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Home My WebLink About06-0271 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, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CNIL ACTION - LAW vs. STEVEN A. GR1FFITH TRACY L. GRIFFITH Mortgagors and Real Owners 618 W. Louther Street Carlisle, P A 17013 ACTION OF MORTGAGE FORECLOSURE Term No.OI.. -,),7/ ~t~lL JE/Ll-'Vl Defendants '~~~J '\J. ;:: r::Ct,r'~F-'Cf 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INe 8 Irvine Row Carlisle, PA 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 PERESENT ADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA 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 EST A DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMAND ANTE 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 TlENE 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 P AGARLE A UN ABOGADO, BST A OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS EUGffiLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 7] 7-243-9400 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 the following number: 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HOD'S website 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 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 AMQ-0768. Para informacion en espanol puede communi carse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. VERlFICA nON I, Nand Jimenez , 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 tme 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: H D ~o (p p,~lii6it Jl Conestoga Title Insurance Company SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Policy is described as follows: ALL the following two tracts or parcels of land situate in the Borough of Carlisle, County of Cumberland and State of Pennsyivania more particularly bounded and described as follows: TRACT ONE: On the North by West louther Street; on the East by property formerly of Mabel Grace Wheatfield, on the South by an alley; on the West by property formerly of John Linderner; Containing twenty-five (25) feet six (6( inches. more or less, in depth to said ailey on the South. TRACT TWO: On the North by West louther Street: on the West by land iate of Ida P. Apgar; on the South by a 12 foot ailey; and on the West by lands formerly of John Lindner; Containing twenty-five (25) feet in front of said West louther Street. and extending at an even width in depth one hundred twenty (120) feet tot he aforementioned alley. Parcel #50-20-1796-226 FOR INFORMATIONAL PURPOSES ONLY: Cumberland County has this property assessed as 618 West louther Street AL T A Policy Schedule C (2004080049.PFDI2004080049/42) P,~lii6it (B P.O. BOI11000 Santa Ana, CA 92711-1000 IU i IU i III II ~~ ~.AMC MORTGAGE SERVICES 7182 6389 3060 0711 3513 November 02, 2005 STEVEN A GRIFFITH TRACY L GRIFFITH 618 WEST LOUTI!ER STREET CAllLISLE. PA 11013 _I""'" ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS Oil POLICY Loan Number: Property Address: Original Lender: Current LenderlServicer: 0088985569 618 WEST LOUTHER STREET. CARLISLE PA.17013 AMC Mortgage Services, Inc. AMC Morts&ge Services, Inc. TIDS IIIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. mIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REJ'EJlIlI:D TO HEREIN AND ANY 1NJI01lMA TION OBTAlNEn PROM YOU WILL BE USED IIOR THAT PURPOSE. III YOU HA VI: PREVIOUSLY RECEIVED A DISCIIAIlGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTIllJED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT Oil A LIEN AGAINST PROPERTY. This it .. odie1a1llotice that the moma" oa yoar home isla del..l*- and the le.der ist:elld. to fotedole. SDecific information about the natare of the default II Drovided is the atuc"ed lIaHl. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (llEMAP) may he ahle to helD 10 .ave "... home. This Notice emlma. how the DI"ORram works. To oee if HEMAP CID hela. TOO mall MEET WIm A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS 01' TIlE DATI. OF THIS NOTICE. Tdtetbil Notlcewith,011 whell 'YO. D.cetwlt1t the COUllIClI.. A.caev. The n.m.. addreu ad olio.e ..u....ber of COU11Dlel' Credit Cou..telia. A_de'lem.. yoar CoulliT an listed at the cad of tills Notice. If YOU have anT aautio... YOU maT (all the PeulTlvuia HOIIsI.1l :Fiance ARcaeT toll free at 1-800-342-%397.lPeno.. with ImDalred "eamlll c.... call (717\ 780-1869). This Notice co.Was important Ie", hdonnadoa. If you have oy que.tio.s, represeatadveI at the Co......er Credit CeulllClial Aaeaey IDa,. be able to "elp esplaill it. Yo. may allO wot to coatact.. attoraey bt yo.r areL The local bar a..ociatioD may be able to help you. fi.d a lawyer. LA NOTIYICAC10N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AJlECTA SU DERECHO A CONTlNUAR VIVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIYICACION OBnNGA UNA TIlADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING IIINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO P'""""I~",,I'-'" Also doing business as Delaware AMC Mortgage Services, Inc., in the states of Texas, Rhode Island., and New Hampt'lhire. AIlIlIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDmA DEL DERECHO A REDIMIR SU HlPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE J'OR FINANCIAL ASSISTANCE WIDCH CAN SAVE YOUR HOME nOM :rOIlECLOSUllE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS I:r YOU COMPLY WITH THE PROVISIONS o:r THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT o:r 1983 (THE "ACT"), YOU MAY BE ELIGIBLE :rOR EMERGENCY MORTGAGE ASSISTANCE: , I:r YOUR nE:rAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, , III YOU HAVE A REASONABLE PROSPECT o:r BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . III YOU MEET OTHER ELlG1B1LITY IlEQUIIlEMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORAllY STAY OF FOUCLOSUIlE - Under the Act. you arc entitled to a temporary llULy offoredo6uIe on yout