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Home My WebLink About05-5180 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 . SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagors and Real Owners 5977 Eberly Drive Mechanicsburg, P A 17055 Defendants Term No. 6S- $' I f~ ,.', ,.. AG'T' 'ION' MOATGAGE vI'\! IL: t"'I. . ~O~~ClO8U~e: NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMAND A Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A F A VO~ DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES :DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE US TED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI US TED NO TIENE UN ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either ofthe following numbers: 717-243- 9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SPS-0331. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. plaintiff is US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, 1270 Northland Drive, Ste. 200, Mendota Heights, MN 55120. 2. The names and addresses of the Defendants are KIRK A. PERKINS, 6030 Creekview Road, Mechanicsburg, P A 17055 and LORIEN A. PERKINS FKA LORIAN A. STROHL, 6030 Creekview Road, Mechanicsburg, P A 17055, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On June 15, 1999 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to EQUICREDIT CORPORATION OF PA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1551, Page 171. The mortgage has been assigned to: US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 by assignment of Mortgage, which assignment is lodged for recording. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 10 19(9); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for August 01, 2004 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 07/01/2004 through 09/30/2005 at 9.3000% Per Diem interest rate at $29.81 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 08/01/2004 to 09/3012005 Monthly late charge amount at $40.76 Costs of suit and Title Search Escrow Fees Recoverable Balance $117,005.93 $13,623.16 $5,850.30 $570.63 $900.00 $1,127.00 $77.06 $10.10 $139,164.18 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity ofthe action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $139, 164.18, together with interest at the rate of $29.81, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure oft~ortgage and Sheriffs Sale of the Property. , 1 '\!, tv' By: G" t! '~ GOLDBECK l}icC FERTY & McKEEVER By: JOSEPH Af90LlmECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: 9 -.00 /0 ,S- Brodowsky-lines . ~)"r>)ntro! Officer -'-... ------- p,xfti6it }t - ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: GINNING AT A POINT AT LOW WATER MARK ON THE WEST SIDE OF CONODOGUINE BE LANDS NOW OR FORMERLY OF CLYDE WRIGHTSTONE AND WIFE, ~~~~~ ~~I~O~~~TOis ALSO THREE HUNDRED(300) FEET MEASURED t~N~ ~~R~~~Y DIRECTION ALONG THE LOW WATER MARK OF SAID CREEK FROM THE OF' MARK R. BASEHORE; THENCE CONTINUING A~ONG THE LOW WATER MARK OF SAID CREEK IN A NORTHERLY DIRECTION, A DISTANCE OF ONE HUNDRED (100) FEET TO A POINT ON TH~ SAME, 'AT CORNER OF LANDS OF ELLSWORTHP. MURPHY AND DOROTHY A. MURPHY, HIS WIFE, NORTH 750 45' WEST A'DISTANCE10F TWO HUNDRED THIRTY-FIVE (235) FEET" MORE OR LESS, TO A STAKE AT LINE- OF OTHER LANDS NOW OR FORMERLY OF RAYMOND BRACKBILL AND MARGARET E. BRACKBILL, HIS WIFE; THENCE ALONG THE SAME IN A SOUTHERLY DIRECTION ALONG A LINE PARALLEL.WITH THE SAID LOW WATER MARK OF SAID CREEK, A DISTANCE OF NINETY (90) FEET TO A STAKE AT THE CORNER OF LANDS NOW OR FORMERLY OF CLYDE WRIGHTSTONE AND WIFE, AFORESAID; THENCE ALONG SAID LANDS NOW OR FORMERLY OF CLYDE WRIGHTSTONE AND WIFE, SOUTH 720 45' EAST, A DISTANCE OF TWO HUNDRED THIRTY-FIVE (235) FEET MORE ORLESS, TO A POINT AT THE LOW WATER MARK OF SAID CONODOGUINET CREEK, AT THE POINT AND PLACE OF BEGINNING. ADDRESS: 5977 EBERLY DR; MECHANICSBURG, PA 17055 NO.: 10-18-1321-007 TAX MAP OR PARCEL ID !; . i,....jl: CBtlii6it CJ3 S 'D SSELECT }. l'ori:(Plio . . SE~VICING. iN:. P.O. Box 551170 Jacksonville, FL 32255-1170 7182 6389 3060 0641 9265 July 20, 2005 LORIEN PERKINS KIRK PERKINS 5977 EBERLY DRIVE MECHANICSBURG, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!:a!!:e on vour home is in default. and the lender intends to foreclose. Snecific information about tbe nature of the default is nrovided in the attached na!!:es. The HOMEOWNER S MORTGAGE ASSISTANCE PROGRAM illEMAP) mav be able to heln to save vour home. This Notice exnlains how the nro!!:ram works. To see if HEMAP can heln, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselin!!: A!!:encv. The name, address and phone number of Consumer Credit Counselin!!: A!!:encies servin!!: vour County are listed at the end of this Notice. If vou have any Questions. yoU may call the Pennsylvania Housin!!: Finance A!!:encv toll-free at (800) 342-2397. Persons with imnaired heann!!: can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIT AMENTE LLAMANDO EST A AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PRESTAMO POR EL PROBRAMA LLAMADO HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Homeowner'sName: Property Address: LORIEN PERKINS, KIRK PERKINS 5977 EBERLY DRIVE MECHANICSBURG PA 17055-0000 8062043727 Loan Acct No.: Original Lender Current Lender / Servicer: Select Portfolio Servicing, Inc. EF04VRINCPI3-0S SPSISELf;CT . PorI lio SEit'VICING. in~ P.O. Box 551170 Jacksonville, FL 32255-1170 7182 6389 3060 0641 8183 July 20, 2005 LORIEN A PERKINS KIRK PERKINS 6030 CREEKVIEW ROAD MECHANICSBURG, PA 17055 29' ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!a!!e on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pa!!es. The HOMEOWNER S MORTGAGE ASSISTANCE PROGRAM (JIEMAP) may be able to help to save your home. This Notice exPlains how the pro!!ram works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TIDS NOTICE. Take this Notice with yoU when YOU meet with the Counselin!! A!!encv. The name. address and phone number of Consumer Credit Counselin!! A!!encies servin!! your County are listed at the end of this Notice. Ifvou have any Questions. YOU may call the Pennsylvania Housin!! Finance A!!ency toll-free at (800) 342-2397. Persons with imnaired heann!! can caD (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA. PUES AFECTA SU DERECHO A CONTINUAR VNIENDO EN SU CASA. SI NO COPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PRESTAMO POR EL PROBRAMA LLAMADO HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Homeowner'sName: Property Address: LORIEN A PERKINS, KIRK PERKINS 5977 EBERLY DRIVE MECHANICSBURG PA 17055-0000 8062043727 Loan Acct No.: Original Lender Current Lender / Servicer: Select Portfolio Servicing, Inc. EFQ4VRINCPI3-QS HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGmLE 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 ELIGmLE 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 ELIGmILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA 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 ofthis Notice. 