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Home My WebLink About11-3706MARTHA E. VON ROSENSTIEL, P.C. 27425CFC-DD Martha E. Von Rosenstiel, Esquire I No. 52634 Jacqueline F. McNally, Esquire I No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") CIO IBM LENDER BUSINESS PROCESS SERVICES, INC., AS SERVICER 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 PLAINTIFF V. JOANNE YOUNG 1610 Fox Hollow Road Mechanicsburg, PA 17055 DEFENDANT COURT OF COMMON PLEAS OF CUMBERLAND COUNTY I1=370W C ?n NO W4' r? . c o 1 7 ITI ..•?1 CIVIL ACTION - 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 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 Le han demandado a usted en la torte. 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 a sentar una comparencia escrita o en persona o con un abogado y entregar a la cone en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la cone toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la torte 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 o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 O p? ?d o 74/ 0?sNOb THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §16929 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") C/O IBM LENDER BUSINESS PROCESS SERVICES, INC., AS SERVICER 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 PLAINTIFF V. JOANNE YOUNG 1610 Fox Hollow Road Mechanicsburg, PA 17055 DEFENDANT 27425CFC-DD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Fannie Mae ("Federal National Mortgage Association"), a corporation organized and existing under federal law, c/o IBM Lender Business Process Services, Inc., as Servicer, 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. Defendant, Joanne Young is the mortgagor and real owner of premises 401 Norman Road, Camp Hill, PA 17011, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor, and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor, and real owner to Mortgage Electronic Registration Systems, Inc., as Nominee for Lehman Brothers Bank, FSB on January 25, 2007, which mortgage is recorded on February 5, 2007 in the Office of the Recorder of Deeds of Cumberland County in Record Book 1981, Page 2904, secured on premises 401 Norman Road, Camp Hill, PA 17011 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to Fannie Mae ("Federal National Mortgage Association") by written assignment dated February 16, 2011 and recorded on March 7, 2011 the Office of the Recorder of Deeds of Cumberland County as Document ID# 201107423 a true and correct description of which is attached hereto as Exhibit II. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from April 2010 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 3/1/2010 to 4/1/2011 at $26.24 per diem Accrued Escrow deficit to 4/1/2011 Attorney's Fee (5% of unpaid Principal balance) Property Inspections Suspense Total $ 133,950.00 $ 10,390.85 $ 703.21 $ 6,697.50 $ 173.00 $ (347.85) $ 151,566.71 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law,and will be collected in the event of a third party purchaser at Sheriffs sale. If the mortgage is reinstated prior to the Sheriffs sale, reasonable attorney's fees will be charged based on work actually performed. 10. Plaintiff sent to defendant, mortgagor, and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit III). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $151,566.71, plus per diem interest at $26.24 from March 30, 2011 to the date of judgment plus costs thereon. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY:/ L/ ----? Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally,'Esquire Attorneys for Plaintiff VERIFICATION Rebecca Graves hereby states that he/she is the Foreclosure Specialist of IBM Lender Business Process Services, Inc., Servicing Agent for Fannie Mae ("Federal National Mortgage Association") c/o IBM Lender Business Process Services, Inc., as Servicer, plaintiff herein; that he/she is duly authorized to make this Verification on behalf of IBM Lender Business Process Services, Inc., Servicing Agent for Fannie Mae ("Federal National Mortgage Association") and verifies that the statements made in the foregoing Complaint in Fannie Mae ("Federal National Mortgage Association") c/o IBM Lender Business Process Services, Inc., as Servicer v. Joanne Young relating to the property located at 401 Norman Road, Camp Hill, PA 17011 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: For'edosure Spedallst Title: IBM Lender Business Process Services, Inc. as servicer for Fannie Mae ("Federal National Mortgage Association") c/o IBM Lender Business Process Services, Inc., as Servicer Dated: LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania and described according to a Map of Property of Leonard J. Goss to be conveyed to Thompson W. Young, said Map made by Gerrit J. Betz, Registered Surveyor, dated August 16, 1971, as follows, to wit; BEGINNING at an iron pipe on the Southerly side of Norman Road, at a corner of Lot #15, said point of beginning being measured along the said side of Norman Road the distance of eighty (80) feet from its point of intersection with the side of Kingsley Road; thence extending from said point of beginning and along the Southerly side of Norman Road on the arc of a circle curving to the left having a radius of five hundred twenty-one and forty-three one-hundredths (521.43) feet the arc distance of sixty (60) feet to a hub, at a corner of Lot #18; thence extending along Lot # 18 and partly along Lot # 19, the two following courses and distances, (1) South two degrees fifty-two minutes twenty seconds West, the distance of one hundred (100) feet to a hub, and (2) South forty-five degrees forty-three minutes ten seconds West, the distance of thirty- eight and seventeen one-hundredths (38.17) feet to a hub, at a corner of Lot #14; thence extending along Lot No. 14, North sixty-nine degrees four minutes West, the distance of fifty- two and five one-hundredths (52.05) feet to an iron pipe, at a corner of Lot #15; thence extending along Lot No. 15, North ten degrees thirty-three minutes East, the distance of one hundred sixteen and sixty-nine one-hundredths (116.69) feet to the first mentioned point and place of beginning. BEING SHOWN as Lot #16, Block S, on Plan of Highland Park, in Plan Book 4, Page 98. BEING Designated as House #401 Norman Road TAX PARCEL NUMBER: 13-23-0545-294 Darer = ?yz3 . ? 