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Home My WebLink About11-3638.GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 vs. WILLIAM COON Mortgagor and Record Owner 300 Hollowbrook Drive Carlisle, PA 17013 Plaintiff Defendant CIViLAWlb?-3n"') FORD'! r ,NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes p S sted. A147a SM'A'? PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.Dhfa.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: h i ://www hip ladelphiafed org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw 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 10629417C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION), 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254. 2. The names and addresses of the Defendant is WILLIAM COON, 300 Hollowbrook Drive, Carlisle, PA 17013, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On September 08, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR GREENPOINT MORTGAGE FUNDING INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on September 11, 2006 as Book 1965 Page 2291. The mortgage has been assigned to: FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) by assignment of Mortgage recorded on March 03, 2011 as Instrument# 201107104. 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 January 01, 2010 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance .................................................................... Interest from 12/01/2009 through 03/31/2011 at 7.1250%..... Per Diem interest rate at $49.74 Late Charges from 01/01/2010 to 03/31/2011 ........................ Monthly late charge amount at Monthly Escrow amount $1,042.47 ............$254,826.89 ..............$24,125.65 Suspense .................................................................................................. ($1,290.53) Escrow Balance Deficit .............................................................................$8,130.19 Property Inspection ........................................................................................$86.00 Reasonable Attorney's Fee ....................................................................$1.300.00 $287,178.20 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 Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has 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 Defendant by certified and regular mail on October 28, 2010, 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 Defendant 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 Defendant 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 $287,178.20, together with interest at the rate of $49.74, 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 K CAFFERT & MCKEEVER Michael McK ev 129 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 Rebecca Graves , as the representative of IBM Lender Business Process Services, Inc., as servicer for Fannie Mae ("Federal National Mortgage Association") do hereby verify that I am authorized to and do make this verification on behalf of IBM Lender Business Process Services, Inc., as servicer for Fannie Mae ("Federal National Mortgage Association") 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. Sec. 4904 relating to unworn falsification to authorities. Date: - le > . L,;.. IBM Lender Business Process Services, Inc. as servicer for Fannie Mae (Federal National Mortgage Association) #106294FC - WILLIAM COON 300 Hollowbrook Drive Carlisle, PA 17013 EythibitA Exhibit A - Legal Description Commttmerrt No. 1240599SUE ALL THAT. CERTAIN piece or parcel of land situate In Middlesex Township, Cumberland County Pennsylvania, bounded and described as tidlows, to wit: BEl6 at an iron pin on the eastern dedicated Nght-of-way line of North Middlesex Road, said iron pin being on the dividing line between Lots Nos. 6C and SC on the hereinafter mentioned Plan of Lots, thence along said eastern dedicated right-of-way line of North Middlesex Road, North 21 degrees 47 minutes 30 seconds West, 203.00 feet feet to a point, said point being at the intersection of North Middlesex Road and Hollow Brook Drive; them continuing along the southern dedicated right-of-way line of Hollow Brook Drive, North 29 degrees 32 minutes 26 seconds East, 220.00 feet to an iron pin on the boundary line between Lots Nos. 5C and 4C on the hereinafter mentioned Plan of Lots; thence along said dividing One, South 60 degrees 27 minutes 34 seconds East, 350.00 feet to an Wort pin; thence South 09 degrees 32 mirwtes 55 seconds East, 68.75 feet to an iron pin on the dividing line between Lots Nos. SC and 6C on the hereinafter