mortgage for thirty (30) days from the date alibis Notice. During that time you must anange and atteD.d a face-to-face DlCCUng with ODC of the consumer credit C01UlSCliDg agencies listed at the cud of this Notice. THIS MEETING MUST OCCUR W1TIIlN 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 NOTtCE CALLED "HOW TO CUlIE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -If,". meet with one of the co......' credit _ling a2CDCV liBlcd at the end of this noticc the lender maY NOT take action Bllains! you for thirtv (30) claVI after the date of this meetin2. The names. addresses and teleubonc numbers of dcsi2D8tcd consumer credit cOUDsc.mll HCDcics for the county in which the Dlooem is located are set forth at the end alibi. Notice. It is only ncccB5lllY to schedule one face-to-face meeting. Advise your lcndCT immediatelv of your intentiODJ. APPLICATION :rOR MORTGAGE ASSISTANCE - Your rnortgage is in . def&u1tfor the,.....,. sctfoIlh IoleI in this Notice (see following pages for spccif'k: iDformation about the nature of your default.) If you have tried and are unable to resolve this problCIll with the lender, you have the right to apply for fiDaDcial assilllaJ1CC 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 dcsigoatcd consumer credit counscliog agcnciellisted at the end of this Notice. Ouly consumer credit counseli1lg agcnciCl have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your applicatiou MUST be filed or postmarbd within 1hirty (30) daYI OfyOlU face-to-face meeting. YOU MUST :rILE YOUR APPLICATION PROMPTLY. III YOU:rAIL TO DO SO OR III YOU DO NOT :rOLLOW mE OTHER TIME PEIlIODS SET J'ORm IN THIS LETTEIl, :rOIlECLOSUllE MAY PROCEEn AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION J'OR MORTGAGE ASSISTANCE W1LL BE DENIED. AGENCY ACTION - Available funds fot emcrgency mortgage assistance arc very limited. They win 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 foro:Iomre procccdiugs will be pursued against you if you have met the time requirements set forth above. You wiU be notified. directly by the Pennsylvania Housing Finance Agency of its decision on your application. ..NtI~'05 November 02, 2005 Loan Number: 0088985569 NOTE: IF YOU AllJ: Cmuu:NTL Y PROTECTED BY TIIJ: JlILING 011 A PETITION IN BANKllUPTCY. THE 110LWWlNG PAIlT 011 THIS NOTICE IS POlllNllOllMAT10N PUllPOSES ONLY AND SHOULD NOT BJ: CONSIDElIED AS AN ATTJ:MPT TO COLLECT THE DEBT. (If you. have filed bu.knaptc:y you Cad ,till a.ply for Emergeaey Mort.aae Aul.naaee.) HOW TO CUKE VOUR MORTGAGE DEFAULT (BrillR it DD to date). NATURE OF THE DEF AUL T -The MORTGAGE debl by lb. &bov.lender on yonr property located at: 618 WEST LOUTIlER STREET. CARLISLE. PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and tile following amounts are now past due: 09/01105 Ibm 11/01105 at $1187.36 per moath Monthly PaymentS plus late charge or other fees: $3808.80 Total Am..at to Cure 1Ief...1t: $3808.80 B. YOU HAVl!: PAlLED TO TAKE THJ: I1OLLOWING ACTION (Do aot ...lfaotaDDIi<able), N/A HOW TO CUlIJ: THE DEPAULT --You may cur. lb. dtfaultwitbiu THIRTY (30) DAYS of th. daI. oftbi. aotic. BY PAYING TIIJ: TOTAL AMOUNT PAST DUl: TO TIIJ: LENDER, WHfCH IS 53808.80 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 monev order:made DRyable and sent to: AMC Mortgage Services 505 City Parkway West, Suite *100 Oraug.. CA 92868 You can cure any other default by taking the following action wi1hin TIIIRTY (30) DAYS of the date of this letter: (Do not use ifnot aoolicable.l N/A IF YOU DO NOT CUlIE THE DEllAULT-lfyou do 001 cure lb. default wUbiu THIRTY (30) DAYS of tile date of this Notice, the leader latelld, to eserdle it, ript, to accelerate tlte mortURe debt. This D1C8tlJ that the entire outstanding balance of this debt will be considered due immediately and you may 101C the chance to pay the mortgage in monthly inata1lmenu.. If' full payment of the total amount pail due is not made within TIflRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foree.ute UDO. Tour morblawed ~. IF THE MOllTGAGE IS 1101IECLOSED UPON -- The mortgaged property will be ..Id by the Sbcrifflo pay oft' the mortgage debt. )f the lender refers your casc to its attorneys, but you cure the delinquency bcfole the lendct begin. legal proceedings qainst you, you will still be required to pay the reasonable attorney's fees that WCIC actually incurred. u.p to $50.00. However, if 1cgal proceedings BIt started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomcy's fees will be added to the amount you owe the lender, which may also inclncle other reasonable colU.. If,.ow. ftlr'e tile clef..lt withill the TIIIllTY (30) DAY Delied.:yOll. will Rot be req.ind to pay a<<orlley', fee.. OTIIJ:ll LENDEllllEMEDlJ:S - Tb.lendcr may also su. you penoually for lb. uupaid principal balaucc .... aD other SUIIUI due under the mortgage. RIGHT TO CUlIJ: THJ: DEJ1AULT PRlOll TO SHERIFll'S SALE -- If yo. bave not cured lbe default witbiu the THIRTY (30) DAY period and foreclOiutc proceedingl have bcgu, ,.GU. still hAve the tight tn ClUe the dr5_lt and prevent the sale at any time uP to one boor before the Sheriffs Sale. You may do so bv paving the total amount then past due. plus any late or other charges then doe. rcssonable attorney'S fees and costs colUleCtcd with the foreclosure sale and any other costs connected with the Sberiff's Sale as soecified in writinJ! by the lender and bv ",,,o.ltlcm-OI performing 8DV other reauirements onder the Dtorl2&le Carml your del..lt hi tbe !PUDer set forth. is WI notice "ill renore your mortp.e to tile lame pOli:doa al if 1011 had .ever defaulted. EARLIEST POSSIBLE SRERIn"S SALE DATE -- It ill estimated that the earliest date 1bat BUch a Sheriff's Sale of the mortgaged PTopcrty could be held would be approximately (6) MONTHS from the date ofthil Notice. A notice ofthc actual date of the Sheriff's Sale will be sent to you before the sale. Of