3 MEMSYLVANIA 111111111 PREPARED BY & WHEN RECORDED RET M TO: LBPS 14523 SW ACM LMN MY, #200 BEAVERTON, OR 97005' ATTH coLurY CUJdBSRLAAiD PARCEL No. 13-23-0545-294 POOL NO. LOAN No. (11001974 ) (LB0106] I011M111111 ASSIGNMENT OF MORTGAGE mow ALL mEw ay THSsE PREsmm, thatd SYSTEMS,, ZW. AS N24EM PCR LEAN BNOMEW BAW, FS 9, located at 111 & VOCNIM ST. SiI1'!E C, DANVILLS, IL 61834 hereinafter re- ferred to as Assignor, for and in consideration of the sum of ONE DOLLAR ($1.00) lawful money of the United States of America together with other good and valuable consideration, to it in hand paid by FEDERAL NATIONAL MORTGAGE ASSOCIATION located at 14221 nlTM6 si1OMY BMMS 1000 Lil ZM, = 75254 hereinafter referred to as Assignee, at or before the delivery of these presents, the receipt of which is hereby acknowledged, has granted, bargained, sold, assigned, transferred, conveyed and set over unto said Assignee, its successors and assigns, all of its right, title and interest in and to that certain Mortgage dated the 25th day of JANUARY , 2007 made and executed by JOAIVlITS YOUNG , Mortgagor, to AVIdGM BLEC72KWC l2ra_'T4"?'R1=CK S07SM, INC. AS I Pl'R asaw jtaOTys BANK, FW , Mortgagee, covering premises situated in the county CUMBERLAND Commonwealth of Pennsylvania, more particularly described therein and commonly known as: TOWNSSIP OF LOWER ALLEN PROPERTY ADDRESS: 401 NORMAN RD., CAMP RILL, PA 17011 Said mortgage was duly recorded an the 5th day of FEBRUARY 2007 in the office of the Register, Clerk of Recorder of Deeds of CDNBERLAND County, in Book 1981 at Page 2904 or Document No. of the official Records of said Register, Clerk of Recorder of Deeds;together with that certain Note of even date and secured thereby in the principal amount of cm Kamm Tmag9t Tism TWEVAM N1 PTFPY and 1W/100----- , ( __ __ 133, 950. 00 ) made and executed by mortgagor and payable to the order of the aforementioned Mortgagee. As previously recorded from to in Book _ from to in Book from to in Book at Page (NMRI.PA.PH) at Page and at Page J=LB8040110AI.s.27718 on at Document No. on at Document No. on at Document No. and Page 1 of 2 ooW? Loan No. (11001974 ) [LB01061 TO HAVE AND TO HOLD the same unto said Assignee, its successors and assigns to its and their proper use and benefit forever. rN WITNESS WHEREOF, the said M3RZGRM B C SYS 06, 1W. AS XXV= FAR ITT BRQnWA BAW, FSB has caused these presents to be duly executed by its proper officer this 16th day of FEBRUARY 2011 but made effective AUGUST 2, 2010 1 1'?!C>8 SLR?'1RC C RSGISTi?ATuuty sawn w, nc. AS I FM LREWN BRO77=9 BAW, FSTB BY BY TIFFANY VICE PR STATE OF IDAHO COUNTY O BONNEVILLE on FEBRUARY 16, 2011 , before me, MELISSA HIVELY personally appeared TIFFANY BITSOI and personally (mown to me (or proved to we on the basis of satisfactory evidence) to be the persons who execute the within instrument as VICE PRESIDENT and on behalf of AMGRGE BrA=RM • MOMIIPAT4GW MMSH, Z C. AS BMW JUR LMW RWMW AWK, FSB and acknowledged to me that the Corporation executed it. MELISSA HIVELY MELISSA HIVELY (COMISSION kXk.-J07-28-14) NOTARY PUBLIC Notary Public STATE OF IDAHO ------------------------------------------------------------------------------ I DO HEREBY CERTIFY THAT THE PRECISE ADDRESS OP THE ASSIGNEE RESIDENCE IS: FEDSRAL_NATIONAL -MORTGAGE -ASSOCIATION --------------------------------- ------------------------------------------------------------------------------ -------------------------------------------------------------------------------- ------------------------------------------------------------------------------ _14221_DALLA3_ PARRNAY?_SUITE 1000DALLAS------------------------------------- ------------ ---- - -------------- TIFFANY BIT O LBPS VICE PRESI 14523 SW MILLIICAN WAY, #200 BRAVSRTON, OR 97005 ATTN P=S. 002.00189.308 MN 100025440003610182 MW PB3W: 1-888-679-6377 (Nmi.PA.2) C=S. 375. 0010 J=LB8040110AI.a.27718 Page 2 of 2 ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania and described according to a Map of Property of Leonard J. Goss to be conveyed to Thompson W. Young, said Map made by Gerrit J. Betz, Registered Surveyor, dated August 16, 1971, as follows, to wit; BEGINNING at an iron pipe on the Southerly side of Norman Road, at a corner of Lot #15, said point of beginning being measured along the said side of Norman Road the distance of eighty (80) feet from its point of intersection with the side of Kingsley Road; thence extending from said point of beginning and along the Southerly side of Norman Road on the arc of a circle curving to the left having a radius of five hundred twenty-one and forty-three one-hundredths (521.43) feet the arc distance of sixty (60) feet to a hub, at a corner of Lot #18; thence extending along Lot #18 and partly along Lot #19, the two following courses and distances, (1) South two degrees fifty-two minutes twenty seconds West, the distance of one hundred (100) feet to a hub, and (2) South forty-five degrees forty-three minutes ten seconds West, the distance of thirty-eight and seventeen one- hundredths (38.17) feet to a hub, at a comer of Lot #14; thence extending along Lot No. 14, North sixty-nine degrees four minutes West, the distance of fifty-two and five one- hundredths (52.05) feet to an iron pipe, at a corner of Lot #15; thence extending along Lot No. 15, North ten degrees thirty-three minutes East, the distance of one hundred sixteen and sixty-nine one-hundredths (116.69) feet to the first mentioned point and place of beginning. BEING SHOWN as Lot #16, Block S, on Plan of Highland Park, in Plan Book 4, Page 98. BEING Designated as House #401 Norman Road t TAX PARCEL. NUMBER: 13-23-0545-294 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY I COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201107423 Recorded On 3/712011 At 11:09:55 AM * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 83283 User ID - KW * Mortgagor - YOUNG, JOANNE * Mortgagee - FEDERAL NATIONAL MTG ASSOC * Customer - MARTHA VON ROSENSTIEL * FEES STATE WRIT TAR $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $11.