mentioned Plan of Lots; thence along said dividing line South 68 degrees 12 minutes 30 seconds West, 375.85 feet to an Iron pin on the eastern dedicated right-of-way line of North Mkkb.q x Road, the place of BEGINNING. BEING Lot No. 5C on the Preliminary and Rnal Subdivision Plan of John M. Knaub and Janet D. Knaub, said Plan being recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book 45, Page 146. BEING PARCEL NO. 21-05-0431-056 SKI96.5PG23.07 E.rt hibit (B /S' k L B P S Lender Business Process Services 14523 SW Millikan Way; Suite 200; Beaverton, OR 97005 Business Hours (Pacific Time) Mon-Thu 5:00am to 9:00pm; Fri 5:00am to 6:00pm Sat 6:00am to 12:00pm; Sun 11:00am to 5:00pm October 28, 2010 Payments P.O. Box 7162; Pasadena, CA 91109-7162 Correspondence CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL PO Box 4121; Beaverton, OR 97076-4121 L1781 Phone COON, WILLIAM R 866.570.5277 300 HOLLOWBROOK DR Fax CARLISLE, PA 17013 866.578.5277 Website www.lbps.com RE: Loan No.: am ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE is is the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM E_MAP) may be able to help to save your home This Notice explains how the prom orks. To see if HEMAP can heln- vnn meet XW VT WITTI A 1' C%1%TQTT1LX1V" J.nr..%wn TE T 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 717-780-18691 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. COON, WILLIAM R Loan No.: Page 2 October 28, 2010 LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: COON, WILLIAM R 300 HOLLOWBROOK DR CARLISLE, PA GREENPOINT MORTGAGE FUNDING, INC. Lender Business Process Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PA iMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE.THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is hcensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. COON, WILLIAM R Loan No.: Page 3 October 28, 2010 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICA TION AS SOONAS POSSIBLE. IF YOU HAVE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STAR TING A FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORCLOSURE, YOU HAVE THE RIGHT TO FILE A HEMAP APPLICA TION E VEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, B UT IF YOUR APPLICATION IS E VENTUALL YAPPRO VED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. COON, WILLIAM R Loan No.: Page 4 October 28, 2010 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date.1 NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 300 HOLLOWBROOK DR CARLISLE PA IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Your loan is delinquent for the following months: December 2009, January 2010, February 2010, March 2010, April 2010, May 2010, June 2010, July 2010, August 2010, September 2010, October 2010 Past Due Installments: Totals Principal $2,984.29 Interest 16,573.05 Escrow Installment 1,909.84 Other Open Charges: Late Charges Property Inspections Less Suspense (Balance) TOTAL Prior Servicer Charges $0.00 0.00 $21,467.18 $355.60 $355.60 26.00 26.00 $381.60 $268.47 $21,580.31 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 21,580.3 1, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check certified check or money order made payable and sent to: Lender Business Process Services P.O. Box 7162 Pasadena, CA 91109-7162 (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAl GOVlCA LBPS maintains a local office at 600Seventeenth Street, Suite 800North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. LBPS Charges COON, WILLIAM R Loan No.: Page 5 October 28, 2010 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender will exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $ 50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the 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 Sheriffs Sale of the mortgaged property could be held would be approximately eight (8) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATrORNEYGENERAL V/CA LBPS maintains a local office at 600Seventeenth Street, Suite 800North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. COON, WILLIAM R Loan No.: Page 6 October 28, 2010 HOW TO CONTACT THE SERVICER: Name of Servicer: Lender Business Process Services, Inc. Address: PO Box 4121; Beaverton, OR 97076-4121 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Person(s): Holli Jennings or David Solomon E-Mail Address: ExternalCommunications@Ibps.