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Home My WebLink About05-5373 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 WM SPECIALTY MORTGAGE LLC, WrrnOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE it ()5'- 5?J13 ~i ( , Term No. vs. LORETIA SYKES-LACEY Mortgagor and Real Owner 810 Kent Drive Mechanicsburg, PA 17055 CIVIL ACTION: lv!ORTGAGE NOT ICE fl'QfIIECL08URE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Defendant LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 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 DrAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISa. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa 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 FA VQR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA, POR RAZON DE ESA DECISION, ES POSSffiLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA 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 ELIGffiLE 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, PA 17013 TillS 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. I). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HOD'S web site www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-211-6926 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 payoffthe mortgage or request a Loan Workout I Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The figure andlor 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 AMQ-0584. Para informacion en espanol puede communicarse con Loretta aI215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE I. . Plaintiff is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The name and address ofthe Defendant is LORETTA SYKES-LACEY, 810 Kent Drive, Mechanicsburg, PA 17055, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On December 18, 2003 mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1849, Page 65. The mortgage has been assigned to: WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 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 I 019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for April 01, 2005, and each month thereafter and by the terms ofthe Mortgage, upon default in such payments for a period of one month, 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 03/01/2005 through 10/31/2005 at 9.2500% Per Diem interest rate at $46.64 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph $184,074.01 $11,426.80 $9,203.70 Late Charges from 04/01/2005 to 10/31/2005 Monthly late charge amount at $76.30 Costs of suit and Title Search Escrow Fees $534.09 $900.00 $2.98 $10.00 Monthly Escrow amount $0.00 $206,151.58 7. If the Mortgage is reinstated prior to a Sheriffs 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 reserves its right 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 Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or and "in personam" judgment) against the Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge oftheir personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania. A copy of the Pennsylvania Housing Finance Agency Denial letter is attached hereto as Exhibit "B". The Defendant had the required face to face meeting within the required time and Plaintiff has been advised that the Defendant filed an application for mortgage assistance with the Pennsylvania Housing Finance Agency, the Plaintiff has been advised by the Pennsylvania Housing Finance Agency that the Defendant's application has been rejected. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $206, 151.58, together with interest at the rate of $46.64, per day and other expenses costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale ofthe Property. '1 I., By: c GO E McCAFFERTY & McKEEVER By: /J~SEP 'A. GOLDBECK, JR., ESQUIRE A TTMNEY FOR PLAINTIFF VERIFICA nON \, Teresa Skinner, 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 [ understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: 10/12-0') CITIFINA c&fii6it }t 07/22/2005 12:49 7626218 KffiNERSTDNER PAGE 02 ICl~t 9hu 9~ /llADS'"..2;.1., 41)111 .rtl~ ~ 11f~)II"'Ih,.Ntn~MJ,,;,,,f,y. JIJITWllEH .-.., LUCl/jDA I(. RUBS.IlnoIo_ .nl.,. callH Granw(IJ, "'''' , LORnTA SVI(ltS-IAcn. ""'~JqfIn ../WGton/uAl. W1T1'IIl3JIlTH. """,. ...