courIC, the amount neClded. to cure the default will incrCaBC the lODger 'You wait. Yau ma'Y find out at 8BY time cxactly wha11he lCQuiud payment or action will be by contacting the lendcr. HOW TO CONTACT TIlE LENDER: AMC Mortg.,e Services PO Bo'l: 11000 Santa An.. CA 92711-1000 Phone Number 800-430-S162 FIP NUdlber 7U-30f.7-S037 ED'ECT OF S1IEllD'F'S SALE - You should realize that a Sheriff's Salc will eDd your owncrship ofthc mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Salc, a lawsuit to removc you and your fumishingllUld othet belongings, could be started by the lender at any time. ASSUMPTION 011 MORTGAGE -- YOD _ mayor X- may Dot (CHECK ONE) ..n or _or,.", home to a buycr or transfcrcc who wiD assumc the mortgage debt, provided. that all the outstanding paymcnts, charge. and attomey's fees and costs are paid prior to or at the sale and. that the olber requircmcDtll of the DlOrtsa8C are Il8.tisfied. 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 TIllS DEBT. . TO HA VB TIllS DEFAULT CURED BY ANY TIIIRD PARTY ACTING ON YOUR BEHALF. . TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITlON AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEF AUL T. (HOWEVER. YOU DO NOT HA VB TIllS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LA WSillT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELmVB YOU MAY HA VB TO SUCH ACTION BY THE LENDER , TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUll COUNTY ARE ATTACHED Very Truly Y OUts, AMC Mortgage Services Cc: AMC Mortgage Services Attn: Collections Department Loan Number: 0088985569 Mailed by lit CI... M.n aDd by Certif'lCd Mall """o<'/",,_IHII . . Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of West em PA 2000 Linglestown Road Harrisburg, P A 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Wayoesboro, P A 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, P A 17110 1-800-342-2397 ".""""'"'2.'" J;:) 0 ~ 1 --- ~ ~ ~ t ~ V( .~ (9 fY! 1=: 1- '--'- r-', "'-"':'I -, .. ~^~:~) C,', ..< G . SHERIFF'S RETURN - REGULAR . CASE NO: 2006-00271 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SECIALTY MORTGAGE LLC VS GRIFFITH STEVEN A ET AL DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GRIFFITH STEVEN A the DEFENDANT at 2107:00 HOURS, on the 20th day of January 2006 at 618 W LOUTHER ST CARLISLE, PA 17013 by handing to STEVEN A GRIFFITH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.40 .00 10.00 .00 32.40 "<-:-.,. ../>X y::::O'",,// _ ,.i'_...;.~J J t R. Thomas Kline A.D. Sworn and Subscribed to before By: me this "". ),{q - day of , SHERIFF'S RETURN - REGULAR " CASE NO: 2006-00271 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SECIALTY MORTGAGE LLC VS GRIFFITH STEVEN A ET AL DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GRIFFITH TRACY L the DEFENDANT at 2107:00 HOURS, on the 20th day of January 2006 at 618 W LOUTHER STREET CARLISLE, PA 17013 by handing to STEVEN A GRIFFITH, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 .. ",. ':,.:~~,.~~ / R. Thomas Kline me this J.L €. day of 01/23/2006 GOLDBECK MCCAFFERT?JMCKEEVE~ By: Uilt l ~/, /,~n J Deput)':/Sheri i/ Sworn and Subscribed to before A.D. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, l' A 19\ 06 215-627-1322 Attomey for Plaintiff 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 STEVEN A. GRIFFITH TRACY L. GRIFFITH (Mortgagor(s) and Record owner(s)) 618 W. Louthcr Street Carlisle. PAl 70 13 ACTION OF MORTGAGE FORECLOSURE No. 06-27 \ Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, and against STEVEN A. GRIFFITH and TRACY L GRIFFITH 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$137,989.00. n ;1/J s- /dI~ Joseph ~oldbcck. Jr. Attomeyt(t Plaintiff <."j I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 and that the name(s) and last known address(cs) oflhc Defendant(s) is/are STEVEN A. GRIFFITH, 618 W. Louther Street Carlisle, P A 17013 and TRACY L. GRIFFITH, 618 W. Louther Street Carlisle, PA 17013; \ GOLD 1eCAFFFRTY & McKEEVER BY: J ;cth A. Goldbeck, Jr. Atto e:/(lf Plaintitl .. ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $124,209.29 Interest Irom OS/01/2005 through 02/2312006 $6,605.37 Reasonable Attorney's Fee $6,210.46 Late Charges $431.76 Costs of Suit and Title Search $900.00 Escrow Advance Fees Recoverable Balance Suspense $516.12 $106.00 $10.00 $1,000.00 $137,9S900 GOLDBECK BY: Josep6 Attorne~for \''''.. ,( AFFERTY & McKEEVER . Goldbeck, Jr. laintiff AND NOW, this ~aYOf ~ ,2006 damages are assessed as above. 4,-- Pro Pr . In the Court of Common Pleas of Cumberland County WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 CIty Parkway West Suite 100 Orange, CA 92R6R Plaintiff vs. STEVEN A. GRIFFITH TRACY L GRII'FITH (Mortgagor(s) and Record Owner(s)) 618 W. Louther Street Carlisle, P A 17013 No. 06-271 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 OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING TilE DEBT. Enter the Judgment in favor of PlaintitT and against STEVEN A. GRIFFITH and TRACY L GRIFI'ITH by default for want of an Answer. Assess damages as follows: $137,9R9.00 Debt Interest - 08/01/2005 to 02/23/2006 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DGE IN THE COMPLAINT AND IS CALCULABLE AS A SliM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe \Vas mailed or delivered to the pariy against whom judgment lS to be entered and to hIS attorney of record, If any. after the default occurred and.tft fast ten days pnor to the date of the filmg of tIllS praecIpe A copy of the notIce IS attached R C P 237 I -' ~/~{'L.",- ~ __ _ ~_ Joseph h Goldbeck, .If Att9rhcyjifor PlaintitT 1.1(. III 6 32 ANDNOW Y.R-..