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 * Total Pages - 4 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER OF 6DS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 11111111111111111111 AM LB 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 26, 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 YOUNG, JOANNE 866.570.5277 401 NORMAN RD Fax CAMP HILL, PA 1701 1 866.578.5277 Website www.lbps.com RE: Loan No.: 11001974 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. (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 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. YOUNG, JOANNE Loan No.: Page 2 October 26, 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: YOUNG, JOANNE 401 NORMAN RD CAMP HILL, PA LEHMAN BROTHERS BANK, FSB, A FEDERAL SAVINGS BANK Lender Business Process Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. (Continued) 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 W W W.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. YOUNG, JOANNE Loan No.: Page 3 October 26, 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 APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAYOF FORCLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED 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 W W W.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. YOUNG, JOANNE Loan No.: Page 4 October 26, 2010 HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 401 NORMAN RD CAMP HILL 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: April 2010, May 2010, June 2010, July 2010, August 2010, September 2010, October 2010 Past Due Installments: Totals Principal $0.00 Interest 5,586.84 Escrow Installment 1,174.60 $6,761.44 Prior Servicer Other Open Charges: Charges LBPS Charges Property Inspections $72.00 $26.00 $98.00 $98.00 Less Suspense (Balance) $347.85 TOTAL $6,511.59 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 6,511.59, 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.GOV/CA. LBPS maintains a local office at 600Sevcmccnth 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. YOUNG, JOANNE Loan No.: Page 5 October 26, 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 paving the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s 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.COLORADOATTORNEYGENERAL.GOV/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. YOUNG, JOANNE Loan No.: Page 6 October 26, 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@lbps.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the 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 1S 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 W W W.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. YOUNG, JOANNE Loan No.: Page 7 October 26, 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 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. HEMAP Consumer Credit Counseling Agencies Report last updated: 7/30/2010 8:57:41 AM ^' - CUMBERLAND County American Credit Counseling Institute 175 Strafford Averue CCCS of Western PA Suite 1 2000 Linglestown Road Wayne, PA 19087 Harrisburg, PA 17102 610.971.2210 888.511.2227 888.212.6741 Community Action Commission of Capital Rezlion American riaraneiz; Counseling Sr-rAceti Inc, 1514 Derry Street 1080 N. Delaware Avenue Harrisburg, PA 17104 Suite 200 717,232.97.57 Philadelphia, PA 19125 267.228.7903 'Marar:atha 800.490.3039 43 Philadelphia Avenue Waynesboro. PA 17268 American Financial Counseling Services Inc, 717.762.3285 405 West Germantown Pike Norristown, PA 19403 PA Interfaith Community Programs InC 267.228.7903 40 E High Street 800.490.3039 Gettysburg, PA 17325 717.334.1518 American Financial Counseling Services Inc. 175 Strafford Avenue PHFA Suite One 211 North Front Street Wayne, PA 19087 Harrisburg, PA 17110 267.228.7903 717.780.3940 800.490.3039 800.342 2397 American Red Cross of Chester DAUPHIN County 1729 Edgemont Avenue CCCS of Western PA Chester, PA 19013 2000 Linglestown Road 610.874.1484 Harrisburg, PA 17102 ,tPM 888.511.2227 600 W Diamond Street Community Action Commission of Capital Region Philadelphia, PA 19122 1514 Derry Street 215.235.6070 Harrisburg, PA 17104 (267) 953-4615 717.232.9757 Carroll Park Community Council, inc. PHFA 5218 Master Street 211 North Front Street Philadelphia, PA 19131 Harrisburg, PA 17110 215.877.1157 717, 780.3940 CCCS of Delaware Valley $00.342.2397 4400 North Reese Street DELAWARE County Philadelphia, PA 19140 215.563.5665 Advocate>Fi for Financial Irrd=rpendence 1503 Wadsworth Ave CCCS of Delaware Valley Philadelphia PA 19150 1003 East Lincoln Highway 267-323-2696 Suite 102 Coatesville, PA 19320 American Credit Counseling Institute 215.563.5665 526-528 Dekalb Street Norristown, PA 19401 CCCS of De€aware Valley 610.971.2210 113 East Main Street 888 712 6741 2nd Floor Norristown„ PA 19401 215.563.5665 Page 8 of 21 LBPS'" 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 26, 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 Ll78/ Phone 866.570.5277 YOUNG, JOANNE 1610 FOX HOLLOW RD Fax MECHANICSBURG, PA 17055 866.578.5277 Website www.lbps.com RE: Loan No.: 1 1001974 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The name, address and phone number of Consumer Credit Counseling Agencies Serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. (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 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. 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 A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. YOUNG, JOANNE Loan No.: Page 2 October 26, 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: YOUNG, JOANNE 401 NORMAN RD CAMP HILL, PA LEHMAN BROTHERS BANK, FSB, A FEDERAL SAVINGS BANK Lender Business Process Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. (Continued) 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 W W W.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. YOUNG, JOANNE Loan No.: Page 3 October 26, 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 counselingasencies 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 APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTINGA FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORCLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED 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 W W W.