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Home My WebLink About11-3637UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 /DANIEL S. SIEDMAN, ESQUIRE - ID #306534 JEROME B. BLANK, ESQUIRE - ID #49736 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings a-,udren.com OneWest Bank, FSB CARE OF 888 East Walnut Street Pasadena, CA 91101 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County V. CHRISTOPHER M. KECK 11 KEEFER WAY MECHANICSBURG, PA 17055 MELINDA L. KECK 11 KEEFER WAY MECHANICSBURG, PA 17055 Defendant(s) NO. 11'SW 3-1 l.Jlh? COMPLAINT IN MORTGAGE FORECLOSURE - ,._-. i c? ? x c) CZ) - YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. S :ga.an v a{+y Ck LO%12 LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiffs favor: Assignor: Mortgage Electronic Registration Systems, Inc. as nominee for IndyMac Bank, F.S.B. Assignee: OneWest Bank, FSB Date of Assignment: Recorded Date: Book/Instrument #: Page: 2. Upon information and belief Defendant(s): Christopher M. Keck and Melinda L. Keck (hereinafter "Defendants"), are the owners of property located at 11 Keefer Way, (Upper Allen Township), Mechanicsburg, PA 17055, by virtue of Deed dated 11/30/2006 and recorded 12/01/2006 in Official Records Book 277 at Page 4049 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 11/30/2006, Defendant(s): CHRISTOPHER M. KECK AND MELINDA L. KECK promised to pay to the order of IndyMac Bank, F.S.B. , the principal sum of $139,920.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 11/30/2006, Defendant(s): CHRISTOPHER M. KECK AND MELINDA L. KECK to secure the Note, mortgaged to Mortgage Electronic Registration- Systems, Inc. as nominee for IndyMac Bank, F.S.B. , the Property which is the subject of this action. The Mortgage was recorded on 12/01/2006 in Official Records Book 1974 at Page 4485. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof 5. Said mortgage is in default in that the payment due 10/01/2010, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $151,798.96 Accumulated Interest $2,846.22 Escrow Deficit/(Reserve) $2,790.03 Title Report $325.00 Court Costs- Estimated $300.00 Attorney Fees- Estimated $1,300.00 Suspense Balance $-322.14 Grand Total $159,038.07 The above figures are calculated as of 03/01/2011: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 3.75000 %. The per diem interest accruing on this debt is $15.60 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $37.90. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage, The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $159,038.07 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, BY: Daniel S. Siedman, Esquire PA ID 306534 ALL that certain pies, pmvd Cuw4trland C'aunly, °"enasybrania.. 11 MG Lot So. 2* oa d w Mad S ivisimI a: Paul of Pbaae t - 1oraram V1#lape, more pmpody knews as powmals"a lE` ;, W" i is recamw to. Oc Offiift of fire lbee nhr ai Dee& in grad far Cumberland Cactaty. Prlas"baala, is Plan Uak 73, Pap, 7* k ag more particularly baaa&di and 4aceribed in IbOm s, to *It;. 1RGUMNG in it paint silt lbo acs a. ksod :rigbc- of way lint sit` K, Vi*. at the dbrislkg One bomm fire reddest hmW of 1 tans Nil Parbr %Wp sad Lei NA, be: it dltserilxd; Once by sold 41+r &ng foe go** 46 dognes 23 mlauto 15 vemdb motet, e diolanae• a1" 134-M h d to a paint at Made now or fiwweriy of Hnwtao a RM rkwatiwol,. a plan ad Tats hawwa as rmam Big.'. atom by aadd lamb &asedr 43 degrs+.es 31 sw"Oft 45 sacniuds Wwl- s[ s rive of 37AG feet sea pains: at *U dbAding Ilse of f at 1+9 sad 1. bervin dtaedbed; lbseeft by said dbridlim lim horns 46 ftrs a 17 ukbatm IS suds W wA a diatame of DO" fact tW a paint to l1w ewftm dediidrR4 dot of• of liner Wa ; tbaum sold rW. sift ' Her Nor* 4,4 degmes 32 waimtws 45 seconis Last, a. dit+tauft of 37A fiW to a puoWt, the plr?ca *f FAEGIK D IndyMac Mortgage Services a Division of One West Bank PO Box 9042 TemecLAa, CA 92589-9042 Send Payments to: IndyMac Mortgage Services a Division of One West Bank PO Box 4045 Kalamazoo, MI 49003-4045 Send Correspondence to: IndyMac Mortgage Services a Division of One West Bank PO Box 4045 Kalamazoo, MI 49003-4045 9 7196 9006 9295 0398 4353 PRESORT First-Class Mail U.S. Postage and Fees Paid W SO 20110225-72 CHRISTOPHEKECK 11 KEEFER WAY MECHANICSBURG, PA 17055-9214 eoI41l A XC719 Home Loan Servicing 6900 Beatrice Drive Kalamazoo, MI 49009 02/24/2011 CHRISTOPHEKECK 11 KEEFER WAY MECHANICSBURG, PA 17055-9214 RE: Loan Number: Legal Description of Property: 1008860577 11 KEEFER WAY MECHANICSBURG, PA 17055 ACT 91 NOTICE Sent Via Certified Mail 7146 9006 9245 0348 4353 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in defy - and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paces. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEM") MAY BE ABLE TO HELP TO SAVE YOUR HOME. This Notice explains how the program works To see if HEMAP can help you most MEET WITH 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 servicing your county are listed at the end of this Notice. If you have gW questions yku may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearipg can call 1-717-780-1869). This Notice contains important legal informati on. 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCLA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDH)O DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME 4neWest 13.. 