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HomeMy WebLinkAbout06-0288 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.GOLOBECKLAW.COM ATTORNEY FOR PLAINTIFF LONG BEACH MORTGAGE COMPANY, ADELA 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 and Real Owner 4706 Delbrook Road Mechanicsburg, P A 17050 ACTION OF MORTGAGE FORECLOSURE (:iVP i< ~ " (\ i~' "J'Jy~). Fn'('~ :,'" ...... ~- - .. ~ . -'rerm'" ' -, .....J, '0-" h0f'lfCIQ.R1iN<f. NOT ICE 01.. -- .;2pf' Ciu I:LT ffl.rvJ 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, P A 17013 AVISO LE HAN DEMAND ADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. 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 EST A DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORT ANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FlJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. S] USTED NO PUEDE P AGARLE A UN ABOGADO, EST A OFICINA PUEDE PROVEERE ]NFORMAC]ON ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 7] 7-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call the following number: 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 866-926-8937 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 WM-0682. Para informacion en espanol puede communicarse con Loretta a] 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORlGCLOSURE 1. Plaintiffis LONG BEACH MORTGAGE COMPANY, ADELA W ARE CORPORATION, 9451 Corbin Avenue, Northridge, CA 91324. 2. The name and address ofthe Defendant is RACHEL MUKORA' 4706 Delbrook Road, Mechanicsburg, P A 17050, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On April 18,2005 mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to LONG BEACH MORTGAGE COMPANY, ADELA W ARE CORPORA nON, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1904, Page 3436. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1 019(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 prindpal and interest are due and unpaid for August 01, 2005, and each month thereafter and by the terms of the 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 07/01/2005 through 01/31/2006 at 8.9300% Per Diem interest rate at $25.42 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 08/01/2005 to 01/31/2006 Monthly late charge amount at $49.89 Costs of suit and Title Search Escrow Advance Fees $103,884.27 $5,465.30 $5,194.21 $349.23 $900.00 $1,621.00 $92.60 $117,506.61 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. Plaintiffreserves 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 ifthe complexity of the action requires additional fees in excess ofthe 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-llstablish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. .9. Notice oflntention 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, on the date( s) set forth in the true and correct copy of such notice( s) attached hereto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency. or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $117,506.61, together with interest at the rate of $25.42, 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 Sheriffs Sale of the Property. By: . t} h :1 I~ UC , (k(j)h~f/G DB K McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATIORNEY FOR PLAINTIFF VERIFICATION I. CASSANDRA INOUYE as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn fa1sification to authorities. Date: 12 hlflcS LONG B H MORTGAGE COMPANY, A DELAWARE CORPORATION #0695239640 - RACHEL MUKORA <~.__.-- CE:{lii6it Jl Exhibit "A!' F" No. 01411 AJ..L TlL\T CEllTAlN .- or p...... otlad "WI 11Io bddDjp,.......- _. ......... _la ............ T........ eo_d CClaaty, Peauy....... .ad __ .-a to....., _lIy _I. B.... JI.pt.... 81U'W&)Vr, dated 1'f.......10, 19'n, u I'IIIIowI, to wit: IlEGII'fNlNG ot . lllb .. tit. _Ill _ of Dd-B1'OOk _ (I' fed -l, lit .. COllIer otl.ol 1'1'.. 3, ..... .... .....1 _..... ...... Ill. uIOl _ 01 DoWlraok ..... 249M feet Witt ofllle ...tIt..., _ of Dd-B......Il<.... ad St Morlt'. Road; -.. _dba, tnlao _ .....' of ........., ODd 110I" 110. d_ Oa. _ Loa 3 ... 4!1D111b 23...... 00 __ But 11Io __ of 130 feet I. . bab at 11Io ......... of..... _ or _If of BaX 1lHIIy; _'0' .....'