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. YOUNG, JOANNE Loan No.: Page 4 October 26, 2010 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 401 NORMAN RD CAMP HILL 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: April 2010, May 2010, June 2010, July 2010, August 2010, September 2010, October 2010 Past Due Installments: Totals Principal $0.00 Interest 5,586.84 Escrow Installment 1,174.60 $6,761.44 Prior Servicer Other Open Charges: Charges LBPS Charges Property Inspections $72.00 $26.00 $98.00 $98.00 Less Suspense (Balance) $347.85 TOTAL $6,511.59 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 6,511.59, 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.GOV/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. YOUNG, JOANNE Loan No.: Page 5 October 26, 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 yeriod 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 attornev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing _any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately 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 POSS113LE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE W W W.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. YOUNG, JOANNE Loan No.: Page 6 October 26, 2010 HOW TO CONTACT THE SERVICER: Name of Servicer: Lender Business Process Services, Inc. Address: PO Box 4121; Beaverton, OR 970764121 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Person(s): Holli Jennings or David Solomon E-Mail Address: ExternalCommunications@lbps.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the 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 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. YOUNG, JOANNE Loan No.: Page 7 October 26, 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 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. HEMAP Consumer Credit Counseling Agencies Report last updated: 7/3012010 8:57:41 AM CUMBERLAND County American Credit Counseling Institute 175 Strafford Avenue C ,',CS of Wp sfern PA Suite 1 2000 Lingiestown Road Wayne, PA 19087 Harrisburg, PA 17102 610.971.2210 888.511.2227 888.212.6741 Community Action Commission of Capital Region American f`inanc;al Counseling Sarvrfcezi Inc, 1514 Derry Street 1080 N. Delaware Avenue Harrisburg, PA 17104 Suite 200 717,232.97.57 Philadelphia.. PA 19125 267.228.7903 ".,aranatha 800.490.3039 43 Philadelphia Avenue Wavnesboro, PA 17268 American Financial Counseling Services Inc. 717162.3285 405 West Germantown Pike Norristown, PA 19403 PA Interfaith Community Programs 1FrC 267.228.7903 40 E High Street 800.490.3039 Gettysburg, PA 17325 717334.1518 American Financial Counseling Services Inc. 175 Strafford Avenue PNFA Suite One 211 North Front Street Wayne, PA 19087 Harrisburg, PA 17110 267.228.7903 717.780.3940 800.490.3039 800.342.2397 American Rrrd Cross of Chester DAUPHIN County 1729 Edgemont Avenue CCCS of Western PA Chester, PA 19013 2000 Lingiestown Road 610.874.1484 Harrisburg, PA 17102 APN1 888 511.2227 600 W Diamond Street Community Action Commission of Capital Region Philadelphia, PA 19122 1514 Derry Street 215.235.6070 Harrisburg, PA 17104 (267) 953-4615 717.232.9757 Garrott Park Community Council, inc. PHFA 5218 Master Street 211 North Front Street Philadelphia, PA 19131 Harrisburg, PA 17110 215.877.1157 717.7803940 CCCS of Delaware Valley 800.342.2397 4400 North Reese Street DELAWARE County Philadelphia, PA 19140 215.563.5665 Advocite?, for Financial Independence 1503 Wadsworth Ave CCCS of Delaware Valley Philadelphia, PA 19150 1003 East Lincoln Highway 267-323-2696 Suite 102 Coatesville, PA 19320 rnerican Credit Counseling Institute 215.563.5665 526-528 Dekalb Street Norristown. PA 19401 CCCS of Delaware Valley 610.971.2210 113 East Main Street 888.212.6741 2nd Floor Norristown. PA 19401 215.563.5665 Page 8 of 21 #27425DDCPG MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL COURT OF COMMON PLEAS MORTGAGE ASSOCIATION") C/O IBM CUMBERLAND COUNTY LENDER BUSINESS PROCESS SERVICES, : INC., AS SERVICER PLAINTIFF : Case No: 11-3706 VS. M'M cxr JOANNE YOUNG DEFENDANTS PRAECIPE TO REINSTATE COMPLAINT IN MORTGAGE FORECU][?s r , To the Prothonotary: Kindly reinstate the Complaint in Mortgage Foreclosure in the above matter. MARTHA E. VON ROSENSTIEL, P.C. BY: ?--? / (A Ma'ffha E. Von RosenstieloEsquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff DATED: June 2, 2011 j 6f d-,7-#Y Ck,4 y4 3 J- f.4?a403yY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor j FILED-OFFICE O THI-7 PROTHONOTARY 2011 JUL I I AM 11: 23 CUMBERLAND COUNT`' PENNSYLVANIA Fannie Mae vs. Case Number Joanne Young M M").. 2011-3706 SHERIFF'S RETURN OF SERVICE 06/10/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Gary Young, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 06/17/2011 09:50 AM - Lebanon County Return: And now June 17, 2011 at 0950 hours I, Michael J. DeLeo, Sheriff of Lebanon County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Gary Young by making known unto himself personally, at 720 E. Main Street, Palmyra, Pennsylvania 17078 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.44 SO ANSWERS, 6 .-'?2' Z' x Z??/ July 07, 2011 RON R ANDERSON, SHERIFF Coup<ySuite Sre?:f i?: eosori b.:'. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. BuellProthonotary Joanne Young 401 Norman Road Camp Hill, PA 17011 FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") PLAINTIFF vs. JOANNE YOUNG DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 1 I -M6 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $154,636.79 on July 27, 2011. Proth?otary + M-, ?X Judgment by Default z ' . Money Judgment othonotairy Courthouse Square mberland County Courthouse rlisle, PA 17013-3387 Judgment in Replevin Judgment for Possession Jude j 1 „_ rd of Arbitration i.' Ititi 11 TA' + dings ( I i 1it r,? P1 ! . v 3 COF O? ; ,^, D COUNTY 'elephone r, PENNSYLVANIA Joanne Young 401 Norman Road Camp Hill, I lbo PITNEY B( jt? 02 1 P 000, 0001669279 JUL 26 2 MAILED FROM ZIP CODE IS . r "N' z ; RETU9N TD SENDEV VOUNG .JOANNE MOVED LEFT NO ADDRESS UNADLE To PoRWARD RETURN T TCa SENDER MC: Ii~3'????•ri?l ?1?;!i;I e: 37013339499 303-0425.5-29-? 1 A ' C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE ('FEDERAL NATIONAL MORTGAGE ASSOCIATION") #27425CFJ-DN Plaintiff V. NO. 11-3706 '"'?.