7196 9006 9295 0398 4353 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 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 ANAPPLICATION WITHP1IFA 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 IIEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN A BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. f you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to datel NATURE OF THE DEFAULT, - The MORTGAGE debt held by IndyMac Mortgage Services, a Division of OneWest Bank on your property located at the above referenced address is in SERIOUS DEFAULT, because you have not made the monthly payments that follow: Next Payment Due Date: Current Monthly Payment: Total Monthly Payments Due: Late Charges: Other Charges: Uncollected NSF Fees: Other Fees: Corporate Advance Balance: Partial Payment Balance: TOTAL YOU MUST PAY TO CURE DEFAULT: 10/01/2010 $1,044.14 $5,419.70 $37.90 $0.00 $0.00 $0.00 -$322.14 $5,135.46 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,135.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the _ lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) Days, the lender also intends to instruct its attorneys to start legal action to foreclosure 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 ?? ?. 7196 9006 9295 0398 4353 cure the default within the THIRTY (30) DAY period. you will not be required to nav 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. FIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY(30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by_uaving the total amount then east due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the wort ge 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 6 months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: IndyMac Mortgage Services, a Division of OneWest Bank 2900 Esperanza Crossing Austin, Texas 78758 Loan Resolution Department 1-877-908-4357 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may be eligible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied You will need to obtain expressed approval of the lender prior to any sale or transfer or assumption of the mortgage debt. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ??{ You may also contact a HUD-approved housing counseling agency toll-free at 1-800-569-4287 or TDD 1-800-877-8339 for the housing counseling agency nearest you. These services are usually free of charge. CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE STATE OF PENNSYVANIA This company is a debt collector and any information obtained will be used for that purpose. However, if you have filed a bankruptcy petition and there is either an "automatic stay" in effect in your bankruptcy case, or your debt has been discharged pursuant to the bankruptcy laws of the United States, this communication is intended solely for informational purposes. Sincerely, IndyMac Mortgage Services, a Division of OneWest Bank, FSB Loan Resolution Please 1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank 2) Do not staple your payment to your billing statement 3) Write your loan number on your check or money order 4) Do no include correspondence 5) Do not send Cash 6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 ondwest am*- 7196 9006 9295 0398 4353 CONSUMER CREDIT COUNSELING AGENCIES SERVING CUMBERLAND COUNTY CCCS of Western PA 2000 I.inglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Community Action Commission of Captial Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 IndyMac Mortgage Services a Division of One W est Bank a PO Box 9042 Temecula, CA 92589-9042 Send Payments to: IndyMac Mortgage Services a Division of One West Bank PO Box 4045 Kalamazoo, MI 49003-4045 Send Correspondence to: IndyMac Mortgage Services a Division of One West Bank a PO Box 4045 Kalamazoo, MI 49003-4045 t 7196 9006 9295 0398 4360 20110225-72 MELINDA KECK 11 KEEFER WAY MECHANICSBURG, PA 17055-9214 PRESORT First-Class Mail U.S. Postage and Fees Paid W SO XC718 Home Loan Servicing 6900 Beatrice Drive Kalamazoo, MI 49009 02/24/2011 MELINDA KECK 11 KEEFER WAY MECHANICSBURG, PA 17055-9214 RE: Loan Number: Legal Description of Property: 1008860577 11 KEEFER WAY MECHANICSBURG, PA 17055 Sent Via Certified Mail 7196 9006 9295 0398 4360 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE_ PROGRAM (HEMAP) MAY BE ABLE TO HELP TO SAVE YOUR HOME. This Notice explains how the program works. To see if HEMAP can help you must MEET WITH CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with von when von meet with the Counseling Ale The name, address and phone number of Consumer Credit Counse in Agencies servicing your county are listed at the end of this Notice. If you have gW questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 1-717-780-1869)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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCM PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCIbN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME ( 4n+eWest Bic° ? 7196 9006 9295 0398 43611 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 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 ANAPPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN A BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by IndyMac Mortgage Services, a Division of OneWest Bank on your property located at the above referenced address is in SERIOUS DEFAULT, because you have not made the monthly payments that follow: Next Payment Due Date: Current Monthly Payment: Total Monthly Payments Due: Late Charges: Other Charges: Uncollected NSF Fees: Other Fees: Corporate Advance Balance: Partial Payment Balance: TOTAL YOU MUST PAY TO CURE DEFAULT: 10/01/2010 $1,044.14 $5,419.70 $37.90 $0.00 $0.00 $0.00 -$322.14 $5,135.46 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,135.