...010.... .,.. fDnDerty otllAKlleIIly80llllo.f'1......... __ Weal I:llo_ of6S feet '0 . .... at 110. ......or of Lot No. 5; 110.... aIo., tho dMcIIallla. b_ lAD 4 ftd 5 1'1'_ 23 ....... 01 ...._ Wut'" _ of 130 lOot to . 'ab ., 11Io co...or of LoI No. 5; ....... aIoII1J ... d/fIlIIR. Ibl. ..__ Lol. 4 ODd 5 1'1'_ 23 d....- 00 _.110I WOOC ... ......... oll3O root.. . bb .. ~.. oaId _ of DoJ. Bro_ Road; -.. _. _ ,ide ofJ)ol.Brook Road Nor1ll67 dear- 00__ Eut lb. dto_.. ole _ to . ....... ......... ofBJ:G1JlINING. BJ:ING Lot No. 4.. tII. PIa oUt. )\Iork'. ...... ....onIod .. Pltlll - ......... BEING _. uNo. 4106 Dd-Brook Rood. UNDER AND SUBJ'ECT. NEVER,11IELESS. to ellle....u. nlll"letloM. ......lloa., 0"'__'" riPlI ofwrrof_ .I!ING TIlE eAIIll'REIIlIP....1dI BONrrE LLC, APAL_ LlMIUTYCOOlPMY.., DMddaWd.cttMIIPd~farb.liII .. ~n-..&.In"'OIIIot"~~of _1n_forC_..._.,.,...................,_...,w__ IlUl<IlRA, NI-.a.T 1Nll1Va>UAL.~",""''' 1 Certify"" ". ," P. InCumh," ....,. J \ ~/ ~ .. )'~~ .. i,......... _.. ..\ ~.h':;"ds !)(HIBIT A TO MORTGM" OK 1904f'G;Jl;43 CE,:{lii6it (B Washington Mutual PO Box 2441 Mailstop NOl0207 Chatsworth, CA 91313-2441 0695239640 October 17, 2005 #BWNCLNN# #0906959239964093# 001108 t?A RACHEL MUKORA 4706 DELBROOK RD MECHANI5BURG PA 17050 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0695239640 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the morti~e on your home is in default and the lender intends to foreclo'ie Specific information ahout the nature of rhe default is provided in the attached 1>3.ie5 The HOMEOWNER'S MORTGAGE ASSISTANCE PROnRAM (I-IEMAP) may be ahle to hl'lp to save your home This Notice exnlains how the ome-rarn worh To see if I-lEMAP can help you mllst MFRT WITH A CONSUMER C.REDIT r:OlJNSELlNG AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTIr.E Take this Notice with you when you meet with the C:ounselinl!: Al!'ency. The name addreo>s and nhone numher of Consumer C.re.dit C:ounselini Allencies servinv your Connty are listed at the end of this Notice If you have any questions you may call the Pennsylvania HonsiI'li Finance Apmr:y toll free at 1.800~342-23Q7 (Persons with imn;tired hearin~ can call (717) 7RO~lR(j9) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DER1OCHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCClON INMEDlTAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCV) SIN CARGOS AL NUMERO MENClONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HlPOTECA. Spqqg HOMEOWNER'S NAME(S): Rachel Mukora LOAN ACCT. NUMBER: ORIGINAL LENDER: CURRENT LENDERISERVICER: 4706 Delbrook Rd Mechanicsburg P A 17050 0695239640 Lbm Washington Mutual Bank PROPERTY ADDRESS: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TF.MPORA.RY STAY OF FORRCLOS1JRE ~ Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-ta-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MRETING MUST OCClTR WITHIN THE NEXT (30) 01\ YS IF YOU DO NOT APPLY FOR EMERGFNCY MORTGAGE ASSISTANC:E YOU MOST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CAl I ED "HOW TO CORE ynOR MORTGAGE OFFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE OF TO DATE. rON~IJMRR r.RRDlT COUNSF..UNG ,o\GF.N~lF.S - 1f yOll meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days a.fter the date of this meeting. The names addre~<;e" :lnd telephone numhers of desi>mateo consumer credit cOllnselin~ al?encies for the county in which the property is lor-:ated are set forth at the end of this Notice It is only necessary to schedule one face-to~face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGF. ASS1STANCR - Your mortgage is in default for the reaso:ns set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried a.nd are unable to resolve this problem with the lender, you have the tight to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applica.tions for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Ag,mcy. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ArTION ~ Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE, IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) 001108/SP999 HOW TO CURE YOUR MORTGAGE DEFAULT lBriol!' it uO to date). NA.TIJRE OF TAR DEFAULT ~ The MORTGAGE debt held by the above lender on your property located at: 4706 Oelbrook Rd Mechanicsburg P A 17050 IS SERIOUSLY IN DEFAULT BECAUSE: Non~payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due; Monthly Installments: 0810 112005 09/0112005 10/0112005 $831.58 $831.58 $831.58 Other charges (explain/itemize): Uncollected Late Charges UncoUected Fees; Corporate advances Less Credits TOTAL AMOUNT PAST DUE: $199.56 $26.70 $0.00 $0.00 $2721.00 B. YOU HA VB FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CURE THE DEFAllLT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER. WHICH IS $2721.00. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payment!'. roB!'.t be m:\de ehher by ca...h cashier's check certified check or mnnev order made payable and sent to' Washington Mutual Bank 9451 Corbin Avenue Northridge, CA 91324 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter; (Not applicable): IF YOlT DO NOT rlTRR THE DRF A lJL T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exprcise its rivhts to accelerate the mn-rtiZave debt This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to forerlose IIpon vOllr mort2a2cd nropertv. *JF THF. MORTGAr..E IS FORRCLOSRD ITPON The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed SSO.OO. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If.J'01I rllre the default within the THIRTY (3m DA Y nedod. vou will not he required to Dav attorney's fees. OTHRR LENDER RRMEnIF.S - The lender may also sue you personally for the upaid principal balance and all other sums due under the mor\gage. Spg'lY RIGHT TO ~URE THE DF.FAIII,T PRIOR TO !'lHF.RTFF'S SALE~ If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you maY still have the risft1t to cure the default aJ1d prevertt the sale at any time up to ooe hour hE-fore the Sheriff's Sale Yon maY do so by pavioi th~ total amount then pa'll due plus any late or other chaq::e<io then dul' reasonable attorney's fees :md costs connected -...v1th the foreclosure sale and any other costs c.onnected with the Sherifr.. Sale a<; ..necified in writine: hv the lender and bv oerforminl! any other iE'.qJllreme-nts under the mort~l!e Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you nad never defaulted. EARl.1EST POSSIBLE !'lHERIFF'S ~ALR DATF. - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LF.NDER: Pnone Number: Fax Number: Contact Person: Email Address: Washington Mutual Bank 9451 Corbin Avenue Northridge, CA 91324 1-888-852-1745 1-818-775-6260 CoHection Department www wamuhomeloans.com Name of Lender: Address: EFFF.CfS OF SHERIFF'S SA.LF.. - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASS1JMPTION OF MORTGAGE ~ You _ mayor J(l1lay not seU or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are -paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOlT MAY A.LSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDlNG INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE TIlE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, mi~:sed payments or other defaults on your account may be reflected in your credit report. SPY99 (J ~ AJ l1l. 'c;) ~ 1-.:1 \\:- l(\ <".) n ~:- .-' l1\. - i"l - 93 C> --~~ f' r~,) ~ >J ~ ---, -- - . "---:J .' , -- ~ c:~-, '--L- . SHERIFF'S RETURN - NOT FOUND , CASE NO: 2006-00288 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LONG BEACH MORTGAGE COMPANY VS MUKORA RACHEL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT MUKORA RACHEL but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , MUKORA RACHEL 4706 DELBROOK ROAD MECHANICSBURG, PA 17050 CURRENT RESIDENT NEVER HEARD OF DEFENDANT. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 17.60 5.00 10.00 .00 50.60 So a~sw~~~,:;,~,,~:,.,_~__",,-:::.~~)-~__._~-~ ----~~~~ R. Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 01/26/2006 Sworn and subscribed to before /, day of ( 1:"" ,A... ~~~ )r,D ~~ f "o,k~tt1jji 7 me this ." 