•) v tri F71 Wr rte- ? ? rr C C3 ? C:) -n ° C-I >? w o M.? C°1 JOANNE YOUNG Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Joanne Young for want of an answer. (X) Assess Damages as Follows Debt Interest from 4/2/11 to 7/27/11 At $26.24 per diem Total $ 151,566.71 $ 3,070.08 $ 154,636.79 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY a" e 1N 00pd aNkl art a . Von Rosenstiel, Esq re C ((. Fk ??? N ?P J cqu me F. McNally, Esquire w4-A; ?f 9 7 Attorneys for Plaintiff ?O?•? vvlll?`ea Thiso2l day of LJ1 , 2011 judgment is entered in favor of the Plaintiff and against Defendant(s), Joanne Young by default for want of answ and dagLages assesse the sum of $154,636.79 as per the above certification. 40 Prothonola in er and County 9 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") C/O IBM LENDER BUSINESS PROCESS SERVICES, INC., AS SERVICER 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 V. JOANNE YOUNG 1610 Fox Hollow Road Mechanicsburg, PA 17055 PLAINTIFF DEFENDANT To: Joanne Young 1610 Fox Hollow Road Mechanicsburg, PA 17055 427425CTD - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-3706 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 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 NOTICE TO A 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 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: July 14, 2011 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire /No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION') C/O IBM LENDER BUSINESS PROCESS SERVICES, INC., AS SERVICER 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 PLAINTIFF V. JOANNE YOUNG 1610 Fox Hollow Road Mechanicsburg, PA 17055 DEFENDANT TO: Joanne Young 401 Norman Road Camp Hill, PA 17011 #27425CTD - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-3706 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 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 NOTICE TO A 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 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: July 14, 2011 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire /No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") C/O IBM LENDER BUSINESS PROCESS SERVICES, INC., AS SERVICER 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 PLAINTIFF V. JOANNE YOUNG 1610 Fox Hollow Road Mechanicsburg, PA 17055 DEFENDANT TO: GaryYoung 720 E. Main Street Palmyra, PA 17078 #27425CTD - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-3706 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 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 NOTICE TO A 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 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: July 14, 2011 i MARTHA E. VON ROSENSTIl3L, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff vs. JOANNE YOUNG Defendant(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 11-3706 NON MILITARY AFFIDAVIT Jacqueline F Md*WY Esquire hereby certifies that: 1. I am the attorney for the plaintiff herein. #27425CFJ-DN 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. a E. Von Rosenstiel, Es ire aacqueline F. McNally, Esquir ttorneys for Plaintiff Dated: July 27, 2011 i F OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, I Courthouse Square, Carlisle, PA 17013 Joanne Young 1610 Fox Hollow Road Mechanicsburg, PA17055 FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") PLAINTIFF v5. . ,.. JOANNE YOUNG DEFENDANT(S) David D. Buell, Prothonotary COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-3706 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $154,636.79 on July 27, 2011. Prothon ry X? Judgment by Default 1 ?}lt Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration 1-1 Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney , Esquire at this telephone number: 610-328-2887. F OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Joanne Young 401 Norman Road Camp Hill, PA 17011 FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") PLAINTIFF vs. JOANNE YOUNG DEFENDANT(S) David D. BuellProthonotary COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-3706 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amou of $154,636.79 on July 27, 2011. Protho tary a f El Judgment by Default Money Judgment Judgment in Replevin 7 Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Esquire at this telephone number: 610-328-2887. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3706 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 JOANNE YOUNG (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: $154,636.79 Interest from 7/28/11 to 12/7/11 -- $3,380.86 L.L.: $.50 Atty's Comm:6% Atty Paid: $253.94 Plaintiff Paid: Date: 8/12/11 (Seal) Due Prothy: $2.00 Other Costs: '-4p/ David D. Buell, P othonotary By: Deputy REQUESTING PARTY: Name: JACQUELINE F. McNALLY, ESQUIRE Address: MARTHA E. VON ROSENSTIEL, PC 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 201332 27425CWE-DN Commonwealth of Pennsylvania COUNTY OF CUMBERLAND FANNIE MAE ("FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION") JOANNE YOUNG V. Praecipe for Writ TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 7/28/2011 to 12/7/2011 At6% TOTAL* *Plus costs to be endorsed DOCKET NO. 11-3706 ATTORNEY I.D. #,-?Q 133.z, of Executiox P; ^ M 3?. . z-r, $ 1 §§636 f4 . j "D I .. . $ 3,380.86 $ 158,017.65 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: 0 yx??t' a E. Von Rosenstiel, quire Jacqueline F. McNally, Esquire Attorneys for Plaintiff PREM: 401 Norman Road, Camp Hill, PA 17011 O 01.4.0o P6 A-r" Nf 74. oo CBF 3q.4y 0.00 10.00 " 14.00 x63.94 - PO Al-t/ 4.1.00 UM 4.50 LL & 47433 P,* &o3 !88 E: l01';t d ?.c,a, . o `O o n W CD 0 CD w 000 ' d `C p CrJ 0, > ? o 00 ?.o CD ro ? --5 00 CD ?4 z O C CCD zCD No 0 w v, W N N C*N W .p H>`2a ??rnoo G rnO ? H (dD o a E?S 4?A 0o W ? ow •-+ 00 W ? o rn ? rn "d CD 'TI o? CD C/) CD n C 0 a to O 0 C a Ci7 > ITi r? a? H °zz °z r z O w v O Oo ?Tl H Cd ? ? O z d? Q°z ?r H ? MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire /No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff Fannie Mae ("Federal National Mortgage Association") c/o IBM Lender Business Process Services, Inc., as : Servicer 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 Plaintiff vs. Joanne Young 1610 Fox Hollow Road Mechanicsburg, PA 17055 Defendants COURT OF COMMON PLEAS CUMBERLANDCOUNTY -- rri =M C7- M7- cn r _. =a c, No: 11-3706 ? N CD .