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) Days, the lender also intends to instruct its attorneys to start legal action to foreclosure upon your mortgaeed 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 7"C?tj4 Oineftsl Bank- 7196 9006 9295 0398 4360 ' cure the default within the THIRTY (30) DAY period. you will not be reauired to nay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY(30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at My tp to one hour before the Sheriff's Sale. You may do so by pang the total amount then past due, plus any late or other charges then due, reasonable aggrnev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: IndyMac Mortgage Services, a Division of OneWest Bank 2900 Esperanza Crossing Austin, Texas 78758 Loan Resolution Department 1-877-908-4357 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 be eligible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied You will need to obtain expressed approval of the lender prior to any sale or transfer or assumption of the mortgage debt. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) w' • 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. You may also contact a HUD-approved housing counseling agency toll-free at 1-800-569-4287 or TDD 1-800-877-8339 for the housing counseling agency nearest you. These services are usually free of charge. CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE STATE OF PENNSYVANIA This company is a debt collector and any information obtained will be used for that purpose. However, if you have filed a bankruptcy petition and there is either an "automatic stay" in effect in your bankruptcy case, or your debt has been discharged pursuant to the bankruptcy laws of the United States, this communication is intended solely for informational purposes. Sincerely, IndyMac Mortgage Services, a Division of OneWest Bank, FSB Loan Resolution Please 1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank 2) Do not staple your payment to your billing statement 3) Write your loan number on your check or money order 4) Do no include correspondence 5) Do not send Cash 6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 BE 7196 9006 9295 0398 4360 CONSUMER CREDIT COUNSELING AGENCIES SERVING CUMBERLAND COUNTY CCCS of Western PA 2000 LinglestoHm Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 Noah Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 VERIFICATION The undcrsi.gaed is an authorised signer of OneWest Bank, FSB, servicei on behalf of the Pl,gi-M and as sa h is familiar with the bn ia, s records maim ? by OneW est Bask for the purpose of servicing mortgage loans. These records (which include (icompdations, electronically imaged do=cnis, and oilers) are made at or ntay the t me by, or from other infozma-don provided by, persons with knowledge of the activity and t-=-ar-tons mffected in such records, and are kept in the copse of busi,ss activity conducted regularly by OneWest Bank, FSB_ I am authorized to make this velzncaii.on on beha?? of Pladntia and hereby verify that the facts set fort h in the forego7g Compl?nt in v _ -Mortarage Fore,--log= are true and r=ect to the best of my, knowledge, information, and belief I imderstaad that false statement herein ae made subject to the pemalides of Pa_ C_S. §4904, relahng to unswom falsincation to aLthorities_ OneWest Baal, FSB on behalf of PlainTrl Date: `APR 11 2011 Jammel A. Turki ,v Title. Assistant Secretary UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 g,. , CHANDRA M. ARKEMA, ESQUIRE - ID #203437 . SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 M CD : ...? MARGUERITE L. THOMAS, ESQUIRE - ID #204460 m -V d. DANIEL S. SIEDMAN, ESQUIRE - ID #306534 cn> 1-71 WOODCREST CORPORATE CENTER S C-; 111 WOODCREST ROAD SUITE 200 = ' CHERRY HILL, NJ 08003-3620 o c ca ? ?, 856-669-5400 pleadines(a?udren.com r Cn OneWest Bank, FSB 888 East Walnut Street Pasadena, CA 91101 Plaintiff V. CHRISTOPHER M. KECK 11 KEEFER WAY MECHANICSBURG, PA 17055 MELINDA L. KECK 11 KEEFER WAY MECHANICSBURG, PA 17055 Defendant(s) TO THE PROTHONOTARY: COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. t ENTRY OF APPEARANCE Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Chandra M. Arkema, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN LAW OFFICES, P.C. BY: ?? -r- --- Daniel PA ISiedrnan, D 3065345Quire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?? ?ti,,q of L?aura?rrrtir?} ILEA-OF I` ICE ,- THE PPOTHONOYt",:,'i y Jody S Smith Chief Deputy Richard W Stewart Solicitor Onewest Bank FSB vs. Christopher M. Keck (et al.) 2011 APR 20 PM 2: 00 CUMBERLAND CQUNT?' PENNSYLVANIA Case Number 2011-3637 SHERIFF'S RETURN OF SERVICE 04/15/2011 08:02 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 15, 2011 at 2002 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christopher M. Keck, by making known unto Melinda Keck, Wife of defendant at 11 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEP 04/15/2011 08:02 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 15, 2011 at 2002 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Melinda L. Keck, by making known unto herself personally, at 11 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT,IDEPUT? SHERIFF COST: $54.00 April 18, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) Cou ltYSuite Sherifp, Te!eosoft. ir," Y UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 p?eadings@?idren.com OneWest Bank, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County CHRISTOPHER M. KECK MORTGAGE FORECLOSURE 11 KEEFER WAY == MECHANICSBURG, PA 17055 rt'r'-, NO. 11-3637 MELINDA L. KECK -<? - _ 11 KEEFER WAY . E MECHANICSBURG, PA 17055 ?E? c=? o r' C= Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), CHRISTOPHER M. KECK; MELINDA L. KECK; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $151,798.96 Interest Per Complaint $2,846.22 Additional Interest 03/02/2011 09/20/2011 $3,166.80 Additional Late Charges 03/02/2011 09/20/2011 $265.30 Escrow Per Complaint Title Report $2,790.03 Court Costs- Estimated $325.00 $300.00 Attorney Fees- Estimated Suspense Balance $1,300.00 Grand Total $-322.14 $162,470.17 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. U (v1inoho, E5qui - ?1I 7SS60 ?