~ .:;p , ;;}/'y)fc, \,_./ ,Judgmenlis enlercdIn tavorofWM SPECIAL [.Y MORTGAGE LL(', WITHOUT RECOURSE and against STEVEN A. GRIFFITH and TRACY L GRIPFITH by default for want of an Answer and damages a~scssed in the sum of$137 ,9R9.00 s per the above cer . ~ /J ,./" , AMQ-Q768 :rms 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: February 10,2006 TO: TRACY L. GRIFFITH 618 W. Louthe, Street Carlisle, PA 17013 WM SPECIALTY MORTGAGE LLC. wrrnOUT RECOURSE 505 City Parkway w...t Suite 100 Orange, CA 92868 In the Court of Common Pl~ of Cumberland County CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs. STEVEN A. GRIFFITH TRACY L. GRIFFITH (Mortgagor(s) and Record Owner(s)) 618 w. Loulber Street Carlisle, PA 17013 Term No. 06-271 f)efendont(s) TO: TRACY L. GRIFFITH 61S W. Louther Street Carlisle, PA 17013 IMPORT ANT NOTIf'F. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO EN1'ER A WRITIEN APPEARANCE PERSONALLY OR BY ATIORNEY AND FILE IN WRITING WITH TIlE COURT YOUR DEFENSES OR OBJECflONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIlE DATE OF lHIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RlGlITS. YOU SHOULD TAKE lHIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BEWW. lHIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, lHIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 lrviue Row Carlisle, PA 17013 717-243-9400 CUMBERlAND COUNTY BAR ASSOCIATION 2 Liberty Aveuue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. AJlsxuey for Plaintiff Suite 5000 . Mellon Independence Center. 701 Market Slreet Philadelphi~ PA 19106 215-617-1322 .. AMQ-0768 ;rHIS 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: February 10,2006 TO: STEVEN A. GRIFFITH 618 W. Loutber Street Carlisle, PA 17013 WM SPECIALTY MORTGAGE u.c:, wrrnOUTRECOURSE 505 City Parkway West Suite 100 Orange. CA 92868 In the Court of Common Plcas of Cumberland County CIVlL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs. STEVEN A GRlFFITII rRACY L. GRlFFITII (Mortsasor(s) and Record Owner(s)) 618 W.l.outher Street Carlisle, PA 17013 Term No. 06-271 Defenddn1(s) TO: STEVEN A. GRIFFITII 618 W. Louther Streel Carlisle, PA 17013 IMPORT ANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALL Y.OR BY ATTORNEY AND FILE IN WRITING WI1H 1HE COURT YOUR DEFENSES OR OBJECTIONS TO 1HE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WlTIllN TEN (10) DAYS FROM 1HE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WI1HOUT A HEARING AND YOU MAY WSE YOUR PROPERTY OR 01HER IMPORTANT RlGlITS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE 1HE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WlTH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WlTH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVlCES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Car1isle, PA 17013 717-243-9400 CUMBERLAND COUNlY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 701MIllketStreel Philadelphia, PA 19106 215-627-1322 , . 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-t1ilitary 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, STEVEN A. GRIFFITH, is about unknown years of age, that Defendant's last known residence is 618 W. Louther Street, Carlisle, FA 17013, 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 othenJise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Date: Amendments. ~/'i1/ r .1, ~' ! ,/ \/\_.---- ------. '--------~----~---_._.- , /) 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 verifi.cation of Non-t1ilitary 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, TRACY L. GRIFFITH, lS about unknown years of age, that Defendant's last known residence is 618 W. Louther Street, Carlisle, Pll, 17013, and lS 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 othenvise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Date: Amendments, , \I -JjL------------ [j (; -p ~ ~ - - ~ :e. ~ t III ,... F o .v;,. \~ ~ Q ~ ~ 6J ."~ .., . . -"I", -3 'i~,~\ -, 1 r ") C~' , c,', c'''! '::..i. r , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Je. Attamey 1.0.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-\322 Attamey lor Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintilf VS. CIVIL ACTION. LAW STEVEN A. GRIFFITH TRACY L. GRIFFITH Mortgagor(s) and Record Owner(s) 618 W. Louther Street Carlisle, PAl 70 13 ACTION OF MORTGAGE FORECLOSURE No. 06-271 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO TIlE PROTHONOTARY: Issue \Vrit of Execution in the above matter: Amount Due $137,989.00 Interest from 08/01/2005 to 02/23/2006 at 9.2500%1 (Casts to be added) GOLDBECI<; cCAFFERTY & McKEEVER BY: .loseplyA. old beck, .If. Attorney ~r Pl intiff ~/ t \' t ~ G ~, + ]d0 \\:-'i - \.J ~ ~ ~ 4 -~ ~~ VJ \) ~ () (--~ ) -"I- --- Lv \:> , ..z: Q \ ::: - - 'iocI- lJ.;- ~ --0 tJ, -; ),) l!1 -<I"/C'V1 t; 1:: Q CCCQO\) \ \ I \ \ -cJ _:::--~\?~ ~ 1- -~~:~ .. ,-, ,J c'} -r': en <'( "" ".l 0- ~ o ~ ~~ E ~ 8 " 0-0 ... f- .0 o z~ ;;;> o u "" :!: ,... ~ f- ;::J o :r: ,... ~ u -' -' u.lu.l 0", 0P< f-:J . 0 "'"u Ou.l :;iO"," ~ f- -' -< iJ u.l a.. if; :;iO :::: .f. ~ ~ ~, ""d t " " ":r: i$ ~ ::t.r 0 ~ r<1 f-<G:-o;:- t:i::~""f./JO \.l.., -< 0 I-< r-- .......0::.:..11)....... "'"o~-B-< o . '"O;:j c... <.....l ~.3 0 -< '>-' c:1 . c2 zu'?3;=: u..l<\::' 'a >~?~U ~ l-' 'gp-c f- B' if; ~ o :;iO z o - ,... ;;;> u ~'E "" a ",,,, o ~ ,... ;; -'" ;>: " ~ " o ... "" 0- W u.l <'( " 0- ~~ "" ~ 'J .8 u " ,D- ."P- o ~ v ...8 , >-, -< " .D to ,,"0 "to -J) <( ..s . ~ l' ... " ~ v ~() '" ',J. t :.J!=: '-0 _Q) G '?