<: AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE F. , attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Joanne Young 1610 Fox Hollow Road Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: t,w AartE. Von Rosenstiel, Esq 're Qtrrieys ueline F. McNally, Esquire for Plaintiff #27425-CWE-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. JOANNE YOUNG No: 11-3706 Defendant(s) _ CERTIFICATE TO THE SHERIFF C rn ?. h3 -Q'..,Q,;,. ' t J _V :X Y• ?,.,.. w I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: FHA - Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit XX That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false statement given herein. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: art . Von Rosenstiel, Esq e J queline F. McNally, Esquire ttorneys for Plaintiff #27425CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff' FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff VS. JOANNE YOUNG Defendant(s) .. 0.?a.'. - r-Z) = car • -p-, ? COURT OF COMMON PLEAS c n+" cs - CUMBERLAND COUNTY - '- N ?? -1 (n -'V =;- ..rt; ;z; v ?.. fA) NO: 11-3706 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 ? ns f.?, , ESQUIRE, attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 401 Norman Road, Camp Hill, PA 17011: 1. Name and address of owners(s) or reputed owner(s) Joanne Young 1610 Fox Hollow Road Mechanicsburg, PA 17055 2. Name and address of defendant(s) in the judgment: Joanne Young 1610 Fox Hollow Road Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 ` PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603. Occupant 401 Norman Road Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. a E. Von Rosenstiel, E ire BYJacqueli McNally, Esquire ne F. torneys for Plaintiff Dated: August 02, 2011 27425CAM-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 PA 19018 Secane , (610) 328-2887 " , -`= Attorneys for Plaintiff M X'" rn FANNIE MAE ("FEDERAL COURT OF COMMON PLEAS NATIONAL MORTGAGE CUMBERLAND COUNTY ASSOCIATION") a Plaintiff t= vs. No: 11-3706 JOANNE YOUNG Defendants NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 401 Norman Road Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on Date of Sale: December 07, 2011 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 11-3706 in the Court of Common Pleas of Cumberland County by Fannie Mae ("Federal National Mortgage Association"), Plaintiff against Joanne Young, Defendant(s). Judgment was entered on July 29, 2011 in the amount of $154,636.79. The property was seized and taken in execution as the property of Joanne Young. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania and described according to a Map of Property of Leonard J. Goss to be conveyed to Thompson W. Young, said Map made by Gerrit J. Betz, Registered Surveyor, dated August 16, 1971, as follows, to wit; BEGINNING at an iron pipe on the Southerly side of Norman Road, at a corner of Lot # 15, said point of neginning being measured along the said side of Norman Road the distance of eighty (80) feet from its point of intersection with the side of Kingsley Road; thence extending from said point of beginning and along the Southerly side of Norman Road on the arc of a circle curving to the left having a radius of five hundred twenty-one and forty-three one-hundredths (521.43) feet the arc distance of sixty (60) feet to a hub, at a corner of Lot #18; thence extending along Lot # 18 and partly along Lot # 19, the two following courses and distances, (1) South two degrees fifty-two minutes twenty seconds West, the distance of one hundred (100) feet to a hub, and (2) South forty-five degrees forty-three minutes ten seconds West, the distance of thirty- eight and seventeen one-hundredths (38.17) feet to a hub, at a corner of Lot #14; thence extending along Lot No. 14, North sixty-nine degrees four minutes West, the distance of fifty- two and five one-hundredths (52.05) feet to an iron pipe, at a corner of Lot # 15; thence extending along Lot No. 15, North ten degrees thirty-three minutes East, the distance of one hundred sixteen and sixty-nine one-hundredths (116.69) feet to the first mentioned point and place of beginning. BEING SHOWN as Lot # 16, Block S, on Plan of Highland Park, in Plan Book 4, Page 98. BEING Designated as House #441 Norman Road Tax ID #13-23-0545-294 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 11-3706. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 #27425-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff VS. JOANNE YOUNG Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-3706 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania and described according to a Map of Property of Leonard J. Goss to be conveyed to Thompson W. Young, said Map made by Gerrit J. Betz, Registered Surveyor, dated August 16, 1971, as follows, to wit; BEGINNING at an iron pipe on the Southerly side of Norman Road, at a corner of Lot #15, said point of beginning being measured along the said side of Norman Road the distance of eighty (80) feet from its point of intersection with the side of Kingsley Road; thence extending from said point of beginning and along the Southerly side of Norman Road on the arc of a circle curving to the left having a radius of five hundred twenty-one and forty-three one-hundredths (521.43) feet the arc distance of sixty (60) feet to a hub, at a corner of Lot #18% thence extending along Lot #18 and partly along Lot #19, the two following courses and distances, (1) South two degrees fifty-two minutes twenty seconds West, the distance of one hundred (100) feet to a hub, and (2) South forty-five degrees forty-three minutes ten seconds West, the distance of thirty-eight and seventeen one-hundredths (38.17) feet to a hub, at a corner of Lot #14; thence extending along Lot No. 14, North sixty-nine degrees four minutes West, the distance of fifty-two and five one-hundredths (52.05) feet to an iron pipe, at a corner of Lot # 15; thence extending along Lot No. 15, North ten degrees thirty-three minutes East, the distance of one hundred sixteen and sixty-nine one-hundredths (116.69) feet to the first mentioned point and place of beginning. BEING SHOWN as Lot #16, Block S, on Plan of Highland Park, in Plan Book 4, Page 98. BEING Designated as House #401 Norman Road IMPROVEMENTS: Residential dwelling Tax Parcel # 13-23-0545-294 TITLE TO SAID PREMISES IS VESTED IN Joanne Young by reason of the following: BEING THE SAME PREMISES WHICH Leonard J. Goss and Charlotte J. Goss, his wife by Deed dated 8/27/1971 and recorded 9/2/1971 in the County of Cumberland in Record Book G-24, Page 580 conveyed unto Thompson W. Young and Joanne Young, his wife, in fee. AND THE SAID Thompson W. Young departed this life on whereby Title to said premises became vested in Joanne Young by right of survivorship. 