--omeyfor Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO MJU#: 11040012 CASE#: 11040012-1 %14.06 0 cl?111 C?? doll B ?? ato?O15S UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAI[NE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID 4204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 JEROME B. BLANK, ESQUIRE - ID #49736 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, N3 08003-3620 856-669-5400 pleadm11s(a),udren.com OueWest Bank, FSB CARE OF 888 East Walnut Street Pasadena, CA 91101 Plaintiff V. CHRISTOPHER M. KECK 11 KEEFER WAY MECFIANICSBURG, PA 17055 MELINDA L. KECK 11 KEEFER WAY MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF ?oQ? COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO . :U "' : r= C-5 . COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the - Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MA-17 BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith s;?" Chief Deputy Richard W Stewart Solicitor ALE OF THS sRIP-P Onewest Bank FSB vs. Christopher M. Keck (et aL) Case Number 2011-3637 SHERIFF'S RETURN OF SERVICE 04/15/2011 08:02 PM - Ryan Burgett, Deputy Sheriff, who being duly swom according to law, states that on April 15, 2011 at 2002 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christopher M. Keck, by making known unto Melinda Keck, Wife of defendant at 11 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEP 04/15/2011 08:02 PM - Ryan Burgett, Deputy Sheriff, who being duty sworn according to law, states that on April 15, 2011 at 2002 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Melinda L. Keck, by making known unto herself personally, at 11 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $54.00 April 18, 2011 RYAN BURGI=TT, SO ANSWERS, U'- ROYNR (?1' ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 1.11 WOODCREST ROAD, SUITE 200 CHERRY HILL, N3 08003?-3620 856-669-5400., ---- 0 1`1.. -- OneWest Bank, FSB Plaintiff v. CHRISTOPHER Al. KECK AND MELINDA L. KECK, ET AL Defendant(s) TO-CHRISTOPHER M. KECK 1.1 KEEFER WAY MECH.ANICSBURG, PA 17055 Date of Notice: May 6, 2011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 11-3637 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A IATRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION R.EQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINTO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA. SIN NECESIDAD DE COMP ARARECER USTED EN CORTE O ESCUCHAR PRELTBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS D.ERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A Cam' ABOGADO IMMEDIATAMENTE ST USTED NO TIENTE ABOGADO, O SI NO TIENE DINERO SUFICIENTE P_ARA TAI; SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA. CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCLA LEGAL LA)AT)'ER REFERRAL: SERVICE Cumberland Count)! Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.. Alan M. Minato, Esquire PA ID ?5860 UDREN LAW OFFICES, PC. Woodcrest Corporate Center 11.1 Woodcrest Road. Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. 'WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 OneWest Bank, FSB Plaintiff V. CHRISTOPHER M. KECK AND MELINDA L_ KECK, ET AL Defendant(s) TO:MELINDA L. KECK 11 KEEFER WAY MECHANICSBURG, PA 17055 Date of Notice: May 6, 2011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 11-3637 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENITER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE. A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty, Avenue Carlisle, PA 17013 (80()) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UNT TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER LJSTED EN CORRE O ESCLICHAR PREUBA ALGUNA. DICTAR SENTENCIA EN SU CONTRA; USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDI.ATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTF PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCI_A LEGAL . LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATI ON OBTAINED WILL BE USED FOR THAT PURPOSE. Alan M. Minato, Esquire PA ID 75860 LJDREN LAW OFFICES, PC. Wooderest Corporate Center I I I Wooderest Road. Suite 200 Cherry Hill; New Jersey 0800-3620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 OneWest Bank, FSB V. Plaintiff Christopher M. Keck 11 Keefer Way, Mechanicsburg, PA 17055 Melinda L. Keck 11 Keefer Way, Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-3637 Non-Military Affidavit Under the Servicemembers' Civil Relief Act The affiant, Raymond Liauw , is an employee of OneWest Bank, FSB ("OneWest") as servicing agent to Plaintiff and is authorized to make this affidavit on behalf of the Plaintiff. The affiant, being first duly sworn upon oath, deposes and says: On this date, 0-a Z,' 1, the aff ant conducted a search of the Department of Defense Manpower Data Center for the Defendant(s), Christopher M. Keck, Melinda L. Keck, who/each of whom is over 18 years of age. The certified military status report(s) provided for said Defendant(s) indicate(s) that said Defendant(s) is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) verifying said belief is/are attached hereto as Exhibit A. The affiant is also familiar with and has personally reviewed the servicing records relating to the loan at issue in the above-captioned action, which were and are regularly made and kept by OneWest, in the regular course of its business, made by or at the direction of persons with knowledge of the facts stated therein, at or near the time of learning the facts stated therein, which do not indicate that the above-named defendant(s) is/are in active military service, nor do they indicate that defendant(s) has/have been in active military service for the nine months preceding the date of this affidavit. FURTHER AFFIANT SAYETH NOT. 4ypeNere: OneWest Bank, FSB Raymond Liauw Assistant Secretary MJU#:? 