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 THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF TillS NOTICE CALLED HOW TO CURE YOUR MORTGAGE DEFAULT EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date ofthis 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). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner s Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner s Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU M!lli! FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 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 COLLECf THE DEBT (Ifyru have filed bankruptcy yru can still apply for Emergancy Mortgage Assistance) LR064 EBOOOSfNCP/9-04 HOW TO CURE YOUR MORTGAGE DEF AUL T (Brin!!: it up to date) NATURE OF THE DEFAULT: The MORTGAGE debt held by the above lender on your property located at: 5977 EBERLY DRIVE MECHANICSBURG PA 17055-0000 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payment of $1,115.51 per month due from 08/01/2004 through 07/01/2005 payment (a total of 12 months): (Mortgage payment includes Escrow Payment of $0.00 per month): Accrued Late Charges Non-Sufficient Funds (NSF) / Return Check Fees Escrow Advances for Hazard Insurance, Real Estate Taxes and/or Municipal Liens: Other Advances (Property Preservation) : Funds on Account: ** Total Amount Due: $ 13,386.12 $ 122.28 $ 0.00 $ 935.64 $ 0.00 $ 0.00 $ 14,444.04 ** Funds on A ccount typically represent a parnal payment of principal and interest received that cannot be applied to the loan. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use ifnot applicable) 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 $14,444.04, 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: Select Portfolio Servicing, Inc. Remittance Processing P.O Box 9001710 Louisville, KY 40290-1710 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (do not use ifnot applicable) IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within TlllRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Iffull payment ofthe 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 FORECWSED UPON The mortgaged property will be sold by the Sheriff to pay offthe mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency befoce 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, iflegal proceedings are started against you, you will have to pay all reasonable attorneys 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, LR064 EBOOQT/NCPI9-04 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 mE DEFAULT PRIOR TO SHERIFF S SALE If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney s fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSmLE 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 six (6) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: PHONE NUMBER: FAX NUMBER: Contact Person: Select Portfolio Servicing, Inc. P.O. Box 65250 Salt Lake City, UT 84165-0250 1-800-934-2121 (801) 293-2600 Becca Smith NAME OF LENDER: Address: 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 Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE Under the terms of your mortgage and note, it may, or may not, be possible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney s fees and costs are paid prioc to or at the sale and that the other requirements of the mortgage are satisfied. You may find out at any time if your loan is assumable by contacting your lender as provided herein. 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. . HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . 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.) . ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY LR064 EBOOOUlNCPI9-Q4 Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, P A 17325 (717) 334-1518 CCCS of Western P A 2000 Linglestown Road Harrisburg, P A 17102 1-888-511-2227 Communi ty Action Commission of Captial Region 1514 Derry Street Harrisburg,PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, P A 17110 (717) 232-2207 Maranatha 43 PhiladelphiaA venue Waynesboro, P A 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, P A 17110 1-800-342-2397 APA041/NCP/2-05 -.------..... r<> c:::;;" 0 c:"';, ., C.f"1 i? Q .-\ -r C'> _l_ -r\ .-; fl\r; ~ ~ j I (G G\ ,J W I C) ~ -0 r. . ~ \., ~ _:...~ ...... I..P .. ;.:: ('-) ,en (', - <./l , , -l::\ 00 U\ .f'~ \). co.. ( " '0 .L .,. t v..... y-, c.,:' .< 'l ....!) (;) 'e ----------- SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05180 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS PERKINS KIRK A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT PERKINS LORI EN A FKA LORIAN A STROHL but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , PERKINS LORI EN A FKA LORIAN A STROHL 6030 CREEKVIEW ROAD MECHANICSBURG, PA 17055 DEFENDANT IS BELIEVED TO BE LIVING IN FLORIDA. Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 6.00 .00 5.00 10.00 .00 21.00 //'.;~;~ ~::>.!-e;~ /~. .-- .-::r _ .- %- C"'~-' C c:: / ." - , R. Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 10/17/2005 Sworn and subscribed to before me this I (JA day of tJ(N(",1~ ;;'O()1) A.D. ;Z '~- p~:~~7 SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05180 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS PERKINS KIRK A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT PERKINS LORI EN A FKA LORIAN A STROHL but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND as to the within named DEFENDANT , PERKINS LORI EN A FKA LORIAN A STROHL 5977 EBERLY DRIVE MECHANICSBURG, PA 17055 DEFENDANT DOES NOT LIVE AT 5977 EBERLY DRIVE Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 6.00 .00 5.00 10.00 .00 21.00 ^'~ ...". , ,?...~-?~.L/ , R. Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 10/17/2005 Sworn and subscribed to before me this day of t)(;D'i A ~ (?v$: Prothonota y \ I}\" tJCH I'" bv- SHERIFF'S RETURN ~ NOT FOUND CASE NO: 2005-05180 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS PERKINS KIRK A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT PERKINS KIRK A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT ~ MORT FORE , NOT FOUND , as to the within named DEFENDANT , PERKINS KIRK A 5977 EBERLY DRIVE MECHANICSBURG, PA 17055 DEFENDANT DOES NOT LIVE AT 5977 EBERLY DRIVE Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 9.60 5.00 10.00 .00 42.60 So answers: , --~~~:-/ - /;..--- ~;' ~-~r':-fft'" -:::) R. Thomas Kline Sheriff of Cumberland County , GOLDBECK MCCAFFERTY MCKEEVER 10/17/2005 Sworn and subscribed to before me 1'JO\j~W this Hot'"' day of JfJO 5' {J,1ltt-/!. Pr 0 a 6' SHERIFF'S RETURN - REGULAR CASE NO: 2005-05180 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS PERKINS KIRK A ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PERKINS KIRK A the DEFENDANT , at 1742:00 HOURS, on the 6th day of October 2005 at 6030 CREEKVIEW ROAD MECHANICSBURG, PA 17055 by handing to NANCY PERKINS, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 10.56 .00 10.00 .00 26.56 ~L~)^"?"