30 .... SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-00288 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LONG BEACH MORTGAGE COMPANY VS MUKORA RACHEL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MUKORA RACHEL but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, pennsylvania, to serve the within COMPLAINT - MORT FORE On January 26th , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Postage 6.00 9.00 10.00 29.25 .78 55.03 01/26/2006 GOLDBECK MCCAFFERTY So an~ ....._::...//. //cP"~ R~~~ Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this _in ~ day o'--)~ ~<''f~ . in The Court of Common' Pleas of Cumberland County, Pennsylvania Long Beach Mortgage Canpany VS. Rachel Mukora No. 06-288 civil N January 13, 2006 OW, , !, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r~&4</~-R Sheriff ofCurnberland County, PA Affidavit of Service Now, ,20_,at o'clock M. served the within upon at by handing to a copy of the original and made !mown to the contents thereof. So answers, Sheriff of Couoty, PA Sworn and subscribed before me this day of , 20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ @iib:r of tlp~ ~4~riff William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania LONG BEACH MORTGAGE COMPANY vs County of Dauphin MUKORA RACHEL Sheriff's Return No.0064-T - -2006 OTHER COUNTY NO. 06-288 CIVIL AND NOW:January 20, 2006 at 11:00AM served the within MORTGAGE FORECLOSURE upon MUKORA RACHEL by personally handing to RACHEL MUKORA DEFT 1 true attested copy(ies) of the original MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 1225 ROLLESTON STREET HARRISBURG, PA 17104-0000 Sworn and subscribed to So Answers, ?f~ Sheriff of Dauphin County, Pa. ~,,~ before me this 20TH day of JANUARY, 2006 ~~ By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1,2006 Deputy Sheriff Sheriff's Costs:$29.25 PD 01/18/2006 RCPT NO 213791 TW GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jr. Attorney tD. #16132 Suite 5000 Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY. A DELA WARE CORPORA liON 9451 Corbin Avenue Northridge. CA 91324 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION LAW RACHEL MUKORA (l\lortgagor(s) and Record owner(s)) 4706 Dclbrook Road Mechanicsburg. P A 17050 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-288 ORDER FOR JUDGMENT Please enter Judgment in favor of LONG BEACH MORTGAGE COMPANY, ADELA WARE CORPORATION, and against RACHEL MUKORA 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) trom the date of service of the Complaint. in the sum of $118, 1 41.16. .losep I beck,.lr. Attorney!or Plaintiff 1 hereby certify that the above names are correct and th~ precise residence address of the judgment creditor is l.ONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 9451 Corbin Avenue Northridge, CA 91324 and that the name(s) and last knD\vn addressees) ofthc Defendant(s) is/are RACHEL MUKORA, 1225 Rolleston Street lIarrisburg, PA 17104; GO, EcCAI'FERTY & McKEEVER , I BYAcjSeph A. Goldbeck, Jr. At~rnh for Plaintiff ..' ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $103,88427 Interest from 07/01/2005 through 02/23/2006 $6,049.96 Reasonable Attorney's Fee $5,194.21 late Charges $399.12 Costs of Suit and Title Search $900.00 Escrow Advance Fees $1621.00 $92.60 $118.14Ll6 (' ,,;,1 .) , _ ___) .L ~_n _____ GOlDBE.' AFFERTY & McKEEVER BY: Joseph A. G ldbeck. Jr. Attorney Ii" rl.1aiPtiff I) AND NOW. this ~day of 34 , 2006 damages are assessed as above. In the Court of Common Pleas of Cumberland County LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 9451 Corbin Avenue Northridge, CA 91324 Plaintiff \is. RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Dclbrook Road Mechanicsburg, P A 17050 No. 06-288 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 THE DEBT. Enter the Judgment in favor of Plaintiff and against RACHEL MUKORA by default tor want of an Answer Assess damages as follows: Debt $118,141.16 Interest - 07/01/2005 to 02/23/2006 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe \Vas mailed or delivered to the party against \vhom judgment IS to be entered and to hiS attorney of record, If any, after the default occurred apd at least ten days prior to the date of the fihng of tIlls praecIpe A copy of the nolIee IS attached R C P 237 I o.