-. --g I]) 0' ~ g.g~~1 ,c' 0 ~ 'n o v o 'S if; ALL the following two tracts or parcels of\and situate in the Borough of Carlisle, County of Cumberland and State of Pennsylvania more particularly bounded and described as tallows: TRACT ONE: On the North by West Louthcr Street; on the East by property fonnerly of Mabel Grace Wheatfield, on the South by an alley; on the West by property fonnerly of John Linderncr; Containing twenty- five (25) teet six (6) inches, more or less, in depth to said alley on the South. TRACT TWO: On the North by west Louthcr Street; on the West by land late of Ida P. Apgar: on the South By a 12 toot Alley; and on the West by lands formerly of John Lindner; Containing twenty-five (25) teet in front of said West Louther Street, and extending at an even width in depth onc hundred twenty (120) feet to the aforementioned alley. Parcel #50-20-1796-226 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-271 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 STEVEN A. GRIFFITH AND TRACY L. GRIFFITH (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 tho 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) Ifproperly 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 $137,989.00 luterest FROM 8/1105 TO 2/23/06 AT 9.2500% LL $.50 Atty's Conun % Due Prothy $1.00 Other Costs Atty Paid $130.40 PlaintifIPaid Date: FEBRUARY 28, 2006 (Seal) l':;;;//J ~tlltC-~d Pr honotary / i~ By: " Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Jef:'eph l'IIoGoldbeck, 1r. Attomcy J.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attomey for Plaintiff 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 STEVEN A. GRIFFITH TRACY L. GRIFFITH (Morlgagor(s) and Record Owner(s)) 618 W. Louther Street Carlisle, P A 17013 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-271 AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintitfin 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 conceming the real property located at: 618 W. Louther Street Carlisle, PA 17013 l.Name and address of Owner(s) or Reputed Owner(s): STEVEN A GRIfFITH 618 W. Louther Street Carlisle, P A 17013 TRACY L GRIFFITH 618 W. Louther Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: STEVEN A GRIffiTH 6 I 8 W. Louther Street Carlisle, P ^ 17013 TRACY L GRIFFITH 6 I R VV. Louther Street Carlisle, P A \7013 3. Name and last kllO\vn 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 or PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DlCKINSON COLLEGE West Street, PO Box 1775 Carlisle, Pa 17013 4. Name and address of the last recorded holder of every mortgage ofrecorcl: RICHARD B. STEFFY 346 Veterans Way Elliotsburg. Pa 17024 DANA H. STEFFY 346 Veterans Way Elloitsburg , Pa 17024 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 affecled by the sale. TENANTS/OCCUPANTS 61 R W. Louther Street Carlisle, P A 17013 (attach separate sheet if more space is needed) t 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: February 23. 2006 /', i i j " ,-.----::::. l GOLDBECj< Me 'AFFERTY & McKEEVER BY: losep>!. . Goldbeck, lr., Esq. Attorney ('or laintitT ""'1-: f',1 C ' . , 06-271 "' 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 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 YS. STEVEN A. GRIFFITH TRACY L. GRIFFITH Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 618 W. Louther Street Carlisle, PA 17013 Term No. 06-271 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 VSED FOR THAT PURPOSE. NOTICE OF SHERin'S SALE OF REAL PROPERTY TO: GRIFFITH. STEVEN A. STEVEN A. GRIFFITH 61X W. Louther Street Carlisle, P A 170 \ 3 Your house at 618 W. Louther Street, Carlisle, P A 170] 3 is scheduled to be sold at Sheriffs Sale on Wednesday, June 07. 2006, at lO:OO AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce Ihe court judgment of$137.9X9.00 obtained by WM SPECIALTY MORTGAGE I.LC. WITHOUT RECOURSE against you. "'OTICE OF OWNER'S RIGHTS YOV MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sherifrs Sale you must take !rrtl11cdiale ac;tion: 1. The sale will be cancelled if you pay to WM SPI.ClALTY MORTGAGE LI.C. WITHOUT RECOURSL the back payments, late charges, costs and reasonable attomey's fees due. To find out how much you must pay call: 215-6-27-1322 . . . 06-271 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. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to slop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you \vill have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOVR PROPERTY AND YOV HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sherit1's Sale is not stopped, your property will be sold to the highest bidder. You may lind out the price bid price by calling the Sheriff 01'717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price \vas 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 01'717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff~ you will remain the ov/Oer of the property as if the sale never happened. S. 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. ^ schedule of distribution of the money bid for your house will be liIed hy the Sheriff within thirty (30) days Ii-om the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money \vill be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) arc tiled with the ShcritY within ten (10) days after the schedule of distribution is tiled. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOUl.D 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 1NC 8 Irvine RO\v Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 170t3 ~-'.-" c (,.,'; ".-:- ...... ------ 06-271 . GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck,.lr. Attorney 1.0.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney tor Plaintitl 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. STEVEN A. GRIFFITH TRACY L. GRIFFITH Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 618 W. Louther Street Carlisle, P A 17013 Tern1 No. 06-271 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 lISED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GRIFF1TH. TRACY L TRACY L. GRIFFITH 61 X W. Louther Street Carlisle, P A 171J 13 Your hou~e at 6\ g W. Louther Street, Carlisle, P ^ 170 (3 is scheduled to be sold at ShcrifTs Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL ('ourthouse to enforce the eOllrtjlldgmcnt of $137,9R9.00 obtained by WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU !VIA Y BE ABLE TO PREVE:'oIT TillS SHERIFF'S SALE To prevent this SheritTs Sale you must take immediate actiotr I. The sale will be cancelled ifyoll pay to WM SPECIAI.TY MORTGACiI. L1 C. WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attomey's fees due. To t1nd out hO\v much YOLl must pay call: 215-6?7-1322 06-271 . . 