11040012 CASE#: 11040012-1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3637 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ONEWEST BANK, FSB Plaintiff (s) From CHRISTOPHER M. KECK AND MELINDA L. KECK (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (?) ?'ou 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: $162,470.17 L.L.: $.50 Interest FROM 9/21/2011 TO DATE OF SALE JUNE 6, 2012 - ONGOING PER DIEM OF $15.60 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $4,056.00 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $191.00 Other Costs: Plaintiff Paid: Date: 122112 David D. Buell, Protho?n'otary. (Seal) 4.y?_. Deputy REQUF S T ING PARTY: ;Jame: KASSIA FIALKOFF, ESQUIRE Address: UDREN LAW OFFICES PC WOODCREST CORPORATE CENTER I II WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 310530 UDRIE:N LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2snudren.com OneWest Bank, FSB Plaintiff X7. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Christopher M. Keck MORTGAGE FORECLOSURE Melinda L. Keck Defendant(s) NO. 11-3637 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 9/21/2011 to Date of Sale June 6, 2012 Ongoing Per Diem of $15.60 to actual date of sale including if sale is held at a later date (Costs to be added) MJU#: 11040012 CASE#: 11040012-1 0. ? a?,sc T( aH sL4. ov Mr- 9(:q- cc .Pd a t? $.162,470.17 S 4.056.00 UDREN LAW OFFICES, P.C. BY _ Attorney for Plaintiff' KASSIA FIALKOFF, ESQUIRE PA ID 310530 d--713Y cri N N c.- 0 f 11r ri J?,j f ftis-s'ed ... t f f 9i• 7i t, {,.'i° UDREN LAW OFFICES, P.C. ' W%kNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER r- AN . oil 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 6B ERL `1 D C0UNT ?" 856-669-5400 t_ NS';'LVANI A pleadings(ii).udren.com OneWest Bank, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Christopher M. Keck Melinda L. Keck Defendant(s) Cumberland County MORTGAGE FORECLOSURE NO. 11-3637 CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: F1 Act 91 procedures have been fulfilled El Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LA--W OFFICES, P.C. BY =--?-- --- - Attorn ey for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER c _ r 111 WOODCREST ROAD, SUITE 204 - , i:7 CHERRY HILL, NJ 08003-3620 856-669-5400 12 FE3 22 dim pleadings(iuudren.com OneWest Bank, FSB BE r 3. NTOTOOTONMMON PLEAS Plaintiff V. Cumberland County Christopher M. Keck MORTGAGE FORECLOSURE Melinda L. Keck Defendant(s) NO. 11-3637 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 OneWest Bank, FSB, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 11 Keefer Way, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Christopher M. Keck 11 Keefer Way Mechanicsburg, PA 17055 Melinda L. Keck 11 Keefer Way Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Christopher M. Keck 11 Keefer Way Mechanicsburg, PA 17055 Melinda L. Keck 11 Keefer Way Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: OneWest Bank, FSB 888 East Walnut Street Pasadena, CA 91101 • Sr Mortgage Holders - None Mortgage Electronic Registration Systems, Inc. as nominee for IndyMac Bank, F.S.B. PO Box 2026 Flint, MI 48501-2026 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 11 Keefer Way Mechanicsburg, PA 17055 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None 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. sec. 4904 relating to unsworn falsification to authorities. DATED: 2 / (c, ?? ?1 MJU#: 11040012 CASE#: 11040012-1 UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 FR??IiC'NQ?'.'r UDREN LAW OFFICES, P.C. :??A?I'TORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTE*17 p EB 22 P,N 1 J : 0 J 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 .;UNBERLAN42 COUNT" 856-669-5400 PENNSYLVANIA pleadings(- ,,udren.com OneWest Bank, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County CHRISTOPHER M. KECK AND MORTGAGE FORECLOSURE MELINDA L. KECK Defendant(s) NO. 11-3637 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Christopher M. Keck 11 Keefer Way Mechanicsburg, PA 17055 Your house (real estate) at 11 Keefer Way, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $162,470.17, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late: charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: 856 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 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 on page two 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 TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(d!udren.com _ OneWest Bank, FSB Plaintiff V. CHRISTOPHER M. KECK, MELINDA L. KECK, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-3637 ., -.l cn ? ca war C) r-1) a rv .r- CD AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. ter: This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 5-' C4 Z UDgLN-LAVOFFICES, P.C_: --?> _.... Attorneys for Plaintiff Alan M. Minato, Esquire PA ID 75560 MJU#: 11040012 CASE#: 11040012-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ne est ank, ? Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County CHRISTOPHER M. KECK; MELINDA L. i KECK; I MORTGAGE FORECLOSURE Defendant(s) NO. 11-3637 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): CHRISTOPHER M. KECK; MELINDA L. KECK; PROPERTY: 11 Keefer Way, (Upper Allen Township), Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 06/06/2012 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 11040012 CASE#: 11040012-1 Ilk, R i x I ? •? y Q GC W o ° a C ou p m v o g ?vV0 X y L) y p Q v c'Oa 0. U 7 o ? ?> o c ? •? y L1. v cr c y <" a? Y A ??I G x r V w p a c o ? ? ^ x v x ? ? W x = ? u ????'. UN ?wv?o°o A3?? a ? 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SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith* ter`' Chief Deputy Richard W Stewart Solicitor ;a r - w{rF Onewest Bank FSB Case Number vs. 2011-3637 Christopher M. Keck (et al.) SHERIFF'S RETURN OF SERVICE 03/21/2012 07:55 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and DescrjP#ion, in the above titled action, upon the property located at 11 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 03/24/2012 10:35 AM - Deputy Mark Conklin, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be CHRISTOPHER KECK-HUSBAND, who accepted as "Adult Person in Charge" for Melinda L. Keck at 11 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 03124/2012 10:35 AM - Deputy Mark Conklin, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Christopher M. Keck at 11 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. SHERIFF COST: $919.20 SO ANSWERS, March 27, 2012 RON R ANDERSON, SHERIFF t' Telec;vft SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a 4'+tlita, :~t Ga~a~~Qrz~rf. ~ Jody S Smith ~ ''~ Chief Deputy ._ ! _ ~_`.''-:~ r i-4 f'~ ~ Et~ v~'fi Richard W Stewart R: ~~~t~ ,.~;'.; ~. ,' Solicitor ~ ~ r ~:~ ~ -, ~"~ ~ '," y ! . Onewest Bank FSB vs. Case Number] Christopher M. Keck (et al.) 2011-3637 SHERIFF'S RETURN OF SERVICE 03/21/2012 07:55 PM -Deputy Shawn Gutshall, being duly sworn according to law, states service was performed y posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 11 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 03/24/2012 10:35 AM -Deputy Mark Conklin, being duly sworn according to law, served the requested Real Estat~ Writ, Notice and Description, in the above titled action, by making known its contents and at the same i time personally handing a true copy to a person representing themselves to be CHRISTOPHER KECK-HUSBAND, who accepted as "Adult Person in Charge" for Melinda L. Keck at 11 Keefer Way, ', Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 03/24/2012 10:35 AM -Deputy Mark Conklin, being duly sworn according to law, served the requested Real Estat~ Writ, Notice and Description, in the above titled action, by making known its contents and at the same ' time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Christopher M. Keck at 11 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberlandi County. 06/06/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice h~d been given according to law, he exposed the within described premises at public venue or outcry at th Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on June 06, 2012 at 10:40 AM. He sold the same for the sum of $1.00 to Attorney Mark Udren, on behalf of Federal Home Loan '~ Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $749.62 SO ANSWERS, Au ust 14, 2012 ~- g RON R ANDERSON, SHERIFF- s'~w~~ S P~ d=~ ~_ l '~ ~y 7 y~ ' 3- ~ ~ • UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinas(a~.udren.com OneWest Bank, FSB Plaintiff v. Christopher M. Keck Melinda L. Keck Defendant(s) ATTORNEY FOR. PLAINTIFh COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-3637 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 OneWest Bank, FSB, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 11 Keefer Way, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Christopher M. Keck 11 Keefer W av Mechanicsburg, PA 17055 Melinda L. Keck I 1 Keefer Way Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Christopher M. Keck 11 Keefer Way Mechanicsburg, PA 17055 Melinda L. Keck 11 Keefer Way Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: 3r Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: OneVVest Bank, FSB 888 East Walnut Street Pasadena, CA 91101 ' Sr Mortgage Holders -None t ' Mortgage Electronic Registration Systems, Inc. as nominee for IndyMac Bank, F.S.B. PO Box 2026 Flint, MI 48501-2026 ~. Name and address of every other person who has any record lien on the property: Sr lien Holders -None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: ', Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle. PA 1.7013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 11 Keefer Wav Mechanicsburg, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Federal Tax Lien Holders -None Condo/Homeowners Association -None 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. sec. 4904 relating to unsworn falsification to authorities. I~ DATED: ~ ~ ~.: / ~~""`~'~ ~ UDREN LAW OFFICES, P.C. BY: __ Attorney for Plaintiff MJU#: 1104[1012 CASE#: 11040012-1 KASSiA FIALKOFF, ESQUIRE PA ID 310530 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings (a~udren.com OneWest Bank, FSB --- Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DIVISION Cumberland County CHRISTOPHER M. KECK AND MORTGAGE FORECLOSURE MELINDA L. KECK Defendant(s) ~~~~ NO. 11-3637 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Christopher M. Keck 11 Keefer Way Mechanicsburg, PA 17055 Your house (real estate) at 11 Keefer Way, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $162,_ 470,17, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable ',; attorney's fees. To fmd out how much you must pay, you may call: (856) 669-5400. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 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 on page two 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 TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling 856-669-5400. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 4 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call 856-669-5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. ?. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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. LAWS'ER REFERRAL SERVICE Cumberland Count3~ Bar Association Z Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty, Avenue Carlisle, PA 17013 (800)990-9108 .~Lt: ttw~r eerEai~ ~rrt: pe~ae^c~t! sena# 6rr~ ~,f latrti srseuac in 1i}~~er ~Llcn '~ ¢~.s~~,Taa;s. (~~t~k~eriut~d +Cnaa~r., f'tirr>s~ti.+ats~. ~~;?~~"t l,~rt hr,..'.!~ q,n ~c F'ina~1 ~ra~division I'Is~n of 1"t- M ' It~++°cn~i.~s~ A'i1'la, rnonr pr~-~~rrh; i~ue~+~ ~~ 'ftc~*man'~ ~+'`Ilti~~, w~tu~t+ ~+l~n u r~eea~dt+c1 w tht t~f~~ Sri ttr~ R~ec~ ~~~~ oaf fe~reds in and f+s Ct~rnMcrlartd Cnnnn, t'€o~v~`h'~nis, i~ ~i~n 1~aMr{. '"~, P;n~e ~' . m+~ee~ ~a~rticvk~~J trar~tmelttid q~rl dexcciirett wr le,ltan~c. t~, ~'a.= Ii«f:~I'.`~l~;i?~4a a~ ~ point, ~a~ tt+~ ra.~tcm cbrzlieattd r~pa ,~f ,~~~ lim• ra! t~eef~t' ~'~~ ~. #~r.~ ~n di~tdin~. line lwetv~~+en tkrc ru~l la>rd~ t+'~ $~a+~yat~n+ ~etl 1~'mrr¢hip ~a~' L.kt deseeilreei; th~cx to xui~i diuidin; time `wstti'6 ctcrr~ ~~' minaMC~: 1 s~eaud~ E.,awt, m tttcna~rr ,.MI' 13tt.lMP !n a ~nnit6t N,t t~mrls, cr Igtrturt99' of 1'mar.~. Td~l gtir~,ci~ita:, a pit-n ~~f Nrts ~~oam ~~+ Tirrw~ma~ts t3iil, i#~~nee tn~ ~1~ toss ;+o~atztt ~.'~ r> ~= t~itruc~ -':~ ~.~,,yn,-wx V4'~t & daxta~ ~r[ fi,.AtIM Gyre to x pint pt tb~ diti'ida~~ t~i~iute~0.~ +c ~ ~d~"t~'~ d~acritrert; Zltcysc~r t~~ said r6pvdn~ line M1t+~~ de, ilfi~1 di~~~rce t+l 13d~.6E~I tcxa ~ ~ l-aint on tier etf.en. dedicaee~: ~~ii oaf ~ li~rt 1~f j~,Nx~;r '~ u~; ttrrnarr hn ~.id ~`*~~ +~C~a~ iinr ~i~Le'1'h d3 tte~t'+ec+, ~~ edv~evtcF ~~+ zrx:urrds East., n a6ese;aneti e~i ,4'',Blil lrctt[~ ~ p~tidnl. tint !n]a~r+?~i`ItF:d~T~i'<wl.~+~:_ BEING KNOWN AS: 11 KEEFER Vb'AY, MECHANICSBURG, PA 17055 PROPERTY ID NO.: 42-29-2456-166 TITLE TO SAID PREMISES IS VESTED IN CHRISTOPHER M. KECK AND MELINDA L. KECK, HUSBAND AND WIFE BY DEED FROM KELLY A. EPPERSON, ADULT INDIVIDUAL DATED 11/30/2006 RECORDED 12/01/2006 IN DEED BOOK 277 PAGE 4049 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings udren.com OneWest Bank, FSB Plaintiff ~-. ATTORNEY FOR PLAINTIE'F COURT OF COMMON PLEAS CML DIVISION Cumberland County CHRISTOPHER M. KECK MORTGAGE FORECLOSL7RE MELINDA L. KECK NO. 11-3637 Defendant(s) SHORT DESCRIPTION FOR ADVERTISING ALL THAT CERTAIN LOT OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA: BEING KNOWN AS 11 Keefer Way, Mechanicsburg, PA 17055 PARCEL NUMBER: 42-29-2456-166 IMPROVEMENTS: Residential Property UDREN LAW OFFICES, P.C. -_ ____ Attorney for Plaintiff KASSIA ~AI.ICOFF, ESQUIRE PA ID 310530 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a~udren.com OneWest Bank, FSB '~~ Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County CHRISTOPHER M. KECK AND '~, MORTGAGE FORECLOSURE MELINDA L. KECK Defendant(s) NO. 11-3637 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Melinda L. Keck 11 Keefer Way Mechanicsburg, PA 17055 Your house (real estate) at 11 Keefer Way, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $162,470.17, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To fmd out how much you must pay, you may call: (856) 669-5400. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 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 on page two 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 TAKE PLACE. L If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. I'ou may find, out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate 'i 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 856-669-5400. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the 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 Schedule of Distribution is filed. ?. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. ', 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. LAV~'YER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 .n.Lt: th.ut certain ~+e~~, ~rc~l .~n~ Era[ of 1~nd wYm;~~~*= to i1p~r ~tillfin ~ arw•~r;ha,a. C.-tc~rhe•rinr-d Ci+~antti, i'r.ain~~~1'~=any. E3i:1~d{'; ).tat ?~c~. Xil ~~~~ flat 1°in~1 4rrl~dib=i~iun f'lun of 1"ha~c M - P~~ ~'1la~~, morx pr~~~ri~ 4Jee~-t~ ~K ii•man'~ ~"~E~`~, w~~'ueE+ ~Ewn ~ rectrrad+rd ~n Che ivy' r+i cY~ R~cxa~rr „9 Creeds in rand n:~ Ct~mE~ria#td ~.ann:~, p~q~s~israniu, in Y'i~,n 1#aMrl. "3, f ~~e ~~. hrc~a~ ~aon`#• ~~rtict~kuW h iw~e~rnd~l and deucrii~c! ati ir~ICraw~. i.~p ~'it: IRi:1.sIT.tiAi'I.s~~± ~# ra dim. an tY~ ea.rei ilr~iicat~d ri ~t ,~:' *+"~:+ lint ni Z~.tK:fe'~ '~•~?' aA tErr riiv#iint lYnM Ieet~x+rn for ~~ land ~~ ~rwrutan:~ ~eEl ~'ur¢nc.~hn s~a#! Let : Ca. #rrr~in d4~tribr: A-e~f~c i-•r xaEwi diuitin; ttne Cr~tautit 4ii alc~!+^~ ="• ~inUl ~~ ~ecand~ ¢,~t, m ~Ecrancr ~wf t~it7Jl~ fcrt to ~ faint ~t ~,mtE~ or Itrrcne~e'It' a~C -;rrw~Qn~rri~ Trl#~l A~ u ~~ fr':an raft EMS l,:nt~•at ~s !ice=mn7t~ ~3iCi, ti*~ ~.• s#taii ixtr~~ ~+vnxh ~.~• ~~ ~N~yn~a V4'~t ~ +3a~• tFC 3;,11! iii tta a p~!nt ma tEtx di+=idi~A 6rc,r tiE Lat 1~1 ms~r] :.