__ '111'_00.................. ...... . 01'11 RI!I'IDIlCD P1rrv I1()UIl THOUSAND i'lli'll!: HUI'IDIll!:D DOlLARS ,. _ poId. "'" ,.../pf __lib -h? _~ firIf _ Gmma(>) ""'<!111mb, I"QHI tmd t(UIswy ttJ 1M 1II'JIJ(1rtmtn~. ALL TIlAT CJ:P.TAII'I ..... or ...,.... .t....... _. Iallompdoo To_p, CII-.nd C_, PoonayI..,,1o, ...... putloulerlyboutd.... cloM<lbool u ft>I1o.... '0 wit 8.tGINl'III'IG" .l'OinI.........."'" rlahl-of-wO)' 1In. oIK... Dd"'..... dMdlogu..w-. Lolo 1'1" ~ aod 63 or... _.,1Ior _.... p". oIIoCo; ,"""""..... uId dM....II.. 1'1_ 00 ~ II ml_ 20 _,1!uI11O.... ... poIrt; 'ho....Ioo.1iu otLot 1'1.. 62.Soll\h10~_41_~__I05,....\lno.fLotNo. 81: 1honccllon.l ,....... SouIloM ........11 mlool,,20_ Will 110 ....,....._...,..ot-""I'II.. at IC.... Orin:; tfwInc:c, a10q the wn. NOItIt ~..... 41 mlDUtGl40 lCilMCm.dt WIlIt. ID5 ~ 10 1I....Lot]\lo. OJ. lb. PI... orBllGINl'lII'IG. DaNG .It orLct No. tS2 11ft ,,- ""'1 pt.. N$. 2. Put orSccdDa 2. DcimJe- MUOI', recOrde4 at PI.. Book n. hat 10, Cllmberlancl eou.., ....nlo. BIIN(llho..... pnm;... del. I. wNdo _......... 10,.. G_.) bo.dA by d"'" 0(1"", L. a.u... pd Lucinda K. ku. d.e.d July 2<4. t9St2. and NCOrded m Dead Book U '.... .576 CWnbodon<lC_._. :~ IIJ' " .-;0.... ";J :~: ti ~:i ~ 3 ,,:..:',2 '-::~:i ~ :~, ~~ ~ n:: :.: :t. ~~~ 'a! l,::"; ID ?' ~ N' ~ ~ finll~~! '1I11~;!! i I I ! I 8 i i ~ S 2 il Ii !it J Ji l~ iOf U' i IlOOl 137 ,.It 988 l'~f_ - - ,........ .. p,~lii6it (B ;~F._:l-U':)-:;>Or.:J5 l'l:Pt? C'P HCI'_"Slt--IG ClHD Ff"'AI'ICF '(1 '778'.13995 p.0t/k-1!_ Pennsylvania Housing Finance Agency HomeoWJler.' Emfl'le~y Mortgage Assista"". L~..l'rogram l:!1Y.me1!l.: 211 North FrQ'" Street, P.O. Box 15206 Ham'lnug, PA J71O'-'106 Ct""f!IDtHlUm:e; 211 North Front Strut, P. O. Box } 5510 Harrlsbltrg, PA 17105-5530 (717) 7B0-3940 I_BOO_342_2397 FAX (717) 780,3995 1TY(717) 78M869 9/26/2005 AMC MORTGAGE SERVICES PO BOX 11000 SANiA ANA, CA. 92711 SUBJECT: lORETTA SVKES.LACEY 810 KENT DR MECHANICBURG, PA. 17050 S.S. #: 243-80-6124 loan #: 0064609506 Your application for a HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE lOAN has been DENIED pursuantlO Act 91 of 1983, 35 P.S. Seollon 1680A01-C ot_. andlor Agency Guidelines 12 PA Code SoctIon 31.201 61 seq. for the following ,easons: DELETED IN lEHDER'S COpy You may be entitled to an appeal hearing if you disagree with our decision, Requests for a h....rlng must I)e made in writing and mUlt be sullmltted to the Agency within 15 deys after th.. poatmsrk dste of this latter. Verbal requests a", not acceptable. The hearing may be conducted by a telephone conference call; therefo,e, you must include your telephone number. You also have a right to an in-person heering at the Agency's office In Harrisburg if you so desire. Requests for hearing. must slate 1I1e "'eson{s) thai a hearing is requested and must be sent first class, registered Or cerllfled maUlO: Chief Coun.el- HEMAP Hearing Request, PHFNHEMAP. 211 Horth Front Straet, P.O. Box 15628, Hanisburg, PA, 17105-5628, The hearing request may elso be faxed to the allenUon of Chief Counsel- Hearing Request at 717-780-4031. The Agency will.ll8mpt to schedule the hearing wi1l1in thirty (30) days all8rthe request i5 rtlClIlved. When Bending your spPQal, please be sure to print or type your name legibly and Include your soCial sewrity number and phone number where you may be reached during the day, YOu have a right to be represented by an attorney in wonnec'iJon with your appeal. If you cannot afford an attorney you may be eligible for legal Services representation. You can contact a Legsl Service. representsDve toJ) f,,,,, et1-80{)-322-7572 for a <erenalto the office for your county, Please be aware that scheduling 8n appeal hearing does not necessarily stay foreclosure proceedings. DISCLOSURE OF USE OF INFORMATION OBTAINED FROM OUTSIDE SOURCE: 1. Disclosure inapplicable. The Federal Equal Credit Opportunity k1 prohibits cre<lkors from discriminabng against "'edit applicams on the baslB Of race, color, religion. national origin, sex, maritalstatu8, age (provided that the applicant he. ll1e capacity to enter into a binding contrael); becauss all