// -r ~-;:::C-d'~-~'~-~ ~~ R. Thomas Kline 10/17/2005 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before By: q~~n?~f me this /(01;\, day of N,,~t~ {p 0 otar A.D. R. THOMAS KLINE Shehft Cum;,erland CO, Sherilci: ",\t ot ' UllrfJel"l ~~-o: . <tQ~ ~t' ~ <)i't,r; ~ .,..... fI'. No, 6508 p, 1/1 7f5~ 7r'j1.9 Oct, 7. i005 11:13AM eDWARD L SCHORPP Solicitor RONNY R. ANDERSON Chief Deputy OFFICE OF THE SHERIFF JODY S. SMmi Real Estate D.puly One Courthouse Square Cartisle, Pennsylvania 17013 To: Postmaster t1f)C-II/lMCf ~vP Agency Control No, Date: ;;)5'- 5/10 Address Information Request Pic.... furnish this agency with the new address, if available, for the following individual or verify whether the address given below is one at which mail for this individual is cunently being delivered. If the following address is a post office box, please furnish the streer address as reCorded on the box holder's application form. Name: Ltu'IE',AI A. If~$I'#f A!:i1.. L6U/I.A/11.57I,etJH(. Last Known Address: 5"<;17 ~;jQL-'7 i?~ I certifY the address information for this individual is required for the performance of this agency's official duties. -il-~ \- ",,\ (fbf., C 41.(Si~~YO~i&-) /J ;:1(//'1 ..f/iQu'Y (Title) D t1/) 'b/ (, For Post Omee Use Only ( ) Mail is delivered to address given. Agency Return Address ( ) Not Known at Address Given ( ) Moved, Lell No Forwarding Address ( ) No Such Address () Other (Specify) Postmark/Date StAmp - 0(// '. . AFFIDAVIT OF SERVICE ~/s - crS3) , UNITED STATES DISTRICT COURT Cumberland District of Pennsylvania os- - S'IPO Case Number: 05 5180 Plaintiff/Petitioner: US BANK NATIONAL ASSOCIA nON vs. Defendant/Respondent: KIRK A. PERKINS, et al For: Joseph A Goldbeck GOLDBECK. McCAFFERTY & McKEEVER Ste, 500 - Mellon Independence Ctr: 701 Market St: Philadelphia. PA Received by UNIVERSAL LAWYERS' SERVICE, INC. on the 9th day of November, 2005 at 5:00 pm to be selVed on LORIEN A. PERKINS f/kla LORIAN A. STROHL,1811 KNIGHTS CIRCLE, CANTONMENT, FL 32533 I, Tiffany Thornton, being duly sworn, depose and say that on the 11th day of November, 2005 at 7:05 pm, I: Individually Served the within named person with a true copy of this NOTICE and COMPLAINT with the date and hour endorsed thereon by me, pursuant to applicable state statutes, Additional Information pertaining to this Service: After she identified herself, Ms, Perkins stated she was not going to accept the documents, I informed her they were already selVed and left them on the foyer floor inside her door: I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process SelVer, in good standing, in the First Judicial Circuit in which the process was served. Under penalty of perjury, I declare I have read the foregoing document and the facts stated in it are true, NO NOTARY REQUIRED PUfSUANT TO F,S. 92.525(2). (:1:f21t0I'f - f./vh/t-e - ., /s / ~ / Y5 I J:y~ - L[JtjtY-{ -IStfuYl hcz'lr Subscribed and sworn to before me on the 12th day of November, 2005 by the affiant who is personally known to me.~ . ~ NOTARY PUBLIC , UNIVERSAL LAWYERS' SERVICE, INC. POBox 1180 Bay Shore, NY 11706 {6311866-6168 .,~i~,. Patricia J. Rollin.s Our Job Serial Number: 2005003147 /~4..~',. Commission #00187537 Ref 38289 ~;:, ';),;i Expires: Apr 12, 2007 ....'~J.tOff\.~"~ BondcdThru """"" Ii"uanlic Bonding CO.dn!iriQhtC 1992-2005 Database Services, Inc_ "Process Server's Toolbox V55j SHERIFF'S RETURN - REGULAR CASE,fI"l: 2005-05180 P . COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS PERKINS KIRK A ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PERKINS KIRK A the DEFENDANT , at 1742:00 HOURS, on the 6th day of October 2005 at 6030 CREEKVIEW ROAD MECHANICSBURG, PA 17055 by handing to NANCY PERKINS, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavi t Surcharge So Answers: 6.00 10.56 .00 10,00 ,00 26.56 ~9~--~~ R. Thomas Kline 10/17/2005 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before By: 6lb~~ Deputy Sne iff me this day of A.D. Prothonotary r-> '-,-;:,:::1 "':-',1 (;_""'1 s,"~ c:i l:;'~'" n \'-) C) .-' (.;':- :c_-..,., :.lr ~...." tT1 <;rI :-, ~.,,) '. ~',-; ~ ("') ;)IT' , ~'iJ ~~ co --------- - GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck. Jr. Attorney l.D, #16132 Suite 5000 Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION. AS TRUSTEE FOR TlIE HOt DERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. KIRK A, PERKINS LORtEN A. PERKINS FKA LORIAN A. STROllL (Mortgagor(s) alld Record oWller(s)) 5977 Fberly Drive Mechanicsburg, P A 17055 Defeodant(s) , IN TIlE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No, 05-5180 ORDER FOR JUDGMENT Please enter Judgment in favor of US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR TI IE HOLDERS OF THE EQCC I IOME EQUITY LOAN ASSET BACKED CERTIFICATES. SERIES 1999-3, and against KIRK A. PERKINS and LORIEN A. PERKINS FKA LORIAN A. STROHL for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $ I 41,581,83, Jo e oldbeck, Jr. A tOr1ey for Plaintiff I hereby certify that the above names are correct an that the precise residence address of the judgment creditor is US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR TilE 1I0LDERS OF TilE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive. Ste, 200 Mendota Heights. MN 55120 and that the name(s) and last known address(es) ,,1' the Defendant(s) is/arc KIRK A. PERKINS, 6030 Creekview Road Meehanicsburg, PA 17055 and LORIEN A. PERKINS FKA LORIAN A, STROIIL, 181 I Knights Circle Cantonment. FL 32533; cCAFFERTY & MeKEEVI'R Jos ph A. Goldbeck. Jr. for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 07../01/2004 through 12 \ 6!2005 Attorney's Fec at 5.0000% of principal balance Late Charges Costs of Suit and Title Search Escrow Fec-s Recoverable 8alance AND NOW, this ~ day of "lx.c.. ; $\\7.00593 515,91 R,S3 $5.RSO,30 $692,91 $900.00 $1,Inoo 571.06 $10,10 ($0,00) $14l.5R I.R3 , 2005 damages are assessed as above. Pro P othy , VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, KIRK A. PERKINS, is about unknown years of age, that Defendant's last known residence is 6030 Creekview Road, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: {J!ru!d , VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, LORI EN A. PERKINS FKA LORIAN A. STROHL, is about unknown years of age, that Defendant's last known residence is 1811 Knights Circle, Cantonment, FL 32533, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: !f!IU(7( In the Court of Common Pleas of Cumberland County US BANK NATIONAL ASSOCIATION, AS TRUSTEE E~)R THE HOLDERS or THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES. SERIES 1999-3 1270 Norlhland Drive, Sic, 200 Mendola Heights, MN 55 I 20 Plaintiff VS. KIRK A, PERKINS LORlIN A. PERKINS rK,\ LORI AN A. STROHL (\Iorfgag:or(s) and Record Owner(s)) 5q77 Eberly Drive l'vlccllallicsburg, i>i\ ! 