<,~'t _ _ Joscp , . old beck. Ir Altorn~y for Plaintiff L~.J 132 AND NOW J F~ ..J)> ~ /Y:\~ . Judgment is entered in favor of LONG BEACH MORTGAGE COMPANY. ADELA WARE CORPORA nON and against RACHEL MUKORA by detau!! for \vant of an Ans\vcr and damages assessed in the sum of $11 R,141.16 as per the ove certification r-; Protho WM-0682 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: February 10,2006 TO: RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, P A 17050 LONG BEACH MORTGAGE COMPANY, A OELA W ARE 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)) 4706 Oelbrook Road Mechanicsburg, P A 17050 ACTION OF MORTGAGE FORECLOSURE Defendant(s) Term No. 06-288 TO: RACHEL MUKORA 4706 Delbrook Road Mechanicsburg, PA 17050 TMPORTANTNOTTCF, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BARASSOClATION 2 Liberty Avenue Carhsle,PA 17013 G McCAFFER EVER B oseph A Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center 701 Marlcet Street Philadelphia,PA 19106 215-627-1322 WM-0682 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: February 10, 2006 TO: RACHEL MUKORA 1225 Rolleston Street Harrisburg, P A 17104 LONG BEACH MORTGAGE COMPANY, ADELA W ARE CORPORATION 9451 Corbin Avenue Northridge, CA 91324 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LA W Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. RACHEL MUKORA (Mortgagor( s) and Record Owner( s)) 4706 Delbrook Road Mechanicsburg, P A 17050 Term No. 06-288 Defendant(s) TO: RACHEL MUKORA 1225 Rolleston Street Harrisburg, P A 17104 TMPORTANTNOTTCR YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO TIIE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIIER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT 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 ELlGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 tJ't~ GOLDBECK McCAFFERTY & McKEEVER BY; Joseph A Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center 701 Marice! Street 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-Mili tary Service are true and correct to the knowledge, information and belief. I understand best of my that false sta tements therein are made subj ect to penal ties of 18 Pa. C. S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, RACHEL MUKORA, is about unknown years of age, that Defendant's last known residence lS 1225 Rolleston Street, Harrisburg, PA 17104, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the Uni ted States or its Allies, or otherwise wi thin the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: J cP ~ \f. ~ ~ ~ ~ ~ ,) ~ (:) ~ '-.6 ~ C>' ~r fiS-~ -.._J ,"", ' .-;-1 ". ,',- _--.i r '. Goldbeck MeCallerty & McKeever . flJY: ;"seph A. Goldbeck, Jf. Attomey I.D. #16132 Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attomey for PlaintilI LONG BEACH MORTGAGE COMPANY, A DELA WARE CORPORATION 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS of Cumberland County PlaintilI vs. CIVIL ACTION - LAW RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, P A 17050 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-288 AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, PlaintIfTin thc 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 I.Name and address of (hvner(s) or Reputed Owner(s): RACHEl. MUKORA 1225 RoIleston Street Harrisburg. P A 17 I 04 2. Name and address of Defendant(s) in the judgment: RACHEL MUKORA 1225 RoIleston Street Harrisburg. P A 17 I 04 3. Name and last known address of every judgment creditor \vhose judgment is a record lien on the property to be sold: DISCOVER BANK AWAITING ADDRESS DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. P A 17013 PA DEPARTMENl OF PUBLIC WLLFARE - Bureau of Child Support LllllJrccll1cnl Health and \\/elfarc 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 92R06 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 \vhich may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property \\!hich may be affected by the sale. TENANTS/OCCUP ANTS 4706 Delbrook Road Mechaniesburg, I' A 17050 (attach separate sheet if morc space is needed) I verify that the statements made in this affidavit arc 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. GOLDBECK Mcl: FERTY & McKEEVER BY: Joseph A I beck. Jr.. Esq. Attorney for PI nf T DATED: February 23,2006 \,-"'- (, 06-288 , GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, .If. AttorneyID.