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. « TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of Consumer Credit Counseling Agencies serving your county. (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CTfV: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Mdlikan Way, Beaverton, OR. COON, WILLIAM R Loan No.: Page 7 October 28, 2010 Sincerely, Lender Business Process Services Enclosures: PHFA list of HEMAP-approved agencies, How to Avoid Foreclosure THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff s??^???? of 4tuttbrrr?y?d i.:E Ste:; F;IFF' FILED-OFFIC' fl;c THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor 2011 APR 21 AM 10: 13 CUMBERLAND COUNT"( PENNSYLVANIA Fannie Mae vs. William Coon Case Number 2011-3638 SHERIFF'S RETURN OF SERVICE 04/15/2011 08:05 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 15, 2011 at 2005 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: William Coon, by making known unto himself personally, at 300 Hollow Brook Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.00 April 18, 2011 STEPHEN BENDER, DEPUTY SO ANSWERS, ?k RON F ANDERSON, SHERIFF ci Gaun5:a;lc Sherft Teleosuff ler, •ti PRAECIPE FOR WRTI' OF EXECUTION - (MORTGAGE FORECLOSURG .? P.R.C.P 3180- 3183 033 rn = =-n rn ?,. rn= - Goldbeck McCafferty & McKeever t-- ? '¢ vrn p Suite 5000 - Mellon Independence Center {? O C)-r 701 Market Street ?O a Philadelphia, PA 19106 = = M- 215-627-1322 C O Attorney for Plaintiff -C ? FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. WILLIAM COON Mortgagor(s) and Record Owner(s) 300 Hollowbrook Drive Carlisle, PA 17013 TO THE PROTHONOTARY: Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 11-3638 CIVIL PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: ?A 0-&\ S 4.0o CGr- 9 2.00 %.< <, 1W. oo %t .< a. so ???Oll•s? VU0111 Amount Due Interest from 5/19/2011 to Date of Sale per diem at $49.74 (Costs to be added) $291,650.66 BY: GO BECK MCC TY & MCKEEVER Michael McKeever P . ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Did Fein Pa. ID 82628 omas Puleo Pa. ID 27615 Attorneys for Plaintiff 17 , 5o 4 L Ck-9 Sto3?rs? aF 1% - ed? W Q W O a ? Z a O Z0 Z UO QO oc? z¢ Mo ¢O E4 zo U W H ? w z ?- o _ O x° ~ O a mo o, ?.b`Yp¢„? a) o a s..Q ? a, r?-?Gy a w a O ??x caN ? ? :c ?o ? at 3 o0U fjr? " Q u '? 0n ., 0 a a ALL THAT CERTAIN piece or parcel of land situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron pin on the eastern dedicated right-of-way line of North Middlesex Road, said iron pin being on the dividing line between Lots Nos. 6C and 5C on the hereinafter mentioned Plan of Lots; thence along said eastern dedicated right-of-way line of North Middlesex Road, North 21 degrees 47 minutes 30 seconds West, 203.00 feet to a point, said point being at the intersection of North Middlesex Road and Hollow Brook Drive; thence continuing along the southern dedicated right-of-way line of Hollow Brook Drive, North 29 degrees 32 minutes 26 seconds East, 220.00 feet to an iron pin on the boundary line between Lots Nos. 5C and 4C on the hereinafter mentioned Plan of Lots; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 350.00 feet to an iron pin; thence South 09 degrees 31 minutes 55 seconds East, 68.75 feet to an iron pin on the dividing line between Lots Nos. 5C and 6C on the hereinafter mentioned Plan of Lots; thence along said dividing line South 68 degrees 12 minutes 30 seconds West 375.85 feet to an iron pin on the eastern dedicated right-of-way line of North Middlesex Road, the place of BEGINNING. BEING Lot No. 5C on the Preliminary and Final Subdivision Plan of John M. Knaub and Janet D. Knaub, said Plan being recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book 45, Page 146. TAX PARCEL #:21-05-0431-056 BEING KNOWN AS: 300 Hollowbrook Drive, Carlisle, PA 17013 BEING the same premises which Thomas L. Williams and Marcianne H. Williams, husband and wife,by deed dated 9/8/2006 and recorded 9/11/2006 in Cumberland County In Deed Book Volume 276 at Page 2878 granted and conveyed unto William R. Coon, a married man. M1 Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ILED-OF F ICE U .EKE pROTHOWOTAR'i lot, MAJ zo AM to.. 32 FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. WILLIAM COON (Mortgagor(s) and Record Owner(s)) 300 Hollowbrook Drive Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 11-3638 CIVIL FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION), 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: 300 Hollowbrook Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): WILLIAM COON 300 Hollowbrook Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: WILLIAM COON 300 Hollowbrook Drive Carlisle, PA 17013 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 COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RICKEY L. ZIMMERMAN