or part of the applicant's Income derNes from any public aS$lstance pmgram; or because the applicant has in good f81111 exerclsad any right under the Consumer Credit Proteelion Act The Federal Agency that administers compliance with this law concerning this creditor i.the Federal Trade Commission, Equal Credit Opportunity, Washington, D,C. Sincerely. THE PENNSYLVANIA HOUSING FINANCE AGENCY Homeowners' Emergency Mortgage Assistance Program I-fPREJECT Rev. SephWnQer .2003 TOTAL P.01 c:' ~":;,; (-: ~~ @)~ ~ ~":. D ~~ -.... <.i> ~ ~~u, ~~\ ~ \0) - ..;:- SHERIFF'S RETURN - REGULAR CASE NO: 2005-05373 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS SYKES-LACEY LORETTA JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SYKES-LACEY LORETTA the DEFENDANT , at 2052:00 HOURS, on the 25th day of October ,2005 at 810 KENT DRIVE MECHANICSBURG, PA 17055 by handing to LORETTA LACEY a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18,00 13 .44 .00 10.00 .00 41.44 ...p ~ --$/~/)..~ . ,r? /~'~"'7'~~~.' ~ R. Thomas Kline 10/26/2005 GOLDBECK MCCAFFERTY Sworn and Subscribed to before By: MCKEEVER ~ me this (/"": day of /--, ( /i Dep0 Sheriff ~' n~':TY A.D. ~ GOLDll[TK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Ccnter 70 I Market Strcet Philadelphia, l' A 19106 215~627~1322 Attorncy I"r "lainti ff WM SPECIALTY MORTGAGE LtC, WITHOUT RECOURSE 505 City Parkway West Suite tOO Orange, CA 92S68 IN TilE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION LAW LORETTA SYKES~LACEY (Mortgagor(,) and Record owner(,)) 810 Kent Drive Mechanicshurg. P ^ 17055 ACTION OF MORTGAGE FORECLOSURE Delcndant('j No, 05~5373 CIVIL ORDER FOR JUDGMENT Please enter Judgment in favor of WM SPECIALTY MORTGAGE LLC. WITHOUT RECOURSE, and against LORETTA SYKES~LACEY for failure to file an Answer in fhe above action within (20) days (or sixty (60) days if det'cndant is the United States of America) from the date of service of the Complaint, in the sum of $208.589.54, ~-~~- , Gold 1cck. Jr. f'lf Plaintiff I hereby certify that the above names arc correct and that the precise residence address of the judgment creditor is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 50S City Parkway West Suite 100 Orange, CA 92868 and that the name(s) and last known address(es) of the DeI'endant(s) is/arc LORETTA SYKES~LACEY, 810 Kent Drive Mechanicsburg, PA 17055; GO CK McCAEFERTY & McKEEVER BY: s h A, Goldbeck, Jr. Attorney telr PlainliJJ ASSESSME'<T OF DA\IAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follmvs: Principal Balance ~ I X4,074,O 1 Interest trom 03/01/2005 through 12/19/2005 $13,712,16 Reasonable Attomcy's fcc $9,203,70 Late Charges $6X6,69 Costs of Suit and Title Search $900,00 Escrow Fees S:2.9S $10,00 $20X.5X9,54 _u_ 1cCAFFERTY & McKEFVLR h ^, (ioldbcck. Jr. lor Plaintiff AND NO\V, this 2.2~d.oay of Dt:..c..... ,2005 damages are assessed as above. Pro P othy Ii , VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff (~Jrporation Vi~ th,in nam(=::d c:le hereby verify thd.t 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 knowledge, information and belief. I understand best of my 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 De fendant, LORETTA SYKES- UKEY, IS about Lll.rZI10hirl years of age, that Defendant l.s ! dS-~ knc'I.'Jn residence is 810 Kent Drive, 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 St2tes or its Allies, or other'w'ise 1:Jithin the provisions of the Soldiers' and Sailors' Civi 1 Relief Action of Congress of 1940 and its Amendments. Date: - In the Cmlo:.t of Common Pleas of Cumberland County WM SPECIALTY MORTGAGE LLC'. WITHOUT RECOURSE 505 City Parkway West SUite 100 Orange. CA 92R6R Plaintiff VS. LORETTA SYKES-LACEY <\Iortgagor(s) and Record OWIH-'r(s)) S I 0 Kent Drive Mechaniesburg, P A 17055 No, 05-5373 CIVIL Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBT AINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against LORETTA SYKES-LACEY by det~lUlt for want of an Answer. Assess damages as follows: $20R,5R9.54 Debt Interest - 03/01/2005 to 12/19/2005 Total (Assessment of Damages attached) I CERTIFY TIIAT FOREGOING ASSESSMF:NT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO IW DUE IN TIlE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe \\'(lS mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the det~'lUlt occurred and alleast ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.CP. 237.1 .losep Att me for Plaintitf LD#{6132 AND NOW 'J)F c..