~, Crr#~~: d~Lriired; tht-nar i`++ r~i~d tli~~inli#t~, lint ht~rth ~u d~~+•c~ Z` nruem~ttr!: l~ ~~~~n~`' "Y'-~' ~ dis~tsner ~ t3db..flt1 tai to a ~xnint an tits r~~=c~rn d ~d~ nmi m ~~~4~ti,d3r,Ea~t, a~~e,a~ ~c~i tl~rnrr 1xti s~i#i r%~~ r~C *+a3 hoc ?wta~tir ~3 tie~trr; _.. ,',",tK~ Icet tc~ ~ ~ptnL Citc pla~~fil~F:G}v'tinl(*~:. BEING ILNOWN AS: 11 KEEFER WAY, MECHANICSBURG, PA 1705 PROPERTY ID NO.: 42-29-2456-166 TITLE TU SAID PREMISES IS VESTED IN CHRISTOPHER M. KECK AND MELINDA ', L. KECK, HUSBAND AND WIFE BY DEED FROM KELLY A. EPPERSON, ADULT INDIVIDUAL DATED 1.1/3012006 RECORDED 12/01/2006 IN DEED BOOK 277 PAGE 4049 T UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinas~udren.com OneWest Bank, FSB Plaintiff v. CHRISTOPHER M. KECK MELINDA L. KECK Defendant(s) ATTORNEY FOR. PLAINTIFIB~' COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-3637 SHORT DESCRIPTION FOR ADVERTISING ALL THAT CERTAIN LOT OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA: BEING KNOWN AS 11 Keefer Way, Mechanicsburg, PA 17055 PARCEL NUMBER: 42-29-2456-166 IMPROVEMENTS: Residential Property UDREN LAW OFFICES, P.C. ~, ~. Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 WRIT-OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-3637 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ONEWEST BANK, FSB Plaintiff (s) From CHRISTOPHER M. KECK AND MELINDA L. KECK (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: $162,470.17 L.L.: $.50 Interest FROM 9/21/2011 TO DATE OF SALE JUNE 6, 2012 -ONGOING PER DIEM OF $15.60 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $4,056.00 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $191.00 Other Costs: Plaintiff Paid: Date: 2/22/12 David D. Buell, Prothonota (Seal) Deputy REQUESTING PARTY: Name: KASSIA FIALKOFF, ESQUIRE Address: UDREN LAW OFFICES PC' WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 310530 TRUE COPY FROM RECOR[ In Testimony whereof, t here unto set my and the seal of said Cou_rt~~Carlisle, Pa. This_a~`deyof_..~=..L----. ~LG P i/~ G~ ~~° On March 2, 2012 the Sheriff levied upon the defendant's interest in the real property situated Upper Allen Township, Cumberland County, PA, known and numbered 111 Keefer Way, Mechanicsburg, PA 1~05S more fully described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: March 2, 2012 } By: For Claudia Brewbaker, Real Estate Coordinator . _ ..,~_v .:......~~, t~, ~~~.« ~.~.. , _. ~__ .. _ . ~, ~_ . CUMBERLAND LAW JOURNAL Writ No. 2011-363? Civil Term OneWest Bank, FSB vs. Christopher M. Keck, Melinda L. Keck Atty.: Kassia Fialkoff ALL THAT CERTAIN lot of land situate in Upper Allen Township, Cumberland County, Pennsylvania. BEING KNOWN AS 11 Keefer Way, Mechanicsburg, PA 17055 PARCEL NUMBER: 42-29-2456- 166 IMPROVEMENTS: Residential Property KASSIA FIALKOFF, ESQUIRE PA ID 310530 UDREN LAW OFFICES, P. C. Attorneys for Plaintiff 74 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 an State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La~ Journal, a legal periodical published in the Borough of Carlisle in the County and State afores~ 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 regularl 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, 27. Mav 4, and Mav 11.2012 Affiant further deposes that he is authorized to verify this statement by the Cum Law Journal, a legal periodical of general circulation, and that he is not interested in the subj 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. ,.__ --- Li a Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 11 da of Ma 2012 ~~ Notary ~ - _` ,, NOTARIAL SEAL DEBORAH A COILINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 T,he Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the ~latriot-News Now you know CARLISLE PA 17013 i 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 ~f the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, i the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and he Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and tote aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 1 th, 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 heir regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she n~r said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this ~tatement 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 tatement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted se rally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recordi g 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 beldw: 04127/12 05/04/12 r-- 05/11/12 2ott-3~3T tYN1'll~rm c ~ ~'" ( ~, OrnMNN M~4 °---__ N.1Grdc L Kook ~ f tqp~ Sworn to a~ub crjt5ed be re e this ~2~ay~M~y, 2012 A. D. All That Certeifl Lot 4)1LamdSituate ` - ~' , ~ ,, In Upper Allen'ibi4~hip, Gtimnbcrland ~ + ~ ,4 _: &ingl~arnmf~llKrxfctW®y, --~-- Notary Public Meo6aeieeb~~rg, ~ 17055 Parcel Number: 42-24-2456166 meats: Residential Property n Law Offices, P.C. Attorney For Plaintiff F'aik°tf>F~9uire COMMQNWEAL'YH,_ 0____F ~NHSYLVANIA Pa Id 310530 ---~"^ N~arlal Seal Sherrie L• Owens, Notary Public dower Paxton Twp„ Dauphin County My Commission ExpUes Nov. 26, 2015 MEMBER, PEhNSYLVANJA ASSOCIA'110N OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify t)~at the Sheriff s Deed in which Federal Home Loan Mortg_a eg Com is the grantee the same having bee sold to said grantee on the 6 day of June A.D., 2012, under and by virtue of a writ F,xecution issued on the 22 day of February, A.D., 2012, out of the Court of Common Pleas of said County as of Civil 1~erm, 2011 Number 3637, at the suit of OneWest Bank, FSB against Christopher M. Keck and Melinda I~. Keck is duly recorded as Instrument Number 201224629. IN TESTIMONY WHEREOF, I have hereunto set m~~ hand -~ and seal of said office this _~~ _ d~y of~ A.D. i;~__ '' ,-, 1\ c~ Recorder of Reooider d ~lmibertand t~nryr, ~ !y1 My Conrniss E~ires the Fist Monday of . 2Q14