7055 No, 05-5 I gO Dekndant(s) PRAECIPE FOR .JUDGMENT TIIIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE lISED FOR TIlE PURPOSE OF COLLECTING TIlE DEBT. Enter the Judgment in bvor of Plaintiff and against KIRK A, PERKINS and LORIEN\, PERKINS FKA LORI AN A. STROHL by default for Vo.[~U1t of an Ans\ver. Assess damages as follo\\'s: Debt $ 14 I ,5g Ig3 Interest - 07/01/2004 to 12/[(,/2005 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOllNTS ALLEGED TO m: DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM TIlE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against \\/homjudgmcJl! is to be entered and to his attorney of record, if any, after the detault occurred and at (east ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 AND NOW Df"' (",;)9 cJ.. L:{).S' , Judgment is entered in J~lvor of US BANK NATIONAL ASSOCL^, TION. AS TRUSTEE FOR TIlE HOLDERS OF THE EQCe HOME EQUITY LOAN ASSET BACKED CERTIIICATES, SERIES 1999-3 and against KIRK A. PERKINS and LORIEN A, PERKINS FKA l.ORIAN A. STROHL by default for V\Jnt of an An'mer ,md damages assessed Ul the sum of $l4\ Sf.: I g3 a~ per the aho'-c certiIication. ~~ ~, , onotary ,_--------~/ Rule of Civil Procedure No, 236 - Revised . IN TilE COURT OF COMMON PLEAS or Cumberland COUNTY, prNNSYLV ANIA CIVIL ACTION - LAW US BANK NATIONAL ASSOCIATION. AS TRUSTEE FOR THE HOLDERS or TilE EQCC 1l0ME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive. Ste, 200 t\knuota He\ght~. t\1:.J 55120 Plaintiff No. 05-51 RO vs. KIRK A. PERKINS LORIEN A PERKINS FKA LORIAN A STROHL (Mortgagors and Record Owner(s)) 5977 Eberly Drive Mcchanicsbur~, P A 17055 Dcfendanl(s) THIS LAW HRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWEn TO OlR CLlE:\T. ANY I"FOR~L\TlON OBT,\INED FROM YOU WILL BE liSEn FOR TilE PlIRPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. i:;V~:effi., By . 7J --- f If you have any questions concerning the above. please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKcever Suite 5000 - Mellon lndepcndence Ccnter 70 I Market Street Philadelphia, P A 19106 215-627-1322 , SPS-0331 THIS LAW FIRM IS A DEBT COLLEt:TOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED :l<'ROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: December 2, 2005 TO: KIRK A. PERKINS 5977 Eberly Drive Mechanicsburg, PA 17055 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQillTYLOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL (Mortgagor(s) and Record Owner(s)) 5977 Eberly Drive Mechanicsburg, P A 17055 Term No. 05-5180 Defendant(s) TO: KIRK A. PERKINS 5977 Eberly Drive Mechanicsburg,PA t7055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITIl THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITIIIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITIlOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIlER IMPORTANT RIGIn'S. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITIl 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 EUGlBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES lNe 8 hvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlislc:,PA17013 G cCAFFERTl EVER B' h A Goldbeck, 1r,. Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 . , SPS-0331 tHIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT, DATE OF THIS NOTICE: December 2, 2005 TO: LORlEN A. PERKINS FKA LORIAN A. STROHL 5977 Eberly Drive Mechanicsburg, PA 17055 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN TIlE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL (Mortgagor(s) and Record Owner(s)) 5977 Eberly Drive Mechanicsburg, PA 17055 Term No~ 05-5180 DeJendant(s} TO: LORlEN A. PERKINS FICA LORIAN A. STROHL 5977 Eberly Drive Mechanicsburg. P A 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITrEN APPEARANCE PERSONALLY OR BY A TIORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HtRlNG A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCmS THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 117-243-9400 CUMBERlAND COUNTY BAR ASSOCIA nON 2 uberty Avenue Carlisle,PA 17013 C cCAFFER EEVER B . repn A. Goldbeck. Jr.. E,q. Attorney for Plaintiff Suite 5000 - Menon lndependence Center 701 Market Street PhilndeIphia.PA 19106 215-627-1322 SPS-0331 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: December 2, 2005 TO: LORIEN A. PERKINS FKA LORIAN A. STROHL 181 t Knights Circle Cantonment, FL 32533 US BANK NA TIONAL ASSOCIATION. AS TRUSTEE FOR THE HOLDERS OFTHE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES. SERIES t999-3 1270 Northland Drive. Ste. 200 MendOla Heights, MN 55120 In the Court of Common Picas oiCumbertand County CNILACTION . LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE VS. KIRK A. PERKINS , LOR/EN A. PERKINS FKA LORIAN A, STROHL (Mol'tgagor(s) and Record Owner(s)) 5977 Eberly Drive Mechonicsburg. PA 17055 Term No. 05-5180 Dej'endoll.t(s) TO: LORIEN A. PERKINS FKA LORIAN A. STROHL 1811 Knights Circle Cantonment. FL 32533 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOUW 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 wrrn INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. lEGAL SERVICES INC 8 Irvine Row Carlisle. PA 17013 717.243.9400 CUMBERlAND COUNlY BARASSOCIA TION 2 Liberty Avenue Carlisle. PA 17013 ;ffJIt~ GOLDBECK McCAFFERTY &. McKEEVER BY' los"l'h A. Goldbock, Ir., Esq. Attomey for Plaintiff Suite 5000 - Mellon Independence Center 701 Market Strett PhiladeJphia,PA 19106 215-627.13n SPS-0331 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF TIllS NOTICE: December 2, 2005 TO: KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, PA 17055 US BANK NATIONAL ASSOCIA TlON. AS TRUSTEE FOR THE HOLDERS OFTHE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERlES 1999-3 1270 Northland Drive. Sic. 200 MendOla Heights, MN 55120 In the Court orCommon Pleas ofCumbertand County CIVIL ACTION . lAW Plaimiff ACTION OF MORTGAGE FORECLOSURE vs, KIRK A. PERKlNS LORJEN A. PERKINS FKA LORIAN A STROHL (Mortgagor(s) and Record Owner(s)) 5977 Eberly Drive Mcchanicsburg, PA 17055 Term No. 05-5180 DefendaRt(s} TO: KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, P A 17055 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 CLAlMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF nns NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RlGHTS. 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 1NF0RMATfON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HtRE A LAWYER, THfS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERvrCES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. lEGAL SERVICES INe 8 Irvine Row Carlisle, PA 17013 717-243~9400 CUMBERlAND COUNTY BARASSOCIATlON 2 Liberty AVQ1UO Carlisle, PA 17013 ?J"~ GOLDBECK McCAFFERTY & McKEEVER BY: JosephA. Oo1Qbeck, Jr., Es'l. Attorney for Plaintiff Suite 5000- Mellon IndqlQ1dence Ccnta' 701 Mar)cetStreet Philadelphia.PAl9106 215-627-1322 t \) ~ n ,..., 0 ,;:;.;J ;:::.J L~~.' , -n -0 ':...>'\ ~ r:J ..... ~ 0 il'~, ::C-n n"l ~--~ Cj T- O \~,,} ~?J,~? ~ 9r2. c:> - '\ (" ;~1 ~ ~ ",' - " (') ~ t..J .c: J."C <? ..'