNING at a point On West- ern right-of-way line of Joel Drive (50.00 Ret wide) said point being located at the Southeastern comer of Lot No.20 I; then along said. right-of- way line on the arc of a circle curving to the left, having a radius of 425.00 feet, and an arc length of 7.78 feet, to a point; then South 14 degrees 19 minutes 47 seconds East, for a distance of 49.30 feet, to a point on the arc of a circle curving to the right, having a radius of 25.00 feet, and an arc length of 35.88 feet, to a point on the Northern right-of-way line of Joshua Road (50.00 feet wide); then along said right-of-way line on that arc of a circle curving to the left, having a radius of 475.00 feet and an arc length of 92.24 feet. to a point; Then South 56 degrees 46 minutes 43 seconds West, and through a 15.00 foot wide drainage easement, for a distance of 13.58 feet, to a point in line of proposed Phase VIII; then along said proposed Phase VII, mid along the centerline of said 15.00 foot wide drainage easement, North 33 degrees 13 minutes 17 seconds West for a distance of 105.00 feet, to a point in an existing iron pin; then North 10 degrees 43 minutes 57 seconds East, for a distance of 56.95 feet, to a point at the Southwestern comer of Lot No, 20 I; then along the Southern boundary line of Lot No. 20 I South 72 degrees 16 minutes 00 seconds East, for a distance of 58.89 feet to a point; then North 83 degrees 54 minutes 38 seconds East, for a distance of 85.00 feet to a point and the place of BEGENNINING. This piece, parcel or lot of land contains approximately 15,436.21 square feet of land, has an address of 5405 Joshua Road Mechanicsburg, Pennsylvania 17055, and is known and numbered as Lot No. 202 on the Final Re-Subdivision Plan for Good Hope Farms South Phase IV-Lot Nos. 20 I and 202, which is retarded in Cumberland County in Plan Book 81, Page 66. Parcel# 10-19-1602-108. Property address: 5405 Joshua Road, Mechanicsburg, PA 17050. Being the same premises which McNaughton Company, by Deed dated 09/29/2000 and recorded 10/ 02/2000, in the Recorder's Office of Cumberland County, in Deed Book 230 Page 51, granted and conveyed unto Randy L. Lawrence and Sharon A. Lawrence, husband and wife. 40 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 15, July 22 and July 29, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. f Lisa Marie Cope, Editor V SWORN TO AND SUBSCRIBED before me this da of Jul 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Z4 t Patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of I he Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: Sworn to a9j2rAubscribed19eWre mg tNis/1'8 da 9f August, 2011 A. D. Publics COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisner, Notary Public Lower Paxton Twp., Dauphin County My Commisslon Expires Nov. 26, 2011 Member, Pennsvivania Association of Notaries 07/15111 07/22/11 07/29/11 2011-2985 Chdl Term Wells Fargo Bank NA Vs Randy L. Lawrence Sharon A. Lawrence Atty: Gary McCafferty ALL that certain piece, parcel or lot of land together with improvements, situated In Hampden Township, Cumberland County Pennsylvania and bounded and described as follows: BEGINNING at a point On Western right- of-way he of Joel Drive (50.00 Ret wide) said point being located at the Southeastern comer of Lot No.20 I; then along said. right-of-way line on the arc of a circle curving to the left, having a radius of 425.00 feet, and an arc length of 7.78 feet, to a point; then South 14 degrees 19 minutes 47 seconds East, for a distance of 49.30 feet, to a point on the arc of a circle curving to the right, having a radius of 25.00 feet, and an arc length of 35.88 feet, to a point on the Northern right-of-way line of Joshua Road (50.00 feet wide); then along said right-of- way line on that arc of a circle curving to the left, having a radius of 475.00 feet and an arc length of 92.24 feet. to a point; Then South 56 degrees 46 minutes 43 seconds West, and through a 15.00 foot wide drainage easement, for a distance of 13.58 feet, to a point in he of proposed Phase VIII; then along said proposed Phase VII, mid along the centerline of said 15.00 foot wide drainage easement, North 33 degrees 13 minutes 17 seconds West for a distance of 105.00 feet, to a point in an existing iron pin; then North 10 degrees 43 minutes 57 seconds East, for a distance of 56.95 feet, to a point at the Southwestern comer of Lot No, 20 I; then along the Southern boundary line of Lot No. 201 South 72 degrees 16 minutes 00 seconds East, for a distance of 58.89 feet to a point; then North 83 degrees 54 minutes 38 seconds East, for a distance of 85.00 feet to a point and the place of BEGENN KING This piece, parcel or lot of land contains approximately 15,436.21 square feet ofland, has an address of 5405 Joshua Road Mechanicsburg, Pennsylvania 17055, and is known and numbered as Lot No. 202 on the Final Re-Subdivision Plan for Good Hope Farms South Phase IV - Lot Nos. 20 I and 202, which is retarded in Cumberland County in Plan Book 81, Page 66. Parcel# 10-19-1602-108 Property address: 5405 Joshua Road, Mechanicsburg, PA 17050 Being the same premises which McNaughton Company, by Deed dated 09/29/2000 and recorded 10/0212000, in the Recorder's Office of Cumberland County, in Dees Book 230 Page 51, granted and conveyed unto Randy L. Lawrence an,! Sharon A. Lawrence, husband and wife. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Bank N.A. as Trustee for Soundview Home Loan Trust 2007- OPT1 is the grantee the same having been sold to said grantee on the 7 day of December A.D., 2011, under and by virtue of a writ Execution issued on the 4 day of May, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 2985, at the suit of Wells Fargo Bank, N.A. as Trustee for Soundview Home Loan Trust 2007-OPT1 against Sharon A. Lawrence and Randy L. Lawrence is duly recorded as Instrument Number 201201123. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /+0--1 day of A.D. G? © / cZ Recorder of Deeds WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOII-2985 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1 ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1 Plaintiff (s) From SHARON A. LAWRENCE and RANDY L. LAWRENCE (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 $488,832.66 L.L.$.50 Interest from 4/28/2011 to Date of Sale per diem at $83.66 Atty's Comm % Due Prothy $2.00 Atty Paid $186.50 Other Costs Plaintiff Paid Date: 5/4/11 David D. B411, Prothonotary (Seal) By: REQUESTING PARTY: Name: GARY MCCAFFERTY, ESQUIRE 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 Deputy TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This -li_ day of - 201L_ Prothonotary On May 11, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland. County, FA, Known and numbered as, 5405 Joshua Road., Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 11, 2011 By: Real Estate Coordinator 1:1j