427425CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff VS. JOANNE YOUNG Defendant(s) 11- c -n COURT OF COMMON PLEAS V Z a rnOP CUMBERLAND COUNTY x c X-n rn -a NO: 11-3706 b N XF AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 F., Md , ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY• - a rt E. Von osenstiel, E ire acqueline F. McNally, Esquire Attorneys for Plaintiff for m W ? to '? N j Z 1 CU ? ? r Q l r? c C, 0 o 3 (1) -Z N x 0 0 =3, _ C: 9 ?-nS m O N o , -o v m ° CA D' °1 cD p S . p 0 ? m co s 00 -oo ° S c?5. n0 -0 o•OS?0 0 0 CD _c,? o.0 U) -o o Co yea N C) -0 d m co ?? ? ? ? ?, W.y a 00. m .wA o • ? ? o N H 03NC N N 3C7 Z1 ? . o O " ' 3 z C Zi U3 . cr 0 :T a? :Q O O ? m ? Na 3 CD 'a o CD o ? ? '% 0 .. C X cD O' a O G O ? "I CA w ? ?y . s ?U?- N t9 7?m o C + G QyN 0 C n w CD 0 _ 'o = -, N 3 ? t7 ? N y .0 K ? (y rat ? > N 'N? W W ? G W O , m ¢ to G <O N ` ? ?^ M 4?1 O0 o ?N S ?_? ° >1 W?hN o- %?" o g m ? ? °A '?' ? ° ? ? N -o„ ? ' m "' C? :o om S?? 'fl c a mm s5• i0 t4 m n 7o wm?m G7G 0 NN '. ? n -4 Jw?oooy ?? min N 3 a _ 0 CD 4 a fD , N O. ?T?? f gg 1 V ?B-O ?a3 c 3 ? 3' Y ?, N G 3 c 3o?y. 0 o ?cmc• m ?•oioa 3 G 40 N? tw a o °?0m 7 S. ?$ n c??o b n NgD 3v, o m m??o o 0 -a m CD N o fAN Q W ? S oa• ^m CL ut 0 0 , N 'O O m -n N nCOO ;N3 ? . p v? m G c ? Z C O r "O n O?Q 0 ? ? N (D CD 0 O 4 0 CD U. a ? mS m? ?c 2- a :ra ? U3 LSD d - ? o a ? (.0 N ?. CD cc y G p N oo O N e N m c N ? ? m (n a o' v? v m m -n i m ? C) s. r {LFD=OFF1Ci- '" Tr - PRC IHONOTP-?? AFFIDAVIT OF sERVIi41 1 SEP 26 AM 11: 0 PLAINTIFF: Fannie Mae ("Federal National Mortgage Association") DEFENDANT Joanne Young SERVE UPON: Joanne Young 1610 Fox Hollow Road Mechanicsburg, PA 17055 SPECIAL INSTRUCTIONS: please serve defendant personally or adult in charge of premises CUMBERLAND CGUNI"iL' A f COURT OF COMMON PLCAJ Cumberland COUNTY COURT NO. 11-3706 TYPE OF ACTION XX WRIT OF EXECUTION and Notice of Sheriffs Sale Sheriffs Sale date: lZ7/201f 27425CNC-DN SERVED Served and made known to Defendant, on the day of zoo at o'clock, M., at , Commonwealth of Pennsylvania, in the manner described below: whom Relationship is Adult in charge of Defendant-sres.idence who refused Manager/Clerk of place of lodging in which Defendant resides. Agent or person in charge of Defendant's office or usual place of business. Other Description: Age Height Weight_,_,._ Race Sex Other , a competent adult, being duly sworn according to law, depose and state that 1 personally handed to a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriffs Sale issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed Klt?',lx.v.l `' C L; rTY before me this daY' of 120 N1 IJ AhY PUBI-IC' STAiI. 0F NEW FPISE Notary: By: 13 NOT SERVED On the day of 201( , at _ o S o'clock --P-. M., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Time of Attempt: Date of Attempt: Result: , A , f 5 f 1)"a O i--?D ?'S NAPS r AJ6 pkt u -r y fa-N D T "T GA NYO U 96 -1 I -7 (-7- 33q- 4394) is ?.O.At i worn to and subscribeO before me this ;244-L - day of 2Qr,L. Notary: r By: ATTORNEY Martha E. Von Rosenstiei, P.C. 649 South Avenue, Unit 7 9 Secane, PA 19018 • 610-328-2887 LE - 0 F! CE ram T pR0 ? NOa 0 TA 2011 SPP 26 AM 11: 02, PLAINTIFF: Fannie Mae ("Federal National Mortgage Association") DEFENDAN'T Joanne Young SERVE UPON: Joanne Young 401 Norman Road Camp Hill, PA 17011 COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 113706 TYPE OF ACTION XX WRIT OF EXECUTION and Notice of Sherifrs Sale 27425CNC-DN SPECIAL INSTRUCTIONS: please serve defendant personally or adult Sheriff s Sale date: 12/7/2091 in charge of premises SERVED Served and made known to Defendant, on the day of 200 at o'clock, M., at Commonwealth of Pennsylvania, in the manner described below: I Defendant personally served. , Manager/Clerk of place of lodging in which i Adult family member with whom Defendant Defendant resides. i resides. Agent or person in charge of Defendant's office I( Relationship is or usual place of business. Adult in charge of Defendant's residence Other i who refused i? to give name/relationship. Description: Age Height Weight Race Sex Other 1, , a competent adult, being duly sworn according to law, depose and state that i personally handed to a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriffs Sale issued in the captioned case on the date and at the address indicated above. Swom to and subscribed before me this day of 2Q Notary: By: NOTSERV.ED On the ?7, f' day of _ bcLqS r 20 f t , at 1,35 o'clock A. M., Defendant NOT FOUND because: Moved Unknown No Answer V/ Vacant Date of Attempt: Time of Attempt: Result: i i Swom to and subscr ibed l \ /I NOTARY PUBLIC before me Of Notary: By: AFFIDAVIT OF SERA)"#j bpLFr Coi C,? ,', J+PENNSYLVANIA STAFF OF NEW ERSEY QMY COMMISSION.EX71RES MARCH 7, 2013 J / ATTORNEY i Martha E. Von Rosenstlel, P.C. r 649 South Avenue, Unit 7 9 Secane, PA 19018 • 610-328-2887 7f SHERIFF'S OFFICE OF CUMBERLAND COUNTY L , L) J i e y r Ronny R Anderson L k -? I Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Hid 2 JAN 10 AM 10: 17 CUMBERLAND COUNTY PENNSYLVANIA Fannie Mae vs. Joanne Young (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2011-3706 10/07/2011 Michelle Gutshall, Deputy, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 401 Norman Road, Camp Hill, Cumberland County. 12/07/2011 Ronny Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pa. on December 7, 2011 at 10 a.m. He sold the same for the sum of $1.00 to Attorney Martha E. Von Rosenstiel, on behalf of Fannie Mae (" Federal National Mortgage Association"), P.O. Box 650043, Dallas, TX 75265-0043. Fannie Mae, being the buyer in this execution, paid to the Sheriff the sum of $1,128.99 01/10/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states this writ is returned STAYED. SHERIFF COST: $1,128.99 SO ANSWERS, January 10, 2012 RON R ANDERSON, SHERIFF y? 00 el . . sz tom.. ',el, ek .