Loading...
HomeMy WebLinkAbout11-4747MARTHA 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. JASON M. PERKEY AND ANGELA M. PERKEY 257 Pine Grove Road Gardners, PA 17324 DEFENDANTS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. it - 041 a,lv,[Terl? rnco zr,n z;o C-D 27694CFC-DD c_ c i 3 K5 rn? c: , -- :? o CD -in 3> 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 corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades 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 AGENCIAS 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 0 $ga.oo Po ATr/ e-r *6a8) e a?Gooa 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. §1692, 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. JASON M. PERKEY AND ANGELA M. PERKEY 257 Pine Grove Road Gardners, PA 17324 DEFENDANTS 27694CFC-DD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 11-S-795 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. Defendants, Jason M. Perkey and Angela M. Perkey are the mortgagors and real owners of premises 257 Pine Grove Road, Gardners, PA 17324, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Mortgage Electronic Registration Systems, Inc. as Nominee for First Horizon Home Loan on May 15, 2007, which mortgage is recorded on May 17, 2007 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1992, Page 2776, secured on premises 257 Pine Grove Road, Gardners, PA 17324 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 10, 2011 and recorded in February 25, 2011 the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 201106460. 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 October 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 $ 84,850.77 Interest from 9/1/2010 to 5/25/2011 at $16.56 per diem $ 4,405.85 Accrued late charges $ 89.94 Accrued Escrow deficit $ 3,565.95 Attorney's Fee (5% of unpaid Principal balance) $ 4,242.54 Property Inspections $ 75.00 Taxes and Insurance $ 31.62 Total $ 97,261.67 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 defendants, mortgagors and real owners 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 $97,261.67 , plus per diem interest at $16.56 from May 26, 2011 to the date of judgment plus costs thereon. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: rth E. Von Rosenstiel, Esqu' acqueline F. McNally, Esquire Attorneys for Plaintiff VERIFICATION Nancy Quinn hereby states that he/she is the =re Spedallst of IBM Lender Business Process Services, Inc., Servicing Agent for Fannie Mae ("Federal National Mortgage Association"), 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. Jason M. Perkey and Angela M. Perkey relating to the property located at 257 Pine Grove Road, Gardners, PA 17324 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 unworn falsification to authorities. / BY: Title: "um SMallst IBM Lender Business Process Services, Inc.as servicer for Fannie Mae ("Federal National Mortgage Association") Dated: /// LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate at Toland, in the Township of Dickinson aforesaid, being designated on a " Plan of Lots at Toland", entered for record in the Office for Recording of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan as Lot No. 1 with dimensions as marked on the Plan, together with the use of the common land between the lots and the public road, and the use of the well and pump on the common land, along with other lot owners. TAX PARCEL NUMBER: 08-38-2172-001 rV- - - logfa 0 PENNSYLVANIA PREPARED BY & WHEN RECORDED RETURN TO: LBPS 14523 SW AOLLUW MY #200 BEAVBRTON, OR 97045 ATTN comy C0303ERLAND PARCEL No. 08-38-2172-002 00 11t!1j1MV1W POOL NO. Lom No. (8302091 ) (LB01061 19M I1110111 ASSIGNMENT OF MORTGAGE KNOW ALL MEN BY THESE PRsSENTS, tharMIMMQS ArACMCWC 'I": 7c nUTXW SYB72W, 1W. SOLELY AS K1r UMM FOR FMWr BMZZICN MW LOW located at 1901 E VOGRFM ST. S1= C, ILLWI 2L, IL 61834 hereinafter re- ferred to as Assignor, for and in consideration of the stmt 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 nqu AB nygo 1Y, sm= 1000 ?. 3X 75254 hereinafter referred to as Assignee, at or before the delivery of these presents, the receipt of which is hereby acknowledged, has granted, bargained, sold, assigned, transferred, conveyed and set over unto said Assignee, its successors and assigns, all of its right, title and interest in and to that certain Mortgage dated the 15th day of MAY 2007 made and executed by JASON M. PERKEY, ANGELA M. PERKILY , mortgagor, to 1alZMDQA7TW 8Y81W 32C. SZKY AS AIINDW XV mw 74: nEff 7176 LOW CORECRA27EN Mortgagee, covering premises situated in the County CU148ERZJUW Commonwealth of Pennsylvania, more particularly described therein and coimonly known as: TORNS17IP OF DICKINSON PROPERTY ADDRESS: 257 PINE GROVZ RD., GARDNERS, PA 17324 Said Mortgage was duly recorded on the 17tH day of MAY 2007 in the office of the Register, Clerk of Recorder of Deeds of CU148ERLAND County, in Book 1992 at Page 2776 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 1UGM Y-MM TROUMM and AW/100----- , ( 89, 000.00 ) made and executed by mortgagor and payable to the order of the aforementioned Mortgagee. As previously recorded from to in Book from to in Book from to in Book at Page at Page (WMRI.PA.PH) at Page J=LB8040110AI.s.23811 on at Document No. on at Document No. on at Document No. Page I of 2 and and T ' ?? 