~.;:( ,J,rY':l0 . Judgment is entered in favOfofWM SPECIA1.TY MORTGAGE LLC'. WITHOUT RECOURSE and against 1.0RETTA SYKES-LACEY by dctimlt {i)!' want of an Ansv..'er and damages assessed in the sum of$20R,5R9.54 as per the above certif cation. R Proth . AMQ-0584 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: November 15,2005 TO: LORETTASYKE~LACEY 810 Kent Drive Mechanicsburg. PA 17055 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92&6& In the Court of Common Pleas of Cumberland County CML ACTION - LAW Plaintiff VS. LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) & 1 0 Kent Drive Mechanicsburg, P A 17055 Action of Mortgage Foreclosure Tenn No. 05-5373 CIVIL Defendant(s) TO: LORETTA SYKES-LACEY 810 Kent Drive Mechanic,burg, P A 17055 IMPORT A NT NOTlCY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAlLED TO ENTER A WRJTI'EN 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 TIiE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIiER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIiE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA T 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 ASSOClATION 2 Liberty Avenue Carlisle. PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Ioseph A. Goldbeck, Ir., Esq, Attorney for Plaintiff Suite SOOO - Mellon Independence Center. 101 Marl<etStn:et PMadelphia, PA 19106 215-621-1322 'GJ-J '+- ~ r ~ ~ ~ as '(\ ~ R: () -IA- ....a ~ '> ~ C> ~ -u ~ r- CY1- () ~~ ;~-) C~. r',:') -'jl ,'." o -4 r-q --r: ("~) rn -,-, ,'.'> N -;) - C.) r.....:.. , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A, Goldbeck. .If. Attomey 1.0.# 16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia. P A 19106 115-(<~7-1322 Attomt:y. t(J[ PJ<linlilf WM SPECIALTY MORTGAGE LLC. WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange. CA 92868 IN TIlE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION, LAW LORETTA SYKES-LACEY 1\Iortgagor(s) and Record Owner(s) RlO Kent Drive I'v1ccbanicsburg. PA 17055 ACTION OF MORTGAGE FORECLOSURE No, 05-5373 CIVIL Defcndant( s) PRAECIPE FOR WRIT OF EXECUTION TO TIlE PROTHONOTARY: lssuc Writ of Execution in the above matter: Amount Due $208,589,54 Interest from 03/01/2005 to 12/19/2005 at 9.2500% (Costs to be added) "- -- --"--. -- ---- GOLD ,C McCAFFERTY & McKEEVER BY: os ph A Goldbeck. k Attorney '()f Plaintiff ~ :.... \J ~v " " ~gg .... <l.} ~< ~ 'l.> 0' ~ V (j)..- 01 .. fr~<~. C'U ...:. c..: r--; ~.sJ2 d~~ c.;..';::::::~;:\'c ~ 0";"" 0. I U -;::::: ,2. -' If) r..JV,...-~- ';::'?::=o~(""\ ~ 1 ' ~ U 'J c... ,,~ ~~ ~S?, 6 .~ '" ~ ::, ,/, Jc ~ ~ -:: ,,," '- ;..;.; Z '..;J "'" :::: ~ V :.. >-- " ~ " '- " ,n "" " -, 7, u CD ;;: if> X '" -'" .~ 0 ..J U 0 :0 ..J -< 0 t- Iol " u 0; ::J ::2 " - 0 u ..J "0 ... U .ro 0:: >- "'" u.l Ul ,j; ~ > -< 0 "0 i'. V 0 c " '0 G v: 0 0... '" ~ 0 < ~ Ul " P oil f- 0 V ,2 E M V I:J ~ ~ " "'" ... ::> ci ~ ..: :>, t'- ... ~ 0 >- >- "0 " " ~ " ~ " " '" '" " ~ .ro ~ I- '0 0 u " ~ " 'n 0 CD < ~o .~ p:: J:. c;- o f- ~ oe: I- ::;; ;:;: " ~ ~ :< - ;2 ~ 5 'f :) 0 "'" ~ '.J..l 0 s "'" 6 - z ~ ell 'J ~ 0 - d U ..J 0 .2!l Z :.. -- ..J ~ ';.-.l 0 V '-' ~ ',' ~ 3 0... ~ :r. "'" ~ "" :> >, r~' ,.'- ..n'- j_:: r-' u-!~. (:2c'S .~ ('Cl ~~~ ::JJ~ (1: I () ::r <J :::t VJ -..... ~~ u... ():,::~ N {'>oj '_0 !_d o '"" C:l C;;:l c.. :.:) u ~._l\_," L1J ,......... ~w u......t. i=-:: u_ (') '-.. - - '::: '- - ;:: , ~ ~-$ ~ e --.: "t$-~ I 8 ~ ui~ l/) a f) ~ =<' "'l rg -- j --d ~ 11 ~ 3 <) ::$ ~ - ~ :y ~ .:::r C'\ ~ ("--.. --.. ~ n 5 )1 \J 0 " . ) All that eeliain tract or parcel or ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern right-ot~way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinatlcr mentioned plan of lots; thence along said dividing line n0l1h 69 degrees II minutes 20 seeollds cast] 20 tCet to a point; thence along line of Lot No. 62 s<'lIth 20 degrees 4g minutes 40 seconds cast 105 feet to the line of Lot No, 61; thence along the same south 69 degrees II minutes 20 seconds west 120 feet to the eastern right-of~way line of Kent Drive; thence along the same north 20 degrees 4g minutes 40 seconds west 105 feet to line of Lot No, 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No.2, part of section 2 , Deimlcr Manor, recorded at Plan Book 33, page 10, Cumberland County Records. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5373 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff (s) From LORETTA SYKES-LACEY (I ) You ace directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $208,589.54 L.L. $.50 Interest FROM 311105 TO 12/19/05 AT 9.2500% Atty's Comm % Atty Paid $123.44 Plaintiff Paid Date: DECEMBER 22, 2005 Due Prothy $1.00 Other Costs (Seal) 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 Joseph A. Goldbeck, Jr. Allorney LD, #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 :215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS PlaintitT vs. of Cumberland County l.ORETTA SYKES-l.ACEY Mortgagor(s) and Record Owner(s) 8 10 Kent Drive Mcchanicsburg. P A 17055 crVIL ACTION - LAW ACTION Of MORTGAGE FORECLOSURIO Dcl'cndant(s) NO, 05-5373 CIVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY l. Joseph A, Goldbeck, Jr., Esquire hereby certify that I "m the attorney of record f,x the Pl"intiff in tbis action. "nd I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. t'--' C-:i ~~ CJ Pl c-:> !'., N -0 -," t.....J W ---- (,oldbeek McCafferty & McKeever BY: Joseph ^- Goldbeck, .Ir. Attorney LD, # 16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney I"r Plaintiff r.... .. WM SPECIAl.TY MORtGAGE I.LC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN TilE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS, CIVIL ACTION - LAW LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)} 810 Kent Drive Mcchaniesburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 05-5373 CIVIl. AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC. WITHOUT RECOURSE. Plaintitlin 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 i'ollo\\,'ing inf(xmation concerning the real properly locatcd at 8 t 0 Kent Drive Mechanicsburg, P ^ \7055 l.Name and address of O\vncr(s) or Reputed Owner(s): LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg,PA 17055 2. Name and address of Defendant(s) in the judgment LORHT A SYKES-LACEY 810 Kent Drive Mechanicsburg. P A 17055 3. Name and last known address of cv'cry judgment creditor V','ho.-;c judgment is a record lien on the proper1y to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. PA 170\3 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support [nt(mement Health and Welfare Bldg. - Room 432 1',0, Box 2675 Harrishurg, I' A 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ,. ..... ........ 5. Name and address of every other person \\'110 has any record interest in or record lien on the property and whose interest may be atlccted by the sale: 6. Name and address of every olher person of whom the plaintiff has knowledge who has any record interest in the property \\hich llIay be affectL'd by lhe sale. 7. Name and address of every other person of whom the plaintitrhas knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS S I 0 Kent Drive Mcchanicsburg, P A nOS5 (attach separate sheet if more space is needed) I verify that the statements made in this at1idavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein arc made subject to the penalties of 18 Pa. C .S. Section 4904 relating to unsworn falsifICation to authorities. 'CAFFERTY & McKEEVER BY: 10,' p A, Goldbeck, Jr.. Esq. or PlainlilT DATJD: De_CC]llh~L LlJ, 21.10,2 (' () C. "'" c.> C;;.;l c,n CJ r"','\ n f'.) f'J o -n -\ i~G -;y -;~ (f'~ ""'; c.) 0) ....; -~ l~.n ':~~~ ~y) ....;:;: 05-5373 CIVIL , ,..... GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jf. Attomcy LD,#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia. P A 19106 215-627-1-,~2 .