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. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop Ihe sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you \vill have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOV HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sherin's Sale is not stopped, your property will be sold to the highesll bidder. You may find out thc price bid price by calling the Sheriff 0!'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 oul if Ihis has happened, you may call1he Sheriff 01'717-240-6390. 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. Y Oil have a right to remain in the property until the full amount due is paid to the ShcrifT 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 1iled by the Sheriff within thirty (30) days Irom 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) arc tiled with the Sheriff within ten (10) days atier the schedule of distribution is tiled. 7. You may also have other rights and defenses. or \vays of gctting your house back, if you act immediately aftcr the sale. YOU SHOULD TAKE T[lIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VI: 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 1NC 8 Irvine RO\v Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. P A 17013 -~ ( C,) ....,) GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 AMQ-0768 CF: 01/11/2006 SD: 06/07/2006 $137,989.00 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE STEVEN A. GRIFFITH TRACY L. GRIFFITH Mortgagor(s) and Record Owner(s) Term No. 06-271 618 W. Louther Street Carlisle, P A 17013 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: I ,J . "'~V@So ~~ 3/fB/o, ()() Personal Service by the Sheriffs Office/~teRt Adttlt (8~YJ vf l~tlJl1 &*lIkid). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. g'cv ~ =5~ ~ c; '0. c ~ ,lE8 -~u J: 'iij - '0'- a.<<lE~ 16[13 El:l'O~~~~ .e"OS:g~ co....... U)~l'l<<l EO xrJ)~r-.~"""Q) ~.~:e.g:; en_ <(~2l 0'0 ~~ ~ ~ o :.0 ii ffi c ~ -$ ~ c: e. ~g ~ ~ ~ ~ Ci'€ ~~8 al~o::~ "E!E~ ~ 'g> ~ a, 0::0::0::U5 DODD Qi u .~ III c .2 n; E "" c= "ffi (3 ~ E al ~::l'C '0 € 0 .~ ~ ~ ~ ~8~~~ ~ "" U .r: U (; DDDDD a; -g .... ~ ltl<e '0 a::1l. ~ t;~ -* 1- J: ~~OWIl.C'l Uo~..J(") -gWOa::Wlt) rolOlt)<eO..... <l>EOW:E<e<o ..J.... ..JO roO-.....-..... 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III > .;: Q. Q) Q) en e r:o l"- I"- r:o rrI e e OFFICIAL Postage $ 0 . 8 7 USE ru Cel1llled Fee e Yes e , Return ReceIpt Fee Yes \', PoatmaJ1c e (Enc:Ior8ement Recjulred) Here e Reatrtcted De!!veIY Fee r-'l (E~ Requlnld) r-'l 5. 12 rrI Total PlIlllIIge & Feee $ LI"l c::J e I"- -<:t I !::: u. u. USE ~ <.9 .J Postage $ >- ru es 0 Cerl1lled Fee ~ e Po8tJlIa/tl . e Relum R~ Fee .... e Here (Endcll8ement Recjulred) o<:l e ReelJlaled DeIIwIy Fee I r-'l (EncIorIIement ReqUired) !::: r-'l u. rrI 1btaI Poldage & Feee $ u. 0:: LI"l <.9 c::J e w I- en .. " GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-825-6320 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 Cumberland County Plaintiff CNIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE STEVEN A. GRIFFITH TRACY L. GRIFFITH Mortgagor(s) and Record Owner(s) Term No. 06-271 618 W. Louther Street Carlisle, P A 17013 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 information concerning the real property located at: 618 W. Louther Street Carlisle, P A 17013 l.Name and address ofOwner(s) or Reputed Owner(s): STEVEN A. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 TRACY L. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 2. Name and address ofDefendant(s) in the judgment: STEVEN A. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 TRACY L. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 . . 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, 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 DICKINSON COLLEGE West Street, PO Box 1775 Carlisle, Pa 17013 4. Name and address of the last recorded holder of every mortgage of record: RICHARD B. STEFFY 346 Veterans Way Elliotsburg, Pa 17024 DANA H. STEFFY 346 Veterans Way Elloitsburg , Pa 17024 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 618 W. Louther Street Carlisle, P A 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my 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 16, 2006 C? ~, I'-..;) = <::::I C1' o -n ~-n rnp: -orn -nO ~. i <~U :'c '~~1 ~o ;'')rTI ~-I ~ ~ ::= ~\y... -< N N -0 ::il,: C:.~ N + GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELA WARE CORPORATION 9451 Corbin Avenue Northridge, CA 91324 WM-0682 CF: 01112/2006 SD: 06/07/2006 $118,141.16 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE RACHEL MUKORA Mortgagor(s) and Record Owner(s) Term No. 06-288 4706 Delbrook Road Mechanicsburg, P A 17050 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 Sheriffs Office/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). ( ) r~ ( ) ( ) 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. .JJ .JJ l"- I"- ~ ITI CJ CJ ru CJ CJ CJ CJ r-9 r-9 ITI U S Post<ll Service CERTIFIED MAIL.. RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) o 0" 0 0 0 "0 0 0 I OFFICIAL USE I Postage $ 0.87 CeI1IIIed Fee Yes Postmark Rtftum Receipt Fee Yes Here (Endoreement Recjulnld) R8lIlrIcI8d Dellvely Fee (El1dor8fment Required) . $ 5012 Total Postage & Fees LI'1 l:J CJ I"- .., . Complete items.1, 2, and 3:A1so complete item 4.)f Restricted Delivery Is desired. . Print your name and address on the 1'8Vers8 so that we can return the card to you. . Attach this card to the back of the mallplece, or on the front If space pennits. 1. Article AddI8SS8d to: WM-0882 817108 MUKORA, RACHEL 1225 Rolleaton Street Ham.burg, PA 17104 3. ServIce lyPe ~ Certified Mall 0 ExpI'888 Mall tJ Registered 0 Return ReceIpt for Merchandise o Insured Mall 0 C.O.D. 4. ReetrIcted DelIYery? (&tra Fee) 0 Yes 2. Article Number mw-w from......... PS Form 3811, F*'-Y 2004 1!""