~/-11 W ~,~,\ "";::r _;.v III - ~~ --..l ~ ~ 0'"'\ R ~ _./--- PRAECIPE FOR WRIT OF""XECUTlON - (MORTGAGE FORECLOSURE) P,R.C.P 3180-3183 Joseph A Goldbeck, Jf. Atloll1ey 1.0,#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 2\5-627-\322 Altomey for Plaintifr US [J,\NK NATIONAL ASSOCIATION, AS TRUSTEE fOR TilE 1I0LDERS or TilE EQCC 110MI' EQUIIY LOAN ASSET [lACKED CERTIFlCAncS, SERIES 19~~-3 1270 Northland Drive, Ste, 200 rVlcndota Heights, MN 55120 IN Till' COURT OF COMMO;\l PLEAS of Cumberland County Plaintill CIVIL ACTION LAW VS. ACTION OF MORTGAGE FORf:CLOSURE KIRK A, PERKINS LORI EN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) 5~77 Eberly Drive t'vkchaIlicsburg, PA 170)5 No, 05-5180 Del'cndant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $141.581.83 Interest from 07/0 I /2004 to 12!l6/2005 at 9 J 000% (Costs to be added) GO B cCAFFERTY & McKEEVER BY: Jose h A. Goldbeck, Jf. Attl 'ney for Plaintiff if; ", ',...; ...; ~ '? o ... ,<, ... c e, ~O B~' u ~ if> ~ \-,",0.0 0..... ~c.: ";.;. o U '" ~ ... .?: C;, ~rO' r~ ';--< 0' \-" ',..-< 0' '/J? - ?O~ ::t~- '" -' 1.J <Ii 2. ifl "'" 0 . i~'0i OUI-' "'-<U-4. I;( aU ';"""'"~~ vi,U-' ?~~ O\-"~ .d,',.l.oV ..JO P <fif'WO icf:'-;J.. rWU ~o/; r-.-l -. ","OcCl z.o::.'r-' -;.!.wo'd, ~~'2 "'" I-' . """'~ if'0"'" :J '.J.-< 0 ..J >- cr' ;:$ ;,2~~' "',".--i (i'~ tdC~: ~,d"'-, L4~ L'_ o ,j, " ... - - o '" ... J;~ <tt f' .n -o"~ ~ '2, g~ovr- :/l ~ -0 .':::'- -;zO,bh/!' _ _ (.)1..-1 p.... ;:'J..(3~.;o ~;L,.......,-.... ~\J-<~:g~ p....ifl ;.;'..1J 'G .1. 'b '7~-'~ -;1.-;l.~:7'~ ....cLc'n-u ~ '.,LJ.~) ;;!. ~ c.-~) ,2. de i6 wo ;:2 o ..J IJ~ c;., r:= co N <-> L'..J o l.f.'? C_) C::l '"" -:.~) o 7, '0 - ,.. ''';; U ~~ ",," ~-a o~ ...'0 ~~ ';i<: '" ;;>' " rt.~ '" ,.. ~~ \.Me. ~ .... U '" ~ ~ ,.; -... ~' ';g <) ,~ '" '" ~p: o \-< Cj ,g . :;.-, ..( e f..o C) -;:. 'f) < ~, u ..... ~ ~ :.:i "U 11# (l,) 'J.U \0 vB 0 ~~v;; e:6 ~ <1) .-' r~ . ~~ --< ~r\ c.-o....o-----:' ~,Sjid'~ _ .- ....._ r,) "";o::,,c.-~ u~,2:.~'~ :::.~ _--::? ('\ f":2--Qc<:l ;;. t---E ~g ;:... ,.QO -d ,r. - '" '" v'S if' -- , '- , \ J ~ ~ ;; ar-o ~ - t- ~ t--- i; - 0.. ~ :: :::. 8 -j ~ r' ~-j ::; - :: ::: (' l CiJ I I \ \ \ <) C) ~ () 8 ~ () Q C) () j (J lIJ ~ ~ l/) C lrlCl l.Jl - U) ("( rt~":" v)~ (Q M 'i;;Jl> ...,.: cJ - :::t' ((,\6 V) ~ ~ ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT AT LOW WATER MARK ON THE WEST SIDE OF CONODOGUINE CREEK AT CORNER OF LAND NOW OR FORMERLY OF CLYDE WRIGHT STONE AND WIFE, WHICH SAID POINT IS ALSO THREE HUNDRED (300) FEET MEASURED IN A NORTHERLY DIRECTION ALONG THE LOW WATER MARK OF SAID CREEK FROM THE LINE OF LANDS OF MARK R. BASEHORE; THENCE CONTINUING ALONG THE LOW WATER MARK OF SAID CREEK IN A NORTHERLY DIRECTION, A DISTANCE OF ONE HUNDRED (100) FEET TO A POINT ON THE SAME, AT CORNER OF LANDS OF ELLSWORTH P. MURPHY AND DOROTHY A. MURRY, HIS WIFE, NORTH 750 45' WEST A DISTANCE OF TWO HUNDRED THIRTHY-FIVE (235) FEET, MORE OR LESS, TO A STAKE AT LINE OF OTHER LANDS NOW OR FORMERLY OF RAYMOND BRACKBILL AND MAGARET E. BRACKBILL, HIS WIFE; THENCE ALONG THE SAME IN A SOUTHWESTERLY DIRECTION ALONG A LINE PARALLEL WITH THE SAID LOW WATER MARK OF SAID CREEK, A DISTANCE OF NINETY (90) FEET TO A ST AKE AT THE CORNER OF LANDS NOW OR FORMERLY OF CLYDE WRIGHTSTONE AND WIFE, AFORESAID, THENCE ALONG SAID LANDS NOW OR FORMERLY OF CLYDE WRIGHT STONE AND WIFE, SOUTH 720 45' EAST, A DISTANCE OF TWO HUNDRED THIRTY-FIVE (235) FEET MORE ORLESS, TO A POINT AT THE LOW WATER MARK OF SAID CONODOGUINET CREEK, AT THE POINT AND PLACE OF BEGINNING. ADDRESS: 5977 EBERLY DR; MECHANICSBURG, PA 17055 TAX MAP OR PARCEL ID NO: 10-18-1321-007 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-5180 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999.3, Plaintiff (s) From KIRK A. PERKINS AND LORIEN A. PERKINS FKA LORIAN A. STROHL (I) 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) Ifproperty 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 $141,581.83 Interest FROM 7/1/04 TO 12116/05 AT 9.3000% L.L. $.50 Atty's Comm % Arty Paid $193.16 Plaintiff Paid Date: DECEMBER 28, 2005' Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQillRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKcever BY: Joseph A. Goldbeck, Jr. Attorney LD. # 16132 Suite 500n - Mellon Independcnce Center 70 I Market Street Philadelphia. PAl 9106 215-627-1322 Attorney for Plaintiff -.... ,. US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF TIlE EQCC HOME EQUITY LOAN ASSET [,ACKFn OiRTlF[CA TES, SIR[ES 1999-3 1270 Northland Drive. Ste, 200 Mcndota Hcights. MN 55120 [N TI[E COURT OF COMMON PLEAS oC Cumberland County Plaintiff CIVIL ACTION - LAW vs. KIRK A, PFRKINS LORlEN A, PERKINS FKA LORIAN A. STROHL (Mortgagor(s) and Record Owner(s)) 5977 Eberly Drive Mechanicsburg. PA 17055 ACTION OF MORTGAGF FORECLOSURE No, 05-5180 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 US BANK NATIONAL ASSOCIATION. AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME ~QUITY LOAN ASSET BACK~D CERTIFICATES, SERIES 1999-3, Plaintiff in the above action, by its attorney, Joseph A, Goldbeck Jr., Esquire, sets forth as of the date the praecipe for the writ of execution \vas flIed the following infonnation concerning the real property located at: 5977 ~berty Drive Mechanicsburg, P A 17055 I.Nnme and address ofOwner(s) or Reputed O\vncr(s): KIRK A, PERKINS 6030 Creekview Road Mechanicsburg, PAl 7055 LORI EN A PERKINS FKA LORI AN A, STROHL J R I t Knights Circle Cantonment, FL 32533 2. NnlTIc and address of DeCcndant(s) 1n the judgment: KIRK A, PERKINS 6030 Creekvie\v Road Mechanicshurg, P A 17055 LORIEN A PERKINS FKA LORI AN A, STROHL t R t I Knights Circle Cantonment fL 32533 3, Name and last knoV\11 address of every judgment creditor \\.'hose judgment is a record lien on the property' to be sold: - ,-. DOMESTIC RELA liONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enlorcement Health and Welfare Bldg. - Room 432 P,O, Box 2675 I1arrisburg, P A 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: S. Name and address of evTry other person \\,'ho has any record interest in or record lien on tht: property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintitT has knowledge who has any record interest in \hc property \\'hich may be atlected by' the sale. 7. Name and address of every other person ofwhorn. the plaintiff has knowledge who has any interest in the property which may be affected by the sale. fENANTSOCCUP ANTS 5977 Eberly Drive Mechanicsburg, P A 17055 DIANE G, RADCLIFF. ESQUIRE 3448 'hindle Road Camp Hill, P A 170 II (attach separate sheet ifrnore space is needed) {vcrlfy that the :-;tatements made in this atlidav'it are true and correct to the best of my personal knO\vledge or infonnation and belief. I understand that false statements herein are made subject to the penalties of IF; Pa. C.S. Section 4904 relating to uns\,...orn falsification to authorities. DATED: December 16, 2005 ( ,2_ ____ __ Wi\HERTY & McKEEVER ph A. Goldbeck, .Ir.. Esq, , for Plaintitf p ,...., C;'.:.1 C.:) ...,..;"1 r"l j::'-:-':-1 ,l N CO o -'\1 --1 fT~t1 -::-!rr. -,.,,~" ~) ;r~ - ~ :- , " _:~ ;:!2~ (jrl'; :~;! ...