\ttnl"llcy Illl" Plallltitf WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE IN THE COURT OF COMMON PLEAS 505 City Paf.kway Wesl Suite 100 of Cumberland County Orange, CA 92868 Plaintiff CIVIL ACTION - LAW VS, LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORI;CLOSURE S I () Kent Dri\ e Mcchanicsburg, PA 17055 TCTlll No, 05-5373 CIVIL Defcndant( s TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBT:\INEI) FROM YOll WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SYKES-LACEY. LORETTA LORETTA SYKES-LACEY oS to Kent Drive Mechanicsburg. P A 17055 Your house at 810 Kent Drive, Mechanicsburg, P ^ 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 01, 2006, at 10:00 AM, in Commissioners Hearing Rm2nd FL Courthouse to enlllrcc the court judgment 01'$208.589,54 obtained by WM SPECIALTY MORTGAGE LLC, WITIIOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOIl MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1'0 prevent this Sherilr~ Sale you mu~t take immediate action: 1. The sale will be cancelled if you pay to WM SPECIALTY MORTGAGE LLC. WITHOUT RECOURS I:, the back payment~. late charge~, co~ts and rea~onable attomey'~ fees due. To find out ho\\' much you must pay call: 215-627-1322 , .'- 05-5373 CIVIL 2. You may be able to stop the sale by tiling a petition asking the Court to strike or open judgment, if the judgment was improperly entered. Y c)u may also ask the Court to postpone the sale for good cause. 3. You may also be able 10 stop the sale through other legal proceedings. Y OLl may need an attc'I11cy to assert your rights. The sooner .you contact one, the more chance you \\ill have of stopping the sa!...'. (See noti....c belmV' Oil how to obt:Jin an attomcy). 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 \vill be sold to the highest bidder. You may find out the price bid price by calling the Sheriffof 717-24()-639(), 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. J. The sale \vilJ go through only if the buyer pays the Sheriff the full amount due in lhe sale. To tind out if this has happened. you may call the Sheriff of 717-240-6390. 4. tfthe amount due from the Buyer is not paid to the Sheriff: you \vill remain the O\vner oflhe prnpcrly 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 Illay be entitled to a share of the money which \\-'as paid for your house. ^ schedule of distribution of the money bid tor your house will be tiled by the Sheriff within thirty (30) days from the date of the Sherift's Sale. This schedule \vill state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceplions (reasons why the proposed distribution is wrong) arc tiled with the Sheriff within ten (10) days after the schedule of distribution is tiled. 7. You may also have other rights and defenses. or wa)'s or getting your house back, if you act immediately uner fhe sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HA VE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OHICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 In'ine Row Carlisle, P A '7013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Cadisle. pA 17013 u:.~ 9 r--...,) {~ o;:...,? <J' CJ ." (-) N N o "n :-1 ~-"""I! n-lp' 1~~~ ~ () In (.,.) (..) GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttomeyI.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attome for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 AMQ-0584 CF: 10/14/2005 SD: 06/07/2006 $208,589.54 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) Tenn No. 05-5373 CIVIL 810 Kent Drive Mechanicsburg, PA 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: <X) Personal Service by ,lu IJhlJi6fi 'W'ii:u:'competent adult (copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs 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. ..D lit ..D ..D - ~ \ L__.. I iDume~tlc Mall Only No tllsuf,lnu' Coverage Provfded) ::r ::r c Lf'I r'I C C C c ru <0 r'I Postage S Certified Fee es ReIum _Fee (EltdorMment Required) ReetrIcted Delivery Fee (E~ntAeqUlredl Total Postage & Fe98 $ Lf'I g 0 SYKES-LACEY. LORETTA l'- ~-APt:1Q(i;uumuum--8TO'mK-~rit'--1l1""tve-u--m-.m.u-- arPOBoxNo. . 1 -, _muu.mu__m_m_m_____.~4iil_fl-l-G>&l:lJ,l.I'~.mP-.A---+... Cltr,Stats.ZJP+4 :"'!ll I i~~--l - -------t :I:!l I "'"- "!l "'"- g~+- lhl [':' h n H' ~:; g<m ~ -11' I!! g;' ~Jl! :!! = :I: " m~J ~~-- i~;1s~!~'O !l .!l.1I .l!;s s!l "- <:::. l5'ac..d ~ Z Q. :J U" u> O'C (/)0 c' Z" ~l<: w~ 1-'" - t III t f ~i ~.