1 Loan No. (8302091 ) (LB01061 TO HAVE AND TO HOLD the same unto said Assignee, its successors and assigns to its and their proper use and benefit forever. IN WITNESS WHEREOF, the said JAXIM M $JCTJ1=C -T-4 7RAT2M S S7M, ". SCUMY AS 1VC,M FM FM T RCRX dN JEW ZQM has caused these presents to be duly executed by its proper officer this 10th day of FEBRUARY 2011 but made effective MAY 1, 2010 SYS7?, nC. SOLMY AS I1MUM FCR FIRST JV0RZ QV JEW MW BY BY RLB CCA LEY VICE PRESIDENT STATE of IDAHO COUNTY of BONNEVILLE on FEBRUARY 10, 2011 , before me, M LISSA HIVELY personally appeared REBECCA HIGLEY and personally (mown to me (or proved to me on the basis of satisfactory evidence) to be the persons who execute the within instrument as VICE PRESIDENT and on behalf of MMUMM G' R8 ZR=Cff SEEM, ZW. SMMY AS fiCNI +IIsB FM and acknowledged to me that the Corporation executed it. MELISSA HIVELY f MELISSA HIVELY (Cdff SSION P. 07-28-14) NOTARY PUBLIC Notary Public STATE OF IDAHO -------------------------------------------------------------------------------- I DO HEREBY CERTIFY THAT THE PRECISE ADDRESS of THE ASSIGNEE RESIDENCE IS: FEDERAL_NATIOAVAL MORTGAGE ASSOCIATION -_--_--_-__------_ --------------- ------------------------------------------------------------------------------- ------------------------------------------------------------------------------- ------------------------------------------------------------------------------- _14221_DALLA$ PARICWAY?_SUITE 1000_- DALLAS-- -------- ---- ------ - ` - - -------------------- REBSC HIG LBPS VIOL PRESID 14523 SW MILLIKAN WAY, #200 BEAVERTON, OR 97005 ATTN P=5.002.00164.280 MW 100085200607813336 MEW BURRS: 1-888-679-6377 (NMRI.PA.2) C=a. 375. 0005 J=LB8040110AI. s.23811 Page 2 of 2 ALL THAT CERTAIN lot of ground situate at Toland, in the Township of Dickinson aforesaid, being designated on a " Plan of Lots at Toland", entered for record in the Office for Recording of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan as Lot No. 1 with dimensions as marked on the Plan, together with the use of the common land between the lots and the public road, and the use of the well and pump on the common land, along with other lot owners. TAX PARCEL NUMBER: 08-38-2172-001 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201106460 Recorded On 2/25/2011 At 11:09:15 AM * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 82784 User ID - KW * Mortgagor - PERKEY, JASON M * Mortgagee - FEDERAL NATIONAL MTG ASSOC * Customer - MARTHA VON ROSENSTIEL * FEES STATE WRIT TAX $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 O/D&S * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0wQMW III 1 Alk LBPS' November 30, 2010 Lender Business Process Services 14523 SW Milliken Way; Suite 200; Beaverton, OR 97005 Business Hours (Paclflc 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 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 11781 Phone PERKEY, JASON M 866.570.5277 257 PINE GROVE RD Fax GARDNERS, PA 17324 866.578.5277 Website www.lbps.com RE: Loan No.: 8302091 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE the the attached pages. 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 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. EXHIRIT__? this Notice with you when you meet with the Counseling Agency. hearing can call 717-780-1869). PERKEY, JASON M Loan No.: Page 2 November 30, 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: PERKEY, JASON M 257 PINE GROVE RD GARDNERS,PA FIRST HORIZON HOME LOAN CORPORATION Lender Business Process Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YO[J 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 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. VERKEY, JASON M Loan No.: Page 3 November 30, 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 Droyertis located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAPAPPLICATION AS SOONAS POSSIBLE. IF YOU HAVE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STAR TING A FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORCLOSURE ". YO U HA VE 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 WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766 NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. PERKEY, JASON M Loan No.: Page 4 November 30, 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: 257 PINE GROVE RD GARDNERS 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: October 2010, November 2010 Past Due Installments: Totals Principal $192.19 Interest 1,007.03 Escrow Installment 911.18 $2,110.40 Prior Servicer Other Open Charges: Charges LBPS Charges Late Charges $0.00 $59.96 $59.96 $59.96 Less Suspense (Balance) $0.00 TOTAL $2,170.36 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 2,170.36, 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 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. PERKEY, JASON M Loan No.: Page 5 November 30, 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 12aying the total amount then past due, plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately eight (8) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL OV/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. PERKEY, JASON M Loan No.: Page 6 November 30, 2010 HOW TO CONTACT THE SERVICER: Name of Servicer: Lender Business Process Services, Inc. Address: PO Box 4121; Beaverton, OR 97076-4121 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Person(s): Holli Jennings or David Solomon E-Mail Address: ExternalCommunications@Ibps.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of Consumer Credit Counseling Agencies serving your county. (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE W W W.COLORADOATTORNEYGENERAL OV/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. PERKEY, JASON M Loan No.: Page 7 November 30, 2010 Sincerely, Lender Business Process Services Enclosures: PHFA list of HEMAP-approved agencies, How to Avoid Foreclosure THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. HEMAP Consumer Credit Counseling Agencies Report last updated: 7!3012010 857:41 AM CUMBERLAND County American Credit Counseling institute! 175 Strafford Avenue CCCS of Wesiern PA Suite 1 2000 Linglestown Road Wayne, PA 19087 Harrisburg, PA 17102 610.971.2210 888.511.2227 888.212.6741 C,ornmimity Action Commission of Capital Ree;inn 1514 Derry Street Harrisburg, PA 17104 717.232.9757 "laarar.ath a 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Pro(3rarns Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342 2397 DAUPHIN County CC CCS of Western PA 2000 L inglestown Road Harrisburg, PA 17102 888 511 2227 Community Action Commission of Capital Regir;n 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PHFA 211 North Front Street Harrisburg. PA 17110 717,780 3940 800.342.2397 DELAWARE County Advo"=:tes, ter Financial Independence 1503 Wadsworth Ave Philadelphia, PA 19150 267-323-2696 Amesie.an Credit Counseling Institute 526-528 Dekaib Streei Norristown, PA 19401 6 10.97 1.2210 888.212.6741 Amcrlran F€r?anc!<al Couns-€inq Sn.r.<<c ? 1,,c- 1080 N. Delaware Avenue Suite 200 Philadelphia, PA 19125 267.228.7903 800.490.3039 American Financial Counseling Services ji)c. 405 West Germantown Pike Norristown. PA 19403 267.228.7903 °00.490.3039 Arr:erican Financial Counseling Sonvii-es In c. 175 Strafford Avenue Suite One 'riayne, PA 19087 267.228.7903 800.490.3039 American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 610.874.1484 APM fi00 W Diamond Street Philadelphia, PA 19122 215.235.6070 (267) 953-4615 Carrolf Park Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 215.877.1157 C CC'S of Delaware Halley 4400 North Reese Street Philadelphia, PA 19140 215.563.5665 CCCS of Delaware Malley 1003 East Lincoln Highway Suite 102 Coatesville. PA 19320 215.563.5665 CCCS of Delaware Valley 113 East Main Street 2nd Floor Norristown, PA 19401 215.563 5665 Page 8 of 21 /%k L B P S Lender Business Process Services 14523 SW Milliken 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 November 30, 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 LI78I Phone PERKEY, ANGELA M 866.570.5277 257 PINE GROVE RD Fax GARDNERS, PA 17324 866.578.5277 Website www.lbps.com RE: Loan No.: 8302091 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE the attached naees. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. (Continued) 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 OV/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 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). PERKEY, ANGELA M Loan No.: Page 2 November 30, 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 NOTIFICACI6N 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: PERKEY, ANGELA M 257 PINE GROVE RD GARDNERS,PA FIRST HORIZON HOME LOAN CORPORATION Lender Business Process Services HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. (Continued) 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. PERKEY, ANGELA M Loan No.: Page 3 November 30, 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 SOONAS POSSIBLE. IF YOU HAVE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORCLOSURE". YOU HAVE T H E RIGHT T O F I L E A H E M A P A P P L I C A T I O N E V E N B E Y O N D T H E S E T I M E PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL YAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL GOV/CA LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. PERKEY, ANGELA M Loan No.: Page 4 November 30, 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: 257 PINE GROVE RD GARDNERSPA 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: October 2010, November 2010 Past Due Installments: Principal Interest Escrow Installment Other Open Charges: Late Charges Less Suspense (Balance) TOTAL Prior Servicer Charges $0.00 $ 59.96 Totals $192.19 1,007.03 911.18 $2,110.40 $59.96 $59.96 $0.00 $2,170.36 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 2,170.36, 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 pgyable 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 COLLET 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. LBPS Charges PERKEY, ANGELA M Loan No.: Page 5 November 30, 2010 IF YOU DO NOT CIVRE 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 Sheriffs Sale of the mortgaged property could be held would be approximately eight (8) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. (Continued) THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE 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. PERKEY, ANGELA M Loan No.: Page 6 November 30, 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 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. PERKEY, ANGELA M Loan No.: Page 7 November 30, 2010 Sincerely, Lender Business Process Services Enclosures: PHFA list of HEMAP-approved agencies, How to Avoid Foreclosure THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW COLORADOATTORNEYGENERAL.GOV/CA. LBPS maintains a local office at 600 Seventeenth Street, Suite 800 North Tower, Denver, CO 80202. The office's phone number is 866.436.4766. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. IBM Lender Business Process Services, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. HEMAP Consumer Credit Counseling Agencies Report last updated: 713012010 8:57:41 AM CUMBERLAND County 4m,'?rican Credit Counseling lr+4titute 175 Strafford Avenue CCCS c,jWestern €'A Suite': 2G00 Linglestotirn Road Wayne, PA 19087 Harrisburg. PA 17102 610.971.2210 888.511.2227 388.212.6741 Community Action Commission Of Ca itM ReY iOn rN.,'r r'i, ^zf Cokenselifig Seraicerta. 1514 Derry Street 1080 N. Delaware Avenue Harrisburg. PA 17104 Suite 200 717.232.9757 Philadelphia, PA 19125 267.228.7903 ktaraalatha 800.490.3039 43 Philadelphia Avenue Wavnesboro. PA 17268 Americana Financial Courisr.ling Setvices irac, 717.762.3285 405 West Germantown Pike Norristown, PA 19403 PA Interfaith Community Programs lnc 267.228.7903 40 E High Street 800.490.3039 Gettysburg, PA 17325 717 334.1518 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 Red Cross of Chester DAUPHIN County 1729 Edgemont Avenue CCCS e1 Western PA Chester, PA 19013 2000 Linglestown Road 610.874.1484 Harrisburg, PA 17102 APM 888.5112227 600 W Diamond Street Conamunlty Action Commission of Capital Region Philadelphia, PA 19122 1514 Derry Street 215.235.6070 Harrisburg, PA 17104 (267j 953-4615 717.232.9757 Carroll Park Comniun"sty Council. lnc. PNFA 5218 Master Street 211 North Front Street Philadelphia, PA 19131 Harrisbura, PA 17110 215.877.1157 7177803940 Gr C5 of Delaware Valley 800.342 2397 4400 North Reese Street DELAWARE County Philadelphia, PA 19140 215.563.5665 Advocates 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 nraanrican Credit Counseling lnstitute 215.563.5665 526-528 Dekaib Street Norristown. PA 19401 CCCS of Deixw are Malley 610.971.2210 113 East Main Street 888.212 674' 2nd Floor Norristown. PA 19401 215-563.5665 Page 8 of 21 SHERIFF'S OFFICE OF CUMBERLAND COUNTY i.... Ronny R Anderson? Sheriff -? -~ Jody S Smith V?tt?ti+' at ?rnnf?rr?D?fd _' Chief Deputy Richard W Stewart a Solicitor nF?, -r Fannie Mae vs. Jason M. Perkey (et al.) Case Number 2011-4747 SHERIFF'S RETURN OF SERVICE 06/08/2011 03:41 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 8, 2011 at 1541 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Angela M. Perkey, by making known unto Linda Goodling, Aunt of Defendant at 257 Pine Grove Road, Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to her personally the said true and correct copy of the BARRI D UTY 06/14/2011 07:56 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2011 at 1956 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jason M. Perkey, by making known unto himself personally, at 1 S. Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and cprrect copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $58.00 June 15, 2011 SO ANSWERS, ) 4RONR ANDERSON, SHERIFF (c) Gbur±ySulte Sheriff . Teievo<uft. Inc. #27694CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff V. JASON M. PERKEY AND ANGELA M. PERKEY Defendant(s) ' y F - I rT NO. 11-4747 U)v co C)C:) ?s . ?p dC7 ` CD ?:. PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Jason M. Perkey and Angela M. Perkey for want of an answer. (X) Assess Damages as Follows Debt $ 97,261.67 Interest from 5/26/11 to 7/26/11 At $16.56 per diem $ 1,026.72 Total $ 98,288.39 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: Qom,}. $ l4. oo Eel A.N? rth Von Rosenstiel, Esquir coal 1J7X7 acqueline F. McNally, Esquire Q# a V ?yy Attorneys for Plaintiff NAu M& WA This d k day of 2011 judgment is entered in favor of the Plaintiff and against Defendant(s), Jason M. Perkey and Angela M. Per ey by default for want of an ;er and damages assessed at the sum of $98,288.39 as per the above ificaX. '.D /I ProthorV%AQoCMiTcertTh- Wunty 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. JASON M. PERKEY AND ANGELA M. PERKEY 257 Pine Grove Road Gardners, PA 17324 DEFENDANT TO: Jason M. Perkey 257 Pine Grove Road Gardners, PA 17324 #27694CTD - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-4747 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 ROSENSTWL, P.C. f r ay: Martha E. Von Rosens , squii Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: July 5, 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. JASON M. PERKEY AND ANGELA M. PERKEY 257 Pine Grove Road Gardners, PA 17324 DEFENDANT TO: Angela M. Perkey 257 Pine Grove Road. Gardners, PA 17324 427694CTD - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11.4747 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. Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: July 5. 2011 MARTHA E. VON ROSENSTIEL, P.C. 427694CTD - DD Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 1901.8 (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 SERV ICER 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 JASON M. PERKEY 257 Pine Grove Road Gardners, PA 17324 PLAINTIFF V. AND ANGELA M. PERKEY DEFENDANT Case No: 11-4747 TO: Jason M. Perkey I S. Baltimore Ave Mount Holly Springs, PA 17065 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 717-249-3 166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENSTIEL' P.C. Martha E. Von Rosenstiel, sqi Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: July 5, 2011 #27694CFJ-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. JASON M. PERKEY AND ANGELA M. PERKEY Defendant(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 11-4747 NON MILITARY AFFIDAVIT F Esquire hereby certifies that: I . I am the attorney for the plaintiff herein. 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. BY: on Rosenstiel, Esquir JtJa WV uel ine F. McNally, Esquire orneys ys for Plaintiff Dated: July 26, 2011 l..F oinv 1 ?i.c'+v OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Jason M. Perkey 257 Pine Grove Road Gardners, PA17324 FANNIE MAE ("FEDERAL NATIONAL COURT OF COMMON PLEAS MORTGAGE ASSOCIATION") CUMBERLAND COUNTY PLAINTIFF VS. JASON M. PERKEY AND ANGELA,.. NO: 11-4747 PERKEY ;..::,... DEFENDANT(S) Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are h by fie a Judgme has been entered against you in the above proceeding as indicated belo in th o iof $98,288.39 on July 26, 2011. avi D. Prot otary ? Judgment by Default Money Judgment Judgment in Replevin F1 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. ;;;jjjGGGq ; ? Olio, ,? a„"rt '::#.. why . ?c;w..?"MA .ed+' ViN ?y OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Angela M. Perkey 257 Pine Grove Road Gardners, PA 17324 FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") PLAINTIFF VS. JASON M. PERKEY AND ANGELA M PERKEY DEFENDANT(S) David D. Buell, Prothonotary COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-4747 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you jhb y 'fie t a Judgm has been entered against you in the above proceeding as indicaten t m of $98,288.3 9 on July 26, 2011. DavPy 0 Judgment by Default Money Judgment Judgment in Replevin F1 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. ?_,.r-:= ;`? '?? '? oi« r ''air OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 JASON M.PERKEY 1 S. Baltimore Ave Mount Holly Springs, PA 17065 FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") PLAINTIFF VS. JASON M. PERKEY AND ANGELA M PERKEY DEFENDANT(S) David D. Buell, Prothonotary COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-4747 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are her y no ed Judgme has been entered against you in the above proceeding as indicated belo nth a o of $98,288.39 on July 26, 2011. Davi Prothonotary FRI Judgment by Default F1 Money Judgment 1-1 Judgment in Replevin Judgment for Possession ? Judgment on Award of Arbitration Judgment on Court Findings If you have any questionssccooncing this notice, please call: Attorney - E. erpy , Esquire at this telephone number: 610-328-2887. ,,:. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4747 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 JASON M. PERKEY AND ANGELA M. PERKEY (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: $98,288.39 L.L.: $.50 Interest from 7/27/11 to 12/7/11 at 6% - $2,165.44 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $190.50 Other Costs: Plaintiff Paid: Date: 7/28/11 David D. uell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MARTHA E. VON ROSENSTIEL, ESQUIRE Address: MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 27694CWE-DN Commonwealth of Pennsylvania COUNTY OF CUMBERLAND FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") V. JASON M. PERKEY AND ANGELA M. PERKEY Praecipe for Writ TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 7/27/2011 to 12/7/2011 At6% TOTAL* *Plus costs to be endorsed COURT OF COMMON PLEAS DOCKET NO. 11-4747 ATTORNEY I.D. # of Execution ? O n t-? $ 98,288.39 $ 2,165.44 $ 100,453.83 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: C? ? AfieP?Fsquir h Von Rose----- , J cqueline F. McNally, Esquire Attorneys for Plaintiff PREM: 257 Pine Grove Road, Gardners, PA 17324 CLUA PA a lks$. oo eaF q a. 60 < < 14.dpuIi a.so ??u ?7ai7 e# aoL&&p _I SS W ? o? Q z o? w W O ? ? U O? zz z 0 zz Qv WO w? wd dw ?Q Z ? w ? W W C1. W z ?d z W w a, O Q C. O V i'C N w? 4-o o O ? a? ?. an 0 cd a? c? 4 ? M M 0c N 00 N O a\ 6/9 6S a? 0 o 7? ? o o d o M N ? M N M O ? ,o ?z w •? a 00 o ?.'Q1 0 w ?° d cv W p N GtidIva`?° #27694-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. COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 11-4747 JASON M. PERKEY AND ANGELA M. PERKEY Defendant(s) LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate at Toland, in the Township of Dickinson aforesaid, being designated on a " Plan of Lots at Toland", entered for record in the Office for Recording of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan as Lot No. 1 with dimensions as marked on the Plan, together with the use of the common land between the lots and the public road, and the use of the well and pump on the common land, along with other lot owners. TAX PARCEL NUMBER: 08-38-2172-001 IMPROVEMENTS: Residential dwelling TITLE TO SAID PREMISES IS VESTED IN Jason M. Perkey and Angela M. Perkey, husband and wife, as tenants by the entireties by Deed from James J. Collins and Dawn E. Collins, husband and wife dated 5/15/2007 and recorded 5/17/2007 in Record Book 280, Page 151. 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. #27694CAM - DN C _ f7 M COURT OF COMMON PLEAS CUMBERLAND COUNTY C--) - e5 NO: 11-4747 JASON M. PERKEY AND ANGELA M. PERKEY Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 IN vw F. fWatiholy , 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 257 Pine Grove Road, Gardners, PA 17324: 1. Name and address of owners(s) or reputed owner(s) Jason M. Perkey 257 Pine Grove Road Gardners, PA 17324 Angela M. Perkey 257 Pine Grove Road Gardners, PA 17324 2. Name and address of defendant(s) in the judgment: Jason M. Perkey 257 Pine Grove Road Gardners, PA 17324 Angela M. Perkey 257 Pine Grove Road Gardners, PA 17324 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Old Dominion Freight Line, Inc. 500 Old Dominion Way Thomasville, NC 27360 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 I Courthouse Square k , Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. CIO 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, 1 lth 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 257 Pine Grove Road Gardners, PA 17324 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: M rtE. Von Rosenstiel, Esqui Ja queline F. McNally, Esquire orneys for Plaintiff Dated: July 25, 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") Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. JASON M. PERKEY AND ANGELA M. No: 11-4747 PERKEY Defendant(s) CERTIFICATE TO THE SHERIFF #27694-CWE-DN cY c'. .. -K czr rn ?-- - T., co E Y rr .C© o zip ?. CD-T1 = 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 0 Commercial 0 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: rart . Von Rosenstiel, Esquire J cqueline F. McNally, Esquire Attorneys for Plaintiff 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. Jason M. Perkey and Angela M. Perkey 257 Pine Grove Road Gardners, PA 17324 Defendants COURT OF COMMON PLEAS CUMBERLANDCOUNTY No: 11-4747 AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE " co r =? 3 C- CID 0, ?p C-0 jacgueline F- k4C"ly , 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: Jason M. Perkey 257 Pine Grove Road Gardners, PA 17324 Angela M. Perkey 257 Pine Grove Road Gardners, PA 17324 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: . Von Rosenstiel, Esquir queline F. McNally, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. 