-, :.< 0-) 0' -,~~-~~.._-'-_. ~ , 05-5180 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, JT. AttomeyI.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-t532 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORlAN A. STROHL Mortgagor(s) and Record Owner(s) Term No. 05-5180 5977 Eberly Drive Mechanicsburg, PA 17055 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: KIRK A. PERKINS KIRK A PERKINS 5977 EBERLY DRIVE MECHANICSBURG, PA 17055 Your house at 5977 Eberly Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$141,581.83 obtained byUS BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: \. ".- 05-5180 1. The sale will be cancelled if you pay to US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of7 I 7-240-6390, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale, This schedule will state who will be receiviug that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 C) ~~-;: ", ':::.~~ c....-;, '~.n C") -n --j 'T i'lliTI :~:0b (~ ~ (J., -,,:!-.:; r:::J i'-.'l C) "" = _.~-~ .:-.? Z;", cj rT~ ~i ~~ '-:? (J') ---- - .... 05-5180 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jf. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA t9106-1532 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) Term No. 05-5180 5977 Eberly Drive Mechanicsburg, PA 17055 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT, ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PERKINS. LORlEN F/K/A LORlEN STROHL Lorien Perkins f/k/a Lorien Strohl 5977 EBERLY DRIVE MECHANICSBURG, PA 17055 Your house at 5977 Eberly Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $141 ,581.83 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: -' , 05-5180 I. The sale will be cancelIed if you pay to US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR TIlE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calIing the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may calI the Sheriff 0017-240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule wilI state who wilI be receiving that money. The money wilI be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PAt 70 13 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 (") ~, 0 ,;;;;;;. F~ c:> ~n ....fl C'1 -l ~. r/\ nip n n-: f'.) c:; co () " '. " -'~~~~ ,'._, en LkJ ~~ ~D CY' .< 05-5180 GOLDBECK McCAFFERTY a McKEEVER BY: Joseph A, Goldbeck, Jf. - AttorneyI.D,#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) Term No. 05-5180 5977 Eberly Drive Mechanicsburg, P A 17055 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PERKINS. KlRK A, KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, P A 17055 Your house at 5977 Eberly Drive. Mechanicsburg, P A 17055 is scheduled to be sold at Sheriff's Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $141 ,581.83 obtained by US BANK NA TIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 05-5180 -. , I. The sale will be cancelled if you pay to US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, the back payments, late charges, costs and reasonable attorney's fees due. To frod out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale, (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest hidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find ont if this has happened, you may call the Sheriff of7 I 7-240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share oflhe money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale, This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ---~,._.~-'<- C) C' r-> (~::) ,:::::> "",,"J o (''';''1 CJ ---------- r<;. CO ,-) ~"l :-;:\ ri\1J -r,rl'"'; ;:A"~~ _~f;,; ::;J .-< -0 (J ...... 05-5180 GOLDBECK McCAFFERTY>'kMc'KEEVER BY: Joseph A. Goldbeck, Jr. Attorney l.D.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, PAt 9 t 06 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) Tenn No. 05-5180 5977 Eberly Drive Mechanicsburg, P A 17055 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PERKlNS, WRIEN A. LORIEN A. PERKINS FKA LORIAN A. STROHL 1811 Knights Circle Cantonment, FL 32533 Your house at 5977 Eberly Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $141 ,581.83 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: ~~ 05-5180 ". . 1. The sale will be cancelled if you pay to US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. Yau may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. IUhe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5, You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale, This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irvine Row Carlisle, PA t70t3 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 n C."".:. 1>"',) ,:::::) .':';',) (.,/1 = I.....; n ''''' CO o -n .--1 f1i:n , rr; L-; -<~' -1''''' ":.J. ~~~ ~~rn :< .w.\,. 'f? -' ,/ " GOLDBECK McCAFFERTY & McKEEVER By: MICHAEL T. MCKEEVER, ESQ. ATfORNEY J.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATfORNEY FOR PLAINTIFF US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL (Mortgagor and Record Owner) 5977 Eberly Drive Mechanicsburg, PA 17055 Term No. 05-5180 Defendant( s) PRAECIPE TO CORRECT PROPERTY ADDRESS Kindly correct the docket to reflect the correct property address of 5985 Eberly Drive fIka 5977 Mechanicsburg, PA 17055. Respectfully submitted, GOLDBECK, McCAFFERTY & McKEEVER By: ~.-::lt',;~. ~ = a-'" ..,...,.,... ::0 ?:::l N ......l o .1 .....-\ --:t: -n flip" If", -, \.,... c., (:::-.:/ - - . ~ -C'"i ~.~.~\ J, s ~ 0) 0'" GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000 .. Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorn for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 MendOla Heights, MN 55120 SPS-0331 CF: 10/03/2005 SD: 06/07/2006 $141,581.83 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) Tenn No. 05-5180 5985 Eberly Drive Vk/a 5977 Mechanicsburg, P A 17055 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ()() Personal Service by the Sheriff's Office,.t:,l~~~~~{wl'] vf .~l~.. Ah...J.~Jr. ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriff's Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. B : Jo ph A. Goldbeck, Jr. Attorn y for Plaintiff .... ;r I\J ;r ;r IT" ..D ..D ..D 0 FF I C I US E ..D .... .... , '" '" ,l.!-,/" CJ "- , Yes CJ - , (?~!. -:.-') I\J ~Foe I\J ~Foe ,5 '/' , CJ CJ '~ CJ . FlelumRecllfplFee T CJ Retum~Fee CJ -- CJ (U4.....emtJlll RequIred) CJ (~"'1.""~ CJ _ 0el1wlY Fee IT" . IT" (~ndcnement AequJred) SPS-0331 6/7/( l'Tl l'Tl CJ lbtaJ-.'& "",5, KIR CJ lbtaJ_~ 5 I'" l'Tl IT" ..D ..D .... '" CJ eER III-Iel) 1I!IAIl riLl.-. " (DofllestH M,,,j(JI1f.' ",! 'lv,'1'11 ",1'( OFFICIAL es USE -' ,J \\ :)({}Pr' \,.':\-". ;, ,";J'\ I;:" > JAL#,' 5_,,1 ;;;",' ryo'" ' LV!,' ....,1 I\J CerIlflodFee e ~ . 