~wm~'I! 00InIMk: RlItum AeceIpt l02595-02-M-l540 . Complete ltems.1, 2, and 3. Also complete item 411 Restricted Delivery Is desired. · Print your name and address on the reverse so that we OM return the card to you. . Attach this cardlo the back of the mallplece, or on the front If space pennits. 1. ~~_/06 o Agent o Addressee C. Date of Delivery . 'lo.00 D. Is delivery addnles dIIr8rent from Item 1? 0 Yes If YES, enter delivery address below: 0 No MUKORA, RACHEL 4706 DELBROOK ROAD MECHANICSBURG, PA 17050 3. ServIce lyPe II CertIfIed M811 0 exp,.. Mall o RegIater8d 0 Return Receipt for Merchandise o Insured Mall tJ C.O.D. 4. ReetrIcted DelIYery? (&tra Fee) 2. Article Nlmber (1hInsfer from semee label) PS Form 3811 , February 2004 *70053110000200387766* ~ Return Reoelpt 102595-02-M-1540 0:: ill O::u. Clill O::u. :I: ill cnu. uill cnu. uill ClU. ~Cl (1)0 cnU (1)- :J .- Cl - al(l) 5.2 ~~ (l)U >- :l f!? 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E o () N '0 N co <0 o , ~ s: ~ o ~ => ~ ...J W I () ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-825-6320 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELA WARE CORPORATION 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. RACHEL MUKORA Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 4706 Delbrook Road Mechanicsburg, P A 17050 Term No. 06-288 Defendant( s) AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, A DELA WARE CORPORATION, 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: 4706 Delbrook Road Mechanicsburg, P A 17050 l.Name and address ofOwner(s) or Reputed Owner(s): RACHEL MUKORA 1225 Rolleston Street Harrisburg, P A 17104 2. Name and address ofDefendant(s) in the judgment: RACHEL MUKORA 1225 Rolleston Street Harrisburg, PA 17104 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DISCOVER BANK. AWAITING ADDRESS 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 4. Name and address of the last recorded holder of every mortgage of record: LONG BEACH MORTGAGE COMPANY 1409 South Douglass Rd. Suite 100 Anaheim, Ca 92806 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. TENANT~OCCUPANTS 4706 Delbrook Road Mechanicsburg, P A 17050 (attach separate sheet ifmore 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 17,2006 2 r---) = 0 = <.-:0' c:T' "T1 r:'; ::n: ~:n ~ -< N -ofTl N :uCi ~-... i ""'8 '_;J S? -Y'~ r';:': -r1 -a. .,,-!. ,-) w 8m :-1 ::( N ?D v.) .< '" GOLDBECK McCAFFERTY & McKEEVER' BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIAL TV MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange. CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. STEVEN A. GRIFFITH TRACY L. GRIFFITH (Mortgagor(s) and Record owner(s)) 618 W. Louther Street Carlisle. PA 17013 No. 06-271 PRABCIn TO VACA'l'l!: JUDGMEN'l' TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only, :JIt~ JOSEPH A. GOLDBECK, JR., ESQUIRE x:> ~ ~ ~ ,...0 ,,~:) ~ D '7;:) 0.... 0. L_ ,~."'-~ ~ ,- p:? 1 ........ F:: c_r; ~ .. "() D -.;--" ..0 12 6"- - f'.J ..:..a ~ C.,I . " GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr, . Attorney I.D, #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 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 Cumberland County Plaintiff vs. STEVEN A. GRIFFITH TRACY L. GRIFFITH (Mortgagor(s) and Record owner(s)) 618 W, Louther Street Carlisle, P A 17013 No. 06-271 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. fJIr~ JOSEPH A. GOLDBECK, JR, ESQUIRE C) ~n c,;;;:. \~..: \ 0\ .-;:':\ _... --' c:? (',) C-=I WM Specialty Mortgage LLC without recourse VS Steven A. Griffith and Tracy L. Griffith In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-271 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 08,2006 at 2:35 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Steven A. Griffith and Tracy L. Griffith, by making known unto Steven A. Griffith, personally and husband of Tracy L. Griffith, at 618 West Louther Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 06, 2006 at 7:54 o'clock P.M., he posted a true copy ofthe within Real Estate Writ, Notice, . Poster and Description, in the above entitled action, upon the property of Steven A. Griffith and Tracy L. Griffith located at 618 West Louther Street, Carlisle, 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 defendants, to wit: Steven A. Griffith and Tracy L. Griffith by regular mail to their last known address of 618 West Louther Street, Carlisle, PA 17013. These letters were mailed under the date of April 06, 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 Postpone Sale Law J oumal Patriot News Share of Bills 30.00 226.22 30.00 30.00 0.50 1.00 8.80 1.63 30.00 40.00 20.00 233.00 206.00 19.57 876.72 .,/ 9- ? jlJl!;/bG ,. Total: J() 'f'1.b ~l{(,'JO ~.) ~ j11 q/{V So Answers: <~~~~ R. Thomas Kline, Sheriff B~~lbl Real Estate ergeant ~ 4 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for PlaintifT 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 STEVEN A. GRIFFITH TRACY L. GRIFFITH (Mortgagor(s) and Record Owner(s)) 618 W. Louther Street Carlisle, PAl 7013 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-271 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: 618 W. Louther Street Carlisle, P A 17013 I.Name and address of Owner(s) or Reputed Owner(s): STEVEN A. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 TRACY L. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 2. Name and address of Defendant(s) in the judgment: STEVEN A. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 TRACY L. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 ,: f 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, P A 17105-2675 DICKINSON COLLEGE West Street, PO Box 1775 Carlisle, Pa 17013 4. Name and address of the last recorded holder of every mortgage of record: RICHARD B. STEFFY 346 Veterans Way Elliotsburg, Pa 17024 DANA H. STEFFY 346 Veterans Way Elloitsburg , Pa 17024 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/occur ANTS 618 W. Louther Street Carlisle, P A 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my 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: February 23,2006 ., 06-271 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 Attomey for Plaintiff 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. STEVEN A. GRIFFITH TRACY L GRIFFITH Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 618 W. Louther Street Carlisle, PA 17013 Term No. 06-271 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: GRIFFITH, TRACY L TRACY L. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 Your house at 618 W. Louther Street, Carlisle, P A 17013 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$137,989.00 obtained by WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 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: I. 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 , 06-271 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 Sherift~ 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 LA WYER 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 ASSOCIA nON 2 Liberty Avenue Carlisle, PAl 70 13 06-271 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 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. STEVEN A GRIFFITH TRACY L. GRIFFITH Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 618 W. Louther Street Carlisle, PAl 7013 Tem1 No. 06-271 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: GRIFFITH, STEVEN A. STEVEN A. GRIFFITH 618 W. Louther Street Carlisle, P A 17013 Your house at 618 W. Louther Street, Carlisle, P A 17013 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$137,989.00 obtained by WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's 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 06-271 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 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. 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 LA WYER 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, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, PAl 70 13 ALL the following two tracts or parcels of land situate in the Borough of Carlisle, County of Cumberland and State of Pennsylvania more particularly bounded and described as follows: TRACT ONE: On the North by West Louther Street; on the East by property formerly of Mabel Grace Wheatfield, on the South by an alley; on the West by property formerly of John Lindemer; Containing twenty-five (25) feet six (6) inches, more or less, in depth to said alley on the South. TRACT TWO: On the North by west Louther Street; on the West by land late ofIda P. Apgar: on the South By a 12 foot Alley; and on the West by lands formerly of John Lindner; Containing twenty- five (25) feet in front of said West Louther Street, and extending at an even width in depth one hundred twenty (120) feet to the aforementioned alley. Parcel #50-20-1796-226 WRIT OF EXECUllION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-271 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 STEVEN A. GRIFFITH AND TRACY L. GRIFFITH (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $137,989.00 Interest FROM 8/1/05 TO 2/23/06 AT 9.2500% L.L. $.50 Atty's Comm % Atty Paid $130.40 Plaintiff Paid Due Prothy $1.00 Other Costs Date: FEBRUARY 28, 2006 (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 e!!S ~ c:::::a ~ ~ ~ Real Estate Sale # 65 On March 06, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A Known and numbered as 618 West Louther Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 06,2006 By: L t] :01 "\I Z - MVW qOOl Vd 'AlilliUJ m~ 'J 'Iti38~nJ ,j3IH3HS 3Hl .:10 3313--10 \fD~~ Real Estate Sergeant " 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 S ALE #65 ~.~.,.,...... .. No.. :... I !!1~. cr:....... . -~ . . LLC tIIIIOut_ va ' -. A.........1tiIcy L ... . ~ ........ GotIIIIet* I'B1tRPIiuN AIL die ~ Iwo.... CIl' pIIlleIs ofllacl ... it de- .........clt Carliale, COlIIlIy of ~t 'f f8llll .. of PeaIsyMaia IIICll;e J*ii:aIIdy ~ lildclesaibed u CuIbis: . mACl' <M - tie NcIIb by West f.DIldIr:r SInd; -. .. bypllpClty a.ty<< MaIJcl ~~_.... byallfey;<lLdIe ..v~ ~""..of loIII ~ CaiIIiIiIc ~. ~ '.,. '. ,.(2S).' filet. (6) iIdaes, IIICll;eCll' .dlIpdaIoAill6y"~bIh. 11tACT .. .. .... ~ by WestltJadler SInd; -.~'" W., ~IdaP.App:.. . byl 12lilcJt AIIe;;. .. _ die West by ~. of .1aIt .LiIlII!r:r; . . Q$) _._CitSaif NOT PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , l 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: 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. SWORN TO AND SUBSCRIBED before me this 21 day of April. 2006 SEAL LOIS E. SNYDER, Notary Public Carlisle Bora, Cumberland County My Commission Expires March 5, 2009 R&AL _TATE 8AL& NO. 85 Writ No. 2006-271 Civil WM Specialty Mortgage LLC without recourse vs. Steven A. Griffith and Tracy L. Griffith Atty.: Joseph Goldbeck ALL the following two tracts or parcels of land situate in the Bor- ough of Carlisle, County of Cumberland and State of Pennsyl- vania more particularly bounded and described as follows: TRACT ONE: On the North by West Louther Street; on the East by property formerly of Mabel Grace Wheatfield, on the South by an al- ley; on the West by property for- merly of John Lindemer; Contain- ing twenty-five (25) feet six (6) inches, more or less, in depth to said alley on the South. TRACT 1W0: On the North by west Louther Street; on the West by land late of Ida P. Apgar: on the South Bya 12 foot Alley; and on the West by lands formerly of John Lindner; Containing twenty-five (25) feet in front of said West Louther Street, and extending at an even width in depth one hundred twenty (120) feet to the aforementioned alley, Parcel #50-20-1796-226.