1TIi0l`ln1An Martha E. Von Rosenstiel, Esquire /No. 52634011 JUL 28 AM 11 ? ?') Jacqueline F. McNally, Esquire / No. 201332 CUMBERLAND COUNTY 649 South Avenue, Suite 7 °ENNsYLVANIA Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FANNIE MAE ("FEDERAL COURT OF COMMON PLEAS NATIONAL MORTGAGE CUMBERLAND COUNTY ASSOCIATION") Plaintiff VS. : No: 11-4747 JASON M. PERKEY AND ANGELA M. PERKEY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: 27694CAM-DN The real estate and improvements, if any, located at and known as 257 Pine Grove Road Gardners, PA 17324 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. 11-4747 in the Court of Common Pleas of Cumberland County by Fannie Mae ("Federal National Mortgage Association"), Plaintiff against Jason M. Perkey and Angela M. Perkey, Defendant(s). Judgment was entered on July 26, 2011 in the amount of $98,288.39. The property was seized and taken in execution as the property of Jason M. Perkey and Angela M. Perkey. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN lot of ground situate at Toland, in the Township of Dickinson aforesaid, being designated on a " Plan of Lots at Toland", entered for record in the Office for Recording of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan as Lot No. 1 with dimensions as marked on the Plan, together with the use of the common land between the lots and the public road, and the use of the well and pump on the common land, along with other lot owners. TAX PARCEL NUMBER: 08-38-2172-001 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. 11-4747. 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 s 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. AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 JASON M. PERKEY AND ANGELA M. PERKEY Defendant(s) 427694CAM - DN .1 -'5-GFF 1Cc. ROTHONOTARi' 2011 AUG -5? Z= 11 (CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-4747 ESQUIRE, attorney for the Plaintiff in the +JeagWine F. McWly above action, hereby verifies that on 2 - q - 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: ai ha . Von Rosenstiel, Esquir Jac eline F. McNally, Esquire ttorneys for Plaintiff (.f ? For Accountable Mail ` Ffi. r p0"j O CO 00 v O) Cn A W N -? r m d d 3 C& z C (D N Cr O N -4 Cm 3n ?D m m CD ? rn CD ? D -0z-a ?Cn0 so 2vao'v G?N0 c' 2?0 2?>w-0 c m ? D -U C?C?D ? ? ? 0 0 0 0 -0 ? ? 033 3 0 0 C) O v cD (D 00 w Q c v m , Om > a) 0 7 = 2)n O d ? O N O(nX OO v O c c 3 0) nc 0 3 Z ?? X 0 C 7 _ Cr N w Oo 0Wc (D ?? M • ? • ?0ocn? 0 ° ? ? Q? ? ?Co >m 0 CD Cn CD N Q CD y c Cr CD =? O 3 > - < 13. -0-7 ?Xo"° N - n0 inm p) CX3 Nj a xmoa N - =r >C C Cmjv ':2 ;z ox-0S2.'< O N? O••N• (7 C-) ? O j m -0 0 j m p ° D=r DD.. m SD p o' 00? m ??? 0)a - -?n3 D?, ? (D - 3 ? -i ? N;o ' D D m a 0 ?m y< -2 D Z? .? won . CD Drn? ° Do Co < v?p DCn- vao?o >"w 3 p m c ?CnC v m DC X = •43 > C m Dm r o m cno Oa oc f Z N no N O ?. wa v C O ?m Co W O+ v V a' -0 0 O m C) p C 3 - m o v (D W •?' n v O 0 o c e to N' o-0 c c ? 0 y CofD X 3 y v C f0 W< s 0) N Z7 . N O to A N - O A - w -4 Cn > N 0 W 0) m CD ? " - m N 0 H. 0 C CD W m (N W 0 m m y D C O (A N 00 `<< r Co N< n' m< CD ? O . A OD - 21 C< S `< m A y O G) y Q- .. V m m x m CD :3 < CD _ m j;? D 1 . . (D CC X (n m 1 IZ w V/ N y C ?p N D W C 0 CD .O-. O CD O 7 Cn m C y m y m -1 C 3 ? m r 3 I a f7 o ? ,- C?G(S y m00 m ;3. 0 C (a 3 cc CD ° m ' 0 c? Co n CD ?? Q X .0.. 60 K m \? -J35 m oCD i c u m N n C n _ C7 = Q v CD N _ .Tl CD mC d NCD a ?• X CD CL 3 (D m m m 0 C = c 3 3 5' Vim- CD D 3 co 02o' n (D 57 ??mo o c m w < 0 0 m c n) o m N 0 C No 0 w o m y -w 3. W a N _ C ? C N O _ C d n n d O ( Op 2 O O ' j C) y > 7 Hg ? N pn, O? CD CL CL 0 003 -2 OO (D 1-0 j n W p • Om '•1:C O 0 2) 7 CL T ( . -o S' m Q ` m = c O O 3 CD m o o (D m 2. 0 0 0 n °-) - m m - 3 (p 3 . m N oin m e» C CD CT m C O 3 m o . ?v C) m CD ' v y N N PLAINTIFF: Fannie Mae ("Federal National Mortgage Association") DEFENDAN'r Jason M. Perkey and Angela M. Perkey AFFIDAVIT OF SERVICE FILED-OFFiC"E OF THE pROTHON COURT OF CONIMON.PLE:AS 201 I SEC 2 5 A i 1 1' 0 9 Cumberland COUNTY COURTNO. 11-4747 ICUMBERLAND COON PENNSYLVANIA 27694-DN SERVE UPON: Angela M. Perkey TYPE OF ACTION 257 Pine Grove Road Gardners, PA 17324 XX WRIT OF EXECUTION and Notice of Sheriff's Sale Gardners, INSTRUCTIONS: please serve defendant personally Sheriffs Sale Date: 12/7/2011 or adult in charge of premises A IIII SERVED L Served and made known to (??