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Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) 5985 Eberly Drive fIkIa 5977 Mechanicsburg, PA 17055 Term No. 05-5180 Defendant( s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following infonnation concerning the real property located at: 5985 Eberly Drive flk/a 5977 Mechanicsburg, P A 17055 I.Name and address ofOwner(s) or Reputed Owner(s): KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, P A 17055 LORIEN A. PERKINS FKA LORIAN A. STROHL 1811 Knights Circle Cantomnent,FL32533 2. Name and address ofDefendant(s) in the judgment: KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, P A 17055 . LORIEN A. PERKINS FKA LORIAN A. STROHL 1811 Knights Circle Cantomnent, FL 32533 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MANUFACTURERS AND TRADERS TRUST COMPANY, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE CONTIMORTGAGE HOME EQUITY LOAN TRUST 1995-4 CERTIFICATES I EAST MAIN STREET FREDONIA, NY 14063 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUP ANTS 5985 Eberly Drive flk/a 5977 Mechanicsburg, P A 17055 DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 12,2006 o c <~ ~cr' ~:~~; ~:7' r:" .:- ~\"~ ~:i =< ....., = ~-=..l "'" :T- "'" -< o -n ~ ni ::n r- -om ::nX' C) -0 =ri 1', ,;'-""1 ...J-- -:?-O 15m .-. :!O -< 0;) -0 ~ ~. N .. U1 CO 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 Nationscredit Fin Ser Corp is the grantee the same having been sold to said grantee on the 7th day of June A.D., 2006, under and by virtue of a writ Execution issued on the 28th day of December, A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 5180, at the suit of US Bank Natl Assoc. as Tr for the holders of the EOCC Hm Eq Ln Asset Backed Cet series 1999-3 against Krik A Perkins & Lorien A aka Lorien A Strohl is duly recorded in Deed Book No. 275, Page 1874. al of said office this day of US Bank National Association As Trustee for the Holders of the EQCC Home Equity Loan Asset Backed Certificates, Series 1999-3 VS Kirk A. Perkins and Lorien A. Perkins f/k/a Lorian A. Strohl The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5180 Civil Term Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 09,2006 at 2:23 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Kirk A. Perkins, by making known unto Kirk A. Perkins, personally, at 6030 Creekview Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice of Sheriffs Sale and Description in the following manner: The Sheriff mailed by certified mail, return receipt requested, deliver to address only, restricted delivery a copy of the within action to the within named defendant, to wit: Lorien A. Perkins f/k/a Lorian A. Strohl, to her last known address of 1811 Knights Circle, Cantonment, FL 32533. This letter was mailed under the date of March 30, 2006. The return receipt card was signed by Kirt B. Haule on 4/03/06 and returned to the Cumberland County Sheriffs Office. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 05, 2006 at 11 :35 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kirk A. Perkins and Lorien A. Perkins f/k/a Lorian A. Strohl located at 5985 Eberly Drive, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Kirk A. Perkins by regular mail to his last known address of 6030 Creekview Rd., Mechanicsburg, PA 17055. This letter was mailed under the date of April 03, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Lorien A. Perkins f/k/a Lorian A. Strohl by regular mail to her last known address of 1811 Knights Circle, Cantonment, FL 32533. This letter was mailed under the date of April 11 , 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who 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 Courthouse, Carlisle, Cumberland County, Pennsylvania on June 07, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Nationscredit Financial Services Corporation. It being the highest bid and best price received for the same, Nationscredit Financial Services Corporation of 1270 Northland Drive, Suite 200, Mendota Heights, MN 55120, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $962.72. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30.00 18.87 15.00 15.00 30.00 10.00 .50 1.00 19.36 6.52 15.00 30.00 359.00 328.40 19.57 25.00 39.50 $ 962.72 /~ So Answers: r~~~~/~ , R. Thomas Kline, Sheriff '1!J-f!,,(, J))-"^~ (~>J/ 00 . 3t. ./t'J \ ' j : J'..... .;.; (/ ~./ 'r I{ 1r2t-l..-/I J t Olf J i WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5180 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, Plaintiff (s) From KIRK A. PERKINS AND LORIEN A. PERKINS FKA LORIAN A. STROHL (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) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $141,581.83 Interest FROM 7/1/04 TO 12/16/05 AT 9.3000% L.L. $.50 Arty's Comm % Atty Paid $193.16 Plaintiff Paid Date: DECEMBER 28,2005' Due Prothy $1.00 Other Costs (Seal) 8M . ~- Prothonotary ifi'-~ '] By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 10 On February 03, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 5977 Eberly Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 03, 2006 By: . ,- . I ) C (l,io.{) Vli\ JJ._ \'c Real Estate Sergeant ~ ~ .~~ (' "._-"..... ~"~CI iIiiu i S :01 \j I:: - NVr qOill . . v" '\ ; ;. " : .-:"", ~, ~.:l'IB3HsjHl _-HJ j:jl:UO f " Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC I [OME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL (Mortgagor(s) and Record Owncr(s)) 5977 Eberly Drive Ivlechanicsburg, P A 17055 ACTION OF MORTGAGE FORECLOSURE No. 05-5180 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS Of THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, PlaintilTin the above action, by its attomey, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information conceming the real property located at: 5977 Eberly Drive l'vlechanicsburg, P A 17055 I.Name and address ofOwner(s) or Reputed Owner(s): KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, P A 17055 LORI EN A. PERKINS FKA LORIAN A. STROHL 1811 Knights Circle Cantonment FL 32533 2. Name and address of Defcndant(s) in the judgment: KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, P A 17055 LORI EN A. PERKINS FKA LORIAN A. STROHL 1811 Knights Circle Cantonment, FL 32533 " 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. P A 17013 PA DEPARTMENT OF PUBLIC WL::LFARE - Bureau of Child Support Enl(Jrecment Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, P A 17105-2675 4. Name and address of the last recorded holder of every mortgage ofrecord: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be atTeeted by the sale: n. Name and address of every other person of \vhom the plaintiff has knowledge \I/ho has any record interest in the property \vhich may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TFNANTSOCOCUPANTS 5977 Eberly Drive Meehanicsburg, P A 17055 DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road Camp Hill, P A 17011 (attach separate sheet if more space is needed) I verity that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 16, 2005 'AFFERTY & McKEEVER ph A. Goldbeck, Jr., Esq. for Plaintiff f . .. . f I 05-5180 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627 -1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION - LAW Plaintiff YS. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) Term No. 05-5180 5977 Eberly Drive Mechanicsburg, P A 17055 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PERKINS, KIRK A. KIRK A. PERKINS 6030 Creekview Road Mechanicsburg, P A 17055 Your house at 5977 Eberly Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$141,581.83 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: .. r,' , 05-5180 1. The sale will be cancelled if you pay to US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627 -1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, P A 17013 05-5180 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KIRK A. PERKINS LORIEN A. PERKINS FKA LORIAN A. STROHL Mortgagor(s) and Record Owner(s) Term No. 05-5180 5977 Eberly Drive Mechanicsburg, P A 17055 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PERKINS, LORlEN A. LORIEN A. PERKINS FKA LORIAN A. STROHL 1811 Knights Circle Cantonment, FL 32533 Your house at 5977 Eberly Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$141,581.83 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3 against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 05-5180 1. The sale will be cancelled if you pay to US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1999-3, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will ga through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid far your house. A schedule of distribution ofthe money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your hause back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT AT LOW WATER MARK ON THE WEST SIDE OF CONODOGUINE CREEK AT CORNER OF LAND NOW OR FORMERLY OF CLYDE WRIGHT STONE AND WIFE, WHICH SAID POINT IS ALSO THREE HUNDRED (300) FEET MEASURED IN A NORTHERLY DIRECTION ALONG THE LOW WATER MARK OF SAID CREEK FROM THE LINE OF LANDS OF MARK R. BASEHORE; THENCE CONTINUING ALONG THE LOW WATER MARK OF SAID CREEK IN A NORTHERLY DIRECTION, A DISTANCE OF ONE HUNDRED (100) FEET TO A POINT ON THE SAME, AT CORNER OF LANDS OF ELLSWORTH P. MURPHY AND DOROTHY A. MURRY, HIS WIFE, NORTH 75045' WEST A DISTANCE OF TWO HUNDRED THIRTHY-FIVE (235) FEET, MORE OR LESS, TO A STAKE AT LINE OF OTHER LANDS NOW OR FORMERLY OF RAYMOND BRACKBILL AND MAGARET E. BRACKBILL, HIS WIFE; THENCE ALONG THE SAME IN A SOUTHWESTERLY DIRECTION ALONG A LINE PARALLEL WITH THE SAID LOW WATER MARK OF SAID CREEK, A DISTANCE OF NINETY (90) FEET TO A STAKE AT THE CORNER OF LANDS NOW OR FORMERLY OF CLYDE WRIGHTSTONE AND WIFE, AFORESAID, THENCE ALONG SAID LANDS NOW OR FORMERLY OF CLYDE WRIGHTSTONE AND WIFE, SOUTH 720 45' EAST, A DISTANCE OF TWO HUNDRED THIRTY-FIVE (235) FEET MORE ORLESS, TO A POINT AT THE LOW WATERMARK OF SAID CONODOGUINET CREEK, AT THE POINT AND PLACE OF BEGINNING. ADDRESS: 5977 EBERLY DR; MECHANICSBURG, P A 17055 TAX MAP OR PARCEL ID NO: 10-18-1321-007 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEAL TH OF PENNSYL VANIA SSe 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: J\priI7,14,21,2006 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. SWORN TO AND SUBSCRffiED before me this 21 day of April. 2006 ~~~~.~~~A~ ;v~... .'. .' " " tl', " ",)': ..:J;';},'.. ~ I l (""" ,.. . ,. ~ .j> :- OJ -n"'(' " . .. . if -',-' , .'..e.. ., '" .;.... i. i (>k::;~ ::un:)ri: i ~ .j~ ~,.'., REAL ESTATE SALE NO. 10 Writ No. 2005-5180 Civil US Bank National Association, as Trustee for the Holders of the EQCC Home Equity Loan Asset Backed Certificates, Series 1999-3 vs. Kirk A. Perkins and Lorien A. Perkins fjkja Lorian A. Strohl Atty.: Joseph Goldbeck ALL THAT CERTAIN piece or parcel of land situate in the Town- ship of Hampden, County of Cumberland and Slate of Pennsyl- vania, bounded and described as follows. to wit: BEGINNING at a point at low water mark on the west side of Conodoguine Creek at corner of land now or formerly of Clyde Wrightstone and wife, which said point is also three hundred (300) feet measured in a northerly direc- tion along the low water mark of said creek from the line of lands of Mark R. Basehore; Thence continuing along the low water mark of said creek in a northerly direction, a dis- tance of one hundred (100) feet to a point on the same, at corner oflands of Ellsworth P. Murphy and Dor- othy A. Murhy, his wife. North 750 45' West a distance of two hundred thirthy-five (235) feet, more or less, to a stake at line of other lands now or formerly of Raymond Brackbill and Magaret E. Brackbill. his wife; Thence along the same in a south- westerly direction along a line par- allel with the said low water mark of said creek, a distance of ninety (90) feet to a stake at the corner of lands now or formerly of Clyde Wrightstone and wife, aforesaid, thence along said lands now or for- merly of Clyde Wrightstone and wife, South 720 45' East. a distance of two hundred thirty-five (235) feet more or less, to a point at the low water mark of said Conodoguinet Creek, at the point and place of beginning. ADDRESS: 5977 EBERLY DR; MECHANICSBURG, PA 17055. TAX MAP OR PARCEL ID NO: 10-18-1321-007. t' .. 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 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller 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 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, 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 smce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 2006. That neither he 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 he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#10 .~ CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 REAL ESTATE SALE NO. 10 WrIt No. Jln .. ....,.Tenn US BankUdI ",_J:llndr""-., 88 1\'u8Iee for......... or.. EOCC tIoIRlt"" ~ Aawt BacktJd ".L r......1.... 3 vs a<:1rt( A. ~..1Mten A. Pertdns ........A.8II'ohI ~I., ..........11 .All 11r. DI8ItPnoN ~. Wllidrsaill~ is.." tet~iIla~~ tOw. Wlbr Matt ClfsaillCRilt fromtbe lands of Matt R. 1JatIeIm; tImle roatiBuiDg along the Low W~ _ of said Creek in a NoItba:I.y diMeCioD. a ~ of one hundred (100) feet to a point......- tooW oflaads of EIJswutb P: MIlpIIy._~ A. Murphy, his wife, NOl1h7S __ 4S' West a distance of two buJiiJred tIIilty4ift(23S) feet... or less, to a state at lilefi _. _or fomaedy of RayIJlOIll Brar.iIJi1l_...... E. BndbiIl. his wife; tbt.P .,."in aSoulhwesterly . di1miorl ~ a" J*8Iel'with tbe said Law W. *k of._~. a ~ of Dinety (90) fed to ._ at ..........now or formerly Of ~ Willi ' aDd wife, aforesaid., mr.a'" ..... now or formerly of Clyde ~_ '-ife, Soudi 72 de~ 45'EIlIt, a fl>,'lIf two h\mdl'ed thirty five (235) .......toa..... at tbe Low WJfeC Mattof..~Cnlck,at dIe..- IIId ~.JIQNJUNG. AJ>1ltESS: 5fJT1 Ebr.dy Dr; ~, PAI_ TAX MAP OR PAICflI.'lCIL II>. NO NO..: : .~ 1..0-1 . . 007 ~