C/O MARCUS A. MCKNIGHT III ESQUIRE/IRWIN & MCKNIGHT PC 60 W. POMFRET STREET CARLISLE, PA 17013-3222 4. Name and address of the last recorded holder of every mortgage of record: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 MERS AS NOMINEE FOR GREENPOINT MORTGAGE FUNDING INC 100 WOOD HOLLOW DRIVE NOVATO, CA 94945 MERS AS NOMINEE FOR GREENPOINT MORTGAGE FUNDING INC PO BOX 2026 FLINT, MI 48501 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 300 Hollowbrook Drive Carlisle, PA 17013 (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 unswom falsification to authorities. DATED: May 18, 2011 By: GOL CK MCCAF & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 avid Fein Pa. ID 82628 homas Puleo Pa. ID 27615 Attorneys for Plaintiff 11-3638 CIVIL GOLDBECK McCAFFERTY & McKEEVER Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. WILLIAM COON Mortgagor(s) and Record Owner(s) 300 Hollowbrook Drive Carlisle, PA 17013 Defendant(s of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 11-3638 CIVIL 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: Coon, WILLIAM WILLIAM COON 300 Hollowbrook Drive Carlisle, PA 17013 Your house at 300 Hollowbrook Drive, Carlisle, PA 17013 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 court judgment of $291,650.66 obtained by FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION), 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. FILED-OFFICE OF THE PROTHONOTARY 201 ! MAY 20 AM tU*-32 IN THE COURT OF COMMON PLEAS 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. 11-3638 CIVEL 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orgLforeclosure/ 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 t 11-3638 CWEL 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 ht!p://www.phfa.org/con s umers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 10629417C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3638 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) Plaintiff (s) From WILLIAM COON (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 $291,650.66 L.L. $.50 Interest from 5/19/2011 to Date of Sale per diem at $49.74 Atty's Comm % Due Prothy $2.00 Atty Paid $166.50 Other Costs , To 91 Plaintiff Paid Date: 5/20/11 David uell, Protho t (Seal) By. *A A. I Deputy REQUESTING PARTY: Name: THOMAS PULEO, 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. 27615 In the Court of Common Pleas of Cumberland County FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. WILLIAM COON (Mortgagor(s) and Record Owner(s)) 300 Hollowbrook Drive Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT Z ?' - r No. 11-3638 C' -c ty p f?"1 ` ff p. Z CO { O CQ 2D 9" S ck-n ah k N 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 WILLIAM COON by default for want of an Answer. Assess damages as follows: Debt Interest from 5/19/2011 to Date of Sale per diem at $49.74 Total (Assessment of Damages attached) $291,650.66 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 maid or delivered to party against whom judgment is to be entered and to his attorney of record, if any, after the defau urred and ' lea eq days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 2 . / / By: GOLOBECK MCCAFFFIPTY & MCKEEVER Michael McKeever Pa. 56129 Gary McCafferty Pa. ID 42386 " ??, ?? Q Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 l?• V?+-_• `/,, Q J 6 C? 3 avid Fein Pa. ID 82628 xq S Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff n 1? OIJ ` ? k Kwllt C u ,? AND NOW M 1 x Wl. (I ,Judgment is entered in favor of FANNIE MAE (FEDERAL NATIO AL MORTGAGE ASSOCIATION) and against WILLIAM COON by default for want of an Answer and damages assessed in the sum of $291,650.66 as per he above certification. kul. ( Prothonotarl , 'b 'V. PJAVW 106294FC 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. TO: DATE OF THIS NOTICE: May 6, 2011 WILLIAM COON COON, WMLIAM 300 Hollowbrook Drive Carlisle, PA 17013 FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. WILLIAM COON (Mortgagor(s) and Record Owner(s)) 300 Hollowbrook Drive Carlisle, PA 1701.3 Defendant(s) TO: WILLIAM COON 300 Hollowbrook Drive Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 11-3638 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TIES NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES TNC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By; GOLD K RTY & MCKEEVER Micha 1 McKe er Pa. ID 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 Jill P. Jenkins Pa. ID 306588,/ 215-825-6360 Attomeys for Plaintiff 106294FC 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. TO: DATE OF THIS NOTICE: May 6, 2011 WILLIAM COON COON, WILLIAM 1917 Spring Road Carlisle, PA 17013 In the Court of FANNIE MAE (FEDERAL NATIONAL MORTGAGE Common Pleas ASSOCIATION) of Cumberland County 14221 Dallas Parkway suite 1000 CIVIL ACTION - LAW Dallas, TX 75254 Plaintiff vs. Action of WILLIAM COON Mortgage Foreclosure (Mortgagor(s) and Record Owner(s)) 300 Hollowbrook Drive Term Carlisle, PA 17013 No. 11 -3 63 8 CIVIL Defendant(s) TO: WILLIAM COON 1917 Spring Road Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WTTH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A RMGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carbslc, PA 17013 LEGAL SERVICES INC S Irvine Row Carlisle, PA 17013 _ 717-243-9400 By: JA ?,'(Afil GOLD M CAFFERTY & MCKEEVER Michael McKeev r Pa. ID 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 Jill P. Jenkins Pa. ID 306588) 215-825-6360 Attomeys for Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) Plaintiff vs. WILLIAM COON NO. 11-3638 CIVIL Defendant(s) 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, WILLIAM COON, has a last known residence of 300 Hollowbrook Drive, Carlisle, PA 17013. 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 falsificatiqxUo authoriti Date: 5/18/2011 By: GOLDB!WK MCCAFFWTY & MCKEEVER Michael McKeever Pa. ID 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 Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 May-18-2011 09:19:32 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency COON WILLIAM 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). y6t Ira 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 http://www.defenselink.mil/fag/])is/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 5/18/2011 r- . 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:5PFFM3BDF8 https://www.dmdc.osd.mil/appj/scra/popreport.do 5/18/2011 r , '~ • '~ ~!:_ KML LAW GROUP, P.C. ~ 1 _ ~ k, , ,- Suite 5000 - BNY Independence Center ~ ~ `~ ~' `~ ' ~=• 701 Market Street ~' ' x ~ ; ' Philadelphia, PA ]9106-1532 ~= 215-627-1322 ~~~ .#a~) C~)i~f~~~'^ Attorney for Plaintiff ~ - ~~~ ~a'~'~ ; ~~~~ FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County WILLIAM COON (Mortgagor(s) and Record owner(s)) 300 Hollowbrook Drive Carlisle, PA 17013 Defendant(s) No. l 1-3638 CIVIL PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. By. L LAW GROUP, P.C. ichael McKeever Pa. ID 56129 isa 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 Q~~ eq.sop~ ~'I ~~t ~a3$c~a ~~ a~~a.~ A M • KML LAW GROUP, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215)627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. WILLIAM COON (Mortgagor(s) and Record Owner(s)) 300 Hollowbrook Drive Carlisle, PA 17013 CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 11-3638 CIVIL Defendant(s) CERTIFICATE OF SERVICE Angela M. Smith, hereby certifies that he/she did serve true and correct copies of Praecipe to Vacate Judgment and a(ll,supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on 7 ~~~ ~p~ WILLIAM COON 300 Hollowbrook Drive Carlisle, PA 17013 WILLIAM COON 1917 Spring Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY By: ~ ~ _ KML LA ROUP, P.C. Angela M. Smith, Legal Assistant asmith@km l lawgroup.com 215-825-6325 (Direct Phone) KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. 1 _ i' '.., ~. ~ ~ ... - ~ x,.t, ~~} f ~wE r„`~ C~~,"~ r~ ~, -$, ,, R , ..:, ~ ~ +~ .~ t :..`~1 ~.'. , . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 11-3638 CIVIL WILLIAM COON (Mortgagor(s) and Record owner(s)) 300 Hollowbrook Drive Carlisle, PA 17013 Defendant(s) ~ PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon. payment of your costs only. KML LAW GROUP, P.C. F/K/A~OLDBECK McCAFFERTY & McKEEVER sy: ~ ichael McKeever Pa. ID 56129 ay E. Kivitz Pa. ID 26764 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ~' KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff FANNIE MAE (FEDERAL NATIONAL MORTGAGE ASSOCIATION) 1.4221 Dallas Parkway Suite 1000 Dallas, TX 75254 Plaintiff vs. WILLIAM COON (Mortgagor(s) and Record Owner(s)) 300 Hollowbrook Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 11-3638 CIVIL CERTIFICATE OF SERVICE Angela M. Smith, hereby certifies that he/she did serve true and. correct copies of Praecipe to Discontinue and End and all supp forting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on Ll ~ / ~~/p~ WILLIAM COON 300 Hollowbrook Drive Carlisle, PA 17013 WILLIAM COON 1917 Spring Road Carlisle, PA 17013 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY cKEEVER ,, By: ~ ~ ~G An a M. Smith, Legal Assistant asmith@kmllawgroup.com 215-&25-6325 (Direct Phone)