( (,? M, Defendant, on the Q', day of ?t?fsus? 204( , at Q k, A . M. at NE uIE . ?p/dPRS Commonwealth of Pennsylvania, in the manner described elow: b Defendant personally served. Manager/Clerk of place of lodging in which Adult family member with whom Defendant resides. Defendant resides. Relationship is Agent or person in charge of Defendant's office Adult in charge of Defendant's residence who or usual place of business. j refused Other j to give namefrelationshi --11I Description: Age 04 Height_5S_ Weight t ?o I) Race W Sex Other I, ? tA-LD AA4 iCr , 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 Sheriff's Sale issued in the captioned case on the date and at the address indicated above. Sworn to and subscri before me this day of 5 20 Notary: By: NOT SE On the y o 20_, at o'clock ?. M., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Time of Attempt: Date of Attempt: Result: KIMBERLY C'j ( PUBLIC W gfpfFOF?E ARCH"i,2013 MY COMM1 sworn to ana suoscnoea before me this day of 200_ Notary: BY ATTORNEY Martha E. Von Rosenstiei, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 15 r PLAINTIFF: Fannie Mae ("Federal National Mortgage Association") DEFENDANT Jason M. Perkey and Angela M. Perkey SERVE UPON AFFIDAVIT OF SERVICE FILED-OFFICE OF THE PR i l-ICNG Cot1RTOFCOMMON IlsSEf 26 AM!1: I C7 Cumberland Cot'NTY COURT NO. 114747 CUMBERLAND COU f" PENNSYLVAW JASON M. PERKEY TYPE OF ACTION 1 S. Baltimore Ave XX WRIT OF EXECUTION and Notice of Sheriff's Sale Mount Hotly Springs, PA 17065 SPECIAL INSTRUCTIONS: please serve defendant personally Sheriffs Sale Date:121712011 or adult in charge of premises SERVED served and made known to ?/t?N M r FI'? Defendant on the 10 day of described below: Defendant persona served. Manager/Clerk of place of lodging in which Adult family member with whom Defendant resides. Defendant resides. Relationship is Agent or person in charge of Defendant's office Adult in charge of Defendant's residence wbo or usual place of business. refused Other 2 27694-DN _LA Description: Age Height! Weight 40 Race Sex Other l 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 Sheriff's Sate issued in the captioned case on the date and t the address indicated above. Moved Unknown No Answer Vacant NOT SE On the 20at o'clock,. M., Defendant NOT FOUND because: Sworn and subscribe before me thi day of Notary: By' -q?rv? Date of Attempt. 6mnm to and of before me this day of 200_. Notary: By. ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 ?--- ,I ,y CURV NOTARY PW LIC " 051 STATE OF{pIRES MARCk1 "fix 2013 ? COMMISS?ON E' PLAINTIFF: Fannie Mae ("Federal National Mortgage Association') DEFENDANT Jason M. Perkey and Angela M. Perkey SERVE UPON: Jason M. Perkey 257 Pine Grove Road Gardners, PA 17324 AFFIDAVIT OF SERVICE COL!R"f OF CONIMON P[.iiAS Cumberland COUNTY COURT NO. 11-4747 FILED-FIr' ?' 1LED-0 iCE 27694-DN OF THE PROT!-! NOTAR`.` 2011 SEP 26 Ate I1: 09 CUMBERLAND COUNTY' PENNSYLVANIA TYPE OF ACTION XX WRIT OF EXECUTION and Notice of Sheriffs Sale SPECIAL INSTRUCTIONS: please serve defendant personally Sheriffs Safe Date:12/7/2011 or adult in charge of premises SERVED Defendant, on the Served and made known to Comoro o clock, M., af- t persona th re ManagedClerk of place of lodging in wnicn Defendant resides. Agent or person in charge of Defendant's office or usual place of business. Other Relationship is Adult in Char. a of Defendant's residence who refused to dive namelrelationship Sex Other Description: Age Height Wei9ht Race a competent adult, being duly sworn according to law. depose and state that I personally handed a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriff's Sale to issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of 20 Notary: By: NOT Sr.RVLiD On the q4-_t- day of ?Z-- 20 at A :00 o'clock A. M- Defendant NOT FOUND because: Unknown No Answer Vacant Moved Time of Attempt: Date of Attempt Sworn to and subscribes before me this d of By: Notary: ATTORNEY Martha E. Von Rosenstiei, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 STATE PUBLIC v RFS 013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r E ?ix' + t ': , Sheriff r;r THE hl`! ,,11NIOTI ,?ptt`titlof 4uiuG?r?aXl? Jody S Smith ??JAIN ' 7 Chief Deputy Richard W Stewart "Al CUMBERl ANA COUNTY Solicitor F ?cl T?,` PENNSYLVANIA Fannie Mae Case Number vs. 2011-4747 Jason M. Perkey (et al.) SHERIFF'S RETURN OF SERVICE 10/10/2011 02:37 PM - Deputy Noah Cline, 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 257 Pine Grove Road, Gardners, PA 17324, 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 Fannie Mae ("Federa National Mortgage Association"), P.O. Box 650043, Dallas TX 75265-0043. Fannie Mae being the buyer it this execution, paid to the Sheriff the sum of $803.61 01/10/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law states this writ is returned STAYED. SHERIFF COST: $803.61 January 10, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 0 -00 ",d, 6)e, so ',Gl Cckniy5..11(f J:^: n f. Tp!Ppgo1(. r,;;. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 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 28 day of July, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 4747, at the suit of Fannie Mae against Jason M. Perkey and Angela M. Perkey is duly recorded as Instrument Number 201200885. IN TESTIMONY WHEREOF, I have hereunto set my hand leo- an cal of said office this day of A.D. f , x:'/ of Deeds Recafderdgp&rQnibedri 0=t%ale.Phi My Corm" n Free fe F0llon * dJin 2014