* %'y9 ??o rr.) CcuntyS?tlar", She f(. "re'. ecr oft. Inc COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Fannie Mae is the grantee the same having been sold to said grantee on the 7 day of December A.D., 2011, under and by virtue of a writ Execution issued on the 12 day of August, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 3706, at the suit of Fannie Mae against Joanne Yount; is duly recorded as Instrument Number 201200889. IN TESTIMONY WHEREOF, I have hereunto set my hand a-. and al of said office this f D day of A.D. /r A of Deeds 1ewffw d 69gftj evbWWW 0W to gale, PA tj Commission free ft Frst M=Jq of Jan. 2014 On August 19, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 401 Norman Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2011 By: i" Real Estate Coordinator r `t C F CUMBERLAND LAW JOURNAL Writ No. 2011-3706 Civil Fannie Mae VS. Joanne Young Gary Young Atty.: Martha E. Von Rosenstiel ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania and described according to a Map of Property of Leonard J. Goss to be conveyed to Thompson W. Young, said Map made by Gerrit J. Betz, Registered Surveyor, dated August 16, 1971, as follows, to wit; BEGINNING at an iron pipe on the Southerly side of Norman Road, at a comer of Lot #15, said point of beginning being measured along the said side of Norman Road the distance of eighty (80) feet from its point of intersection with the side of Kingsley Road; thence extending from said point of beginning and along the Southerly side of Norman Road on the arc of a circle curving to the left having a radius of five hundred twenty-one and forty-three one-hundredths (521.43) feet the arc distance of sixty (60) feet to a hub, at a corner of Lot # 18; thence extending along Lot #18 and partly along Lot #19, the two following courses and distances, (1) South two degrees fifty- two minutes twenty seconds West, the distance of one hundred (100) feet to a hub, and (2) South forty- five degrees forty-three minutes ten seconds West, the distance of thirty- eight and seventeen one-hundredths (38.17) feet to a hub, at a comer of Lot # 14; thence extending along Lot No. 14, North sixty-nine degrees four minutes West, the distance of fifty- two and five one-hundredths (52.05) feet to an iron pipe, at a corner of Lot # 15; thence extending along Lot No. 15, North ten degrees thirty- three minutes East, the distance of one hundred sixteen and sixty-nine one-hundredths (116.69) feet to the first mentioned point and place of beginning. BEING SHOWN as Lot # 16, Block S, on Plan of Highland Park, in Plan Book 4, Page 98. BEING Designated as House #401 Norman Road. IMPROVEMENTS: Residential dwelling. Tax Parcel # 13-23-0545-294. TITLE TO SAID PREMISES IS VESTED IN Joanne Young by reason of the following: BEING THE SAME PREMISES WHICH Leonard J. Goss and Char- lotte J. Goss, his wife by Deed dated 8/27/1971 and recorded 9/2/1971 in the County of Cumberland in Record Book G-24, Page 580 con- veyed unto Thompson W. Young and Joanne Young, his wife, in fee. AND THE SAID Thompson W. Young departed this life on whereby Title to said premises became vested in Joanne Young by right of survivorship. 86 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 21, October 28, and November 4, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. I- ? 4-;? I----- Lis arie Coyne, Edo r SWORN TO AND SUBSCRIBED before me this da of November, 2011 Notary NOTARIAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 t4tPaft1*otArXtws Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-,News CG. aforesaid by virtue and pursuant to a-resolution unanimously passed'and adopted severally-by the- stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: irl7kii?iili 10/28/11 11/04/11 Sworn bscribed before this if dog of November, 2011 A. D. Notary Public TM 0!4F P S&VANL4 NOWN seal Sherrie L. Owens, Notary Punic Lower Penton TWp., Dw*hln County Camr On Nov. 26, 2015 Me?eez, aeersnv? r[oN oR 2011-3796 CNN Term Fmwft Mae Vs Josinne Young Gary Young Atty: MwUm E. Von Rosenstlel ALL THAT CMMUN piece or parcel of land, with the buildings and improvements thereon erected, situate in Lower Allen Tmvn ip, Cumbeiland County, PennsyMmaad deaaited wmrdmg to a Map of Property of Leonard J. Goss to be conveyed to Thompson W. Young, said Map made by Gerrit J. Betz, Registered Surveyor, dated August 16, 1971, as follows, to wit; BEGINNING at an iron pipe on the Southerly side of Norman Road, at a comer of Lot #15, said point of beginning being _ measured along the said side of Norman Road the distance of eighty (80) feet from its point of intersection with the side of Kingsley Road; thence extending from said point of beginning and along the Southerly side of Norman Road on the arc of a circle curving to the left having a radius of five hundred twenty-one and forty-three one hundredths (521.43) feet the are distance of sixty (60) feet to a hub, at a comer of Lot #18; thence extending along Lot #18 and partly along Lot #19, the two following courses and distances, (1) South two degrees fifty-two minutes twenty seconds West, the distance of one hundred (100) feet to a hub, and (2) South forty-five degrees forty-three minutes ten seconds blast, dis distance of thirty-eight and sevesiteen one-hundtedtlAS (38.17) feet to a hub, at a corner of Lot #14; theme akn ft along Lot No. 14, North sixty-nine degrees font wits West, the distance of fifty-two and five one- hundredths (52.05) feet to an iron pipe, at a comer of Lot #15; thence extending along Lot No. 15, North ten degrees thirty-three minutes Emt, the distance of one hundred sixteen and sixty-nine one-hundredths (116.69) feet to the first mentioned point and place of beginning. BEING SHOWN as Lot #16, Block S, on Plan of Highland Park, in Plan Book 4, Page 98. BEING Designated as House #401 Norman Road IMPROVEMENTS: Residential dwelling Tax Parcel # 13.23.0545-294 TITLE TO SAID PREMISES IS VESTED IN Joanne Yomg by reason of the following: BEING THE SAME PREMISES WHICH Leonard J. Goss and Charlotte J. Cross, his wife by Deed dated 8/27/1971 aid recorded 9/2/1971 in the County of Cumberland in Record Book G-24, Page 580 conveyed unto Thompson W. Young and Joanne Young, his wife, in fee. AND THE SAID Thompson W. Young departed this life on J J whereby Title to said premises became vested in Joanne Young by right of survivorship.