~ ;!] ~" B Ir UU i! 0000 ~ is i i l~ M i 8~ f ~ R I hIU j ~~~i_ ~ 00000 ~g~~ 0001ii oUQ.U ------t-- j ~ 5 z i I- lflcr: '0 ~Q. '" 1-. ~ lI)cr: ~ I-J: ~~!~~~ ~9e!2:5~ z05'-3:'- ~U'leQ..~ I...; I I T , w ~ ':lC!'" W"M ;': E" S,2~~ -'Sir ~ C I It) ..... LU. ,.... 1l..t:r:D ~ u.o:!l .;, o ~tD 0 !ZJ1i t: !:Ii!;g~",:;: ~.c::>""a.. IrU~l!;l - <('0 )(e' Q. o~ ~~~~i ..:~lBq., Q.lllJ:Q.J: N' <"i , 0 ",,,, ....00 ..,0 ~ '" CCN rn 1\\ N; ~ ~I~ Co< <.) ,~, ~ fit 1 Q; l~\ Ii 'Ib~ ~} :o~~ ~&'~ NO<C O..l.LfN(\ 0 0 :i t-- I .f \.,.; <D ..: c I I II ~ '$ '~ Ii I~ 0- J l~ . U l5"1l !~ ~~ U " f! J c o - c " e s ~ - ~ l; !: 'r: Q. Z Ul - c ;e ;B ~ o .. .5 I ... !' j Q. E 8 N- o I ~j I~ ~~ ~:J ~ ~ i ~ ~ th i ~ Ll- ,.: in lio ~ cr: 'i ~ ~ Ll- 0 0:: If ~ 9 Amo -D5?{L/ , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV ANlA WM SPECIALTY MORTGAGE LLC LORETTA SYKES-LACEY (Petitioner) Plaintiff VS. (Respondent) Defendant CASE and/or DOCKET: 05-5373 CIVIL I Declare that I am a Pennsylvania State Deputy Constable and/or Process Server, in and for the County of Montgomery, that I am not a party to this action, not an employee ofa party to this action, or an attorney to the action, and that within the boundaries of the state were service was effected, I was authorized by law to perform the said service. SERVICE UPON: LORETTA SYKES-LACEY ADDRESS: 810 KENT DR, MECHANICSBURG, PA 17055 On: I /~ S /0(, At: $Idol..... Description: Approximate Age:'trHeight: .-I"Weight:?<nRace: LSex: /h Hair:~ With the documents: NOnCE OF SHERIFF'S SALE OF REAL PROPERTY MANNER OF SERVICE By handing a copy to: o 1.) Defendant(s) personally served )Q.) Adult family member with whom said Defendant(s) reside. Name:(Yl4....C<( Ihra~" Relationship: t.f1..JI,......t o 3.) Adult in charge of de endants resIdence. Name: Relationship: 04:) Posted Property 05.) Agent or person in charge of Place of Business. Name: Title: Comments: Defendant was not served because: _Moved _Unknown No Answer _Vacant Other: Service was attempted on the following dates and times: 1.) 2.) 3.) Date: Time: Date: Time: Date: SERVER INFORMATION Time: UNIVERSAL LAWYERS' SERVICE 93 EAST MAIN ST. BAY SHORE, NY I 1706 631.666.6168 Sworn to and subscribed h. 'lr, day before me t IS ____. of ____-d~_,____ 200.f:. ~ 3700eJ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL TERESA A, MINZOLA, Notary Public wesnlngton Twp., Berks coun"ty I ,.' bet 5,.2009 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cwnberland County Plaintiff CML ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) Tenn No. 05-5373 CIVIL 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 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: 810 Kent Drive Mechanicsburg, PA 17055 l.Name and address ofOwner(s) or Reputed Owner(s): LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, P A 17055 2. Name and address ofDefendant(s) in the judgment: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, P A 17055 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 ofChiJd Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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/OCCUPANTS 810 Kent Drive Mechanicsburg, P A 17055 (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 11,2006 McCAFFERTY & McKEEVER BY: osep A. Goldbeck, Jr., Esq. Attorney for Plaintiff q ~" "',;,,. "'1J i.:t~ \lH~' -;, "~ ~\{. '/:( f:-'C) 7-'" (::.~ -~.~ ",", ~-\ -<. ';:3 ,"'" 0" ::l" ~ - a;J ~ :C:!! f>\r-:: -om '" t:t (:~~ ~2. -c -"'I i2B /..- '" ~~ ']>' ~ ...., ";If; N ., ()'\ oJ:) WM Specialty Mortgage LLC, Without recourse VS Loretta Sykes-Lacey The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5373 Civil Term Cpl. Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, states that on March 23,2006 at 7:47 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: Loretta Sykes-Lacey, by making known unto Loretta Sykes-Lacey, personally, at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 05, 2006 at 11:57 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 Loretta Sykes-Lacey located at 810 Kent 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: Loretta Sykes-Lacey by regular mail to her last known address of 81 0 Kent Dr., Mechanicsburg, P A 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 this writ is returned stayed per instructions from attorney Joseph Goldbeck. Sheriffs costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Certified mail Levy Surcharge Law Journal Patriot News Share of Bills Total: 30.00 508.88 15.00 15.00 .50 1.00 22.88 1.08 15.00 20.00 227.00 267.20 19.57 1143.11 ~ ~.sn c,'r.;tt' 6fDB8. 4 ~ '/I /8'16/0 ~~~ R. Thomas Kline, Sheriff .' , " 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 PlaintitT WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, P A 17055 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 05-5373 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 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 information concerning the real property located at: 810 Kent Drive Mechanicsburg, P A 17055 l.Name and address ofOwner(s) or Reputed Owner(s): LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, P A 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, P A 17055 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 WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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. TENANTSJOCCUP ANTS 810 Kent Drive Mechanicsburg, P A 17055 (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 unSWOIl1 falsification to authorities, DATED: December 19. 2005 05-5373 CIVIL 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 Plaintitf WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange, CA 92868 Plaintiff CIVIL ACTION - LAW vs. LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 810 Kent Drive Mechanicsburg, P A 17055 Term No. 05-5373 CIVIL 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: SYKES-LACEY, LORElTA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, P A 17055 Your house at 810 Kent Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 01,2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$208,589.54 obtained by WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 , SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, PA 17055 SOLD as the property of LORETTA SYKES-LACEY TAX PARCEL #10-17-1037-062 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5373 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff (s) From LORETTA SYKES-LACEY (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 $208,589.54 L.L. $.50 Interest FROM 3/1/05 TO 12/19/05 AT 9.2500% Atty's Corom % Atty Paid $123.44 Plaintiff Paid Date: DECEMBER 22, 2005 Due Prothy $1.00 Other Costs (Seal) 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 # 11 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 810 Kent Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 03, 2006 By: qO :/1 'V DE 330 5001 ~~~YU~OfllaFJ Ii -W3fj~nJ n1 .:103;J/.:UO Joclzt~ Real Estate Sergeant ~ ~ ~ ~ ft 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 since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ 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 S ALE #11 NOT Y PUBLIC My commission expires June 6, 2006 ~__ft -- ...~- .... '.' '".'. '. f ,.tijl" 'w .~=-'t'lk ", ,".,' .....,.,..,.-.......,...... ';D.I.JlIt 'dI , . AlL~.......... ....".....~':~& II I =Ei~,-"..:,":' ..,-- 01. Wy,' .....;....... ....il.I':s,CII....... - Ill' - feet .. .. .. " " , "'" ",,' ')) ........' '~_ilecto IIttfiAtMit.. "", " , . ~..Ut........No. :.:-~..::~-r~'-~iJ~.,-~,,1t ..... ",', CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: April 7, 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. SWO AND SUBSCRIBED before me this 21 day of April. 2006 REAL ESTATE SALE NO. 11 Writ No. 2005-5373 Civil WM Specialty Mortgage LLC, without recourse vs. Loretta Sykes-Lacey Atty.: Joseph Goldbeck All that certain tract or parcel or ground situate in Hampden Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: Beginning at a point on the east- ern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 1 1 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to the line of Lot No. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63. the place of beginning. Being all of Lot No. 62 on the Final Plan No.2. part of section 2 , Deimler Manor, recorded at Plan Book 33, page 10. Cumberland County Records.