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106-1532 215-627-1322 Attorney for Plaintitf LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORA nON 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 Oelbrook Road Mechanicsburg, P A 17050 Term No. 06-288 Dcfendant(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 SHERU'F'S SALE OF REAL PROPERTY TO: MUKORA, RACHEL RACHEL MUKORA 4706 DELBROOK ROAD MECHANICSBURG. PA 17050 Your house at 4706 Delbrook Road, Mechanicsburg, P A 17050 is scheduled to be sold at Shcrift's Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rill 2nd FI. Courthouse to enforce the court judgment 01$118,14Ll6 obtained by LONG BEACH MORTGACiF COMPANY. A DELAWARE CORPORA nON against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prev'ent this Sheriffs Sale YOll must take immediate action: I. the sale will be cancelled if you pay to LONG BEACH MORTGAGF COMPANY, A DELA W ARE CORPORATION, the back payments, late charges, costs and reasonable attomey's fees due. To find oul how much you must pay call: 215-627-1322 06-288 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. Iflhe Sheritfs Sale is not stopped. your property will be sold to the highest bidder. You may tind out the price bid price by calling the SheritT 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 Sherin: 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 moncy bid tor your house will be filed by the Sheriff within thirty (30) days from the date of the SherifTs 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 tiled with the Sheriff within ten (10) days atier 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 IIA VI' A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO fIND OUT WIIERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle. P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 r, c (, (- .. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Je. Attorney 1.0.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for PlaintitT LONG BEACH MORTGAGE COMPANY. A OELA WARE CORPORATION 9451 Corbin Avenue Northridgc, CA 91324 IN THE COURT OF COMMON PLEAS PIaintilT of Cumberland County YS. CIVIL ACTION - LAW RACHEL MUKORA Mortgagor(s) and Record Owner(s) 4706 OeIbrook Road Mechanicsburg, P A 17050 ACTION OF MORTGAGE FORECLOSURE Oefendant(s) No. 06-288 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $118.14116 Interest from 07/0 [/2005 to 02/23/2006 at X.9300% (Casts to be added) GOI.OBEC . AFFERTY & McKEEVER BY: .Iascpi~jGoldbeck,.if. Attorney tfy laintiff -""-. j ~ ""-, ~ VI ~ ~~ ~ ~ ~ 9.., ;-O.Vl (j :" 0- D'D"" ~ "1 D . . \ C> w Cvb~ ~ c 0 OC' I I I , I r-~ \ 0~ ' '. ~ -. ~ ~ ::: , ~ ~ , :% , ~ - ':1. () ~ - - b ~. .J-> - ::. - - CC! -f.- - - ::. V;4:- (J- :::r-- kf l if] <1. \.l ,..l p. ~ ~ - riO ;:::r;l U E ~ ~ ',... -. 0 ~~ ;;; o U \.l % ,... z - ll.\ ~ ~ <1. ....l ll.\ Q 4. 'r ~ "-~ ~9. 0':;( U<i- \30 <C~ 00 \-u :5 ~ % u <1'. ll.\ en o '5 ....l if, ~ ~ ~ ~ 'V 0 ~ '.r> 4.6~g cG-do'- O~<i-<c ';L.B~p.. ::J 'J,) 0 ' ~ p:!. 0 e;Jl Z, :0'3 ..-l-~'V..o ~ ~O.S ::>-' if. '-0 c: ,~--'o ~ ..-1, b'--...c ~ cn-<T 0 " " gl ? '" '6 7, g, ,... ;.;l u ~t ~~ ~9. o i: ,...'0 C2~ .~ '" " ~t ~~ ~G p. - U W ~ p. ,;2..~ ~'" u ~ il.) .;; 00- .","- - ~ 13.2- > ',;>', <f'.~ ..::;. C ~g '$0 4. 9," ~ " ,.. " ':-' v :;u ~t ;:. g '5 ?"'O~- _~ Co 'M 0' ,I "'4 'J,) \.-<"-< r-.l .,.'fr~ 4.""-' t:'"O-'o...'""7 OJ,.9, ~ d'-- :;:: Co .......... 0\ ~o~..c<-q U~.z..9".n 0:.1 il.) 1)'- ~ -..:::';; ~ c-l ". ~,~--' ,;;t. '.8 ~g c.. .aC ~ifl o " ~ 'S if; ALL THA T CERTAIN piece or parcel of land with the buildings and improvements thereon erected situate in Hampden Township, Cumberland County, Pennsylvania, and described according to a survey made by Gerrit J. Registered Surveyor, dated November 10, 1972, as follows, to wit: BEGINNING at a hub on the south side of Del-Brook Road (50 feet wide), at the comer of Lot No.3, said point being measured along the said side of Del-Brook Road 249.50 feet West of the southwest comer of Del Brook Road and St, Mark's Road; thence extending from said point of beginning and along the division line between Lots 3 and 4 South 23 degrees 00 minutes East the distance of 130 feet to a hub at the comer of lands now or fonnerly of B&K Realty; thence along lands now or formerly of B&K Realty South 67 degrees 00 minutes West the distance of 65 feet to a hub at the comer of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub at the comer of Lot no. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub on the said side of DcI-Brook Road; thence along said side of Dcl-brook Road North 67 degrees 00 minutes East the distance 01'65 feet to a point, the place of BEGINNING. BEING Lot No.4 on the Plan ofSt. Mark's Place, recorded in Plan book 8, Page 8, BEING known as No, 4706 Del-Brook Road. UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions, and rights of way of record WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-288 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff (s) From RACHEL MUKORA (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $118,141.16 Interest FROM 7/1/05 TO 2/23/06 AT 8.9300% L.L. $.50 Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid $187.63 Plaintiff Paid Date: FEBRUARY 28, 2006 Prothonotary (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 .,,l Long Beach Mortgage Company, A Delaware Corporation VS Rachel Mukora In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-288 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Joseph A Goldbeck, Jr. Sheriffs Costs: Docketing Surcharge Prothonotary Law Library Poundage Advertising Levy Posting Handbills Postpone Sale Deputize Other Co. Out of County Fees Certified Mail Mileage Share of Bills Patriot News Law Journal 30.00 20.00 1.00 .50 41. 00 15.00 15.00 15.00 20.00 29.25 9.00 1.08 21.12 19.57 246.80 347.00 $ 803.07 y qJJA/6~ Q- s<~~ R. Thomas Kline, Sheriff I . $J tk-!:l' S"1 J-r ~ /S3;Lof-{ 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 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW RACHEL MUKORA (Mortgagor(s) and Record Owner(s)) 4706 Delbrook Road Mechanicsburg, P A 17050 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-288 AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff in the above t' b' attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ cf execution was fil a~ I~n, Y Its following information concerning the real property located at: let e 4706 Delbrook Road Mechanicsburg, P A 17050 I.Name and address ofOwner(s) or Reputed Owner(s): RACHEL MUKORA 1225 Rolleston Street Harrisburg, P A 17104 2. Name and address of Defendant(s) in the judgment: RACHEL MUKORA 1225 Rolleston Street Harrisburg, PAl 7104 3. Name and last known address of every judgment creditor whose judgment is a record lien, propel-t t b y 0 e sold: DISCOVER BANK AWAITING ADDRESS DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child SUlforc . - , nlolf"trf~ Bldg. _ Room 432 ement I' " , P.O. Box 2675 Harrisburg, P A 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. TENANTS/OCCUP ANTS 4706 Delbrook Road Mechanicsburg, P A 17050 (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 " 06-288 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE 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, PAl 7050 Term No. 06-288 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 lHA T PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MUKORA. RACHEL RACHEL MUKORA 4706 DELBROOK ROAD MECHANICSBURG, P A 17050 Your house at 4706 Delbrook Road, Mechanicsburg, P A 17050 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$118,141.16 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE 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 LONG BEACH MORTGAGE CaMP ANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 " , 06-288 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 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 of 717 -240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be 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 ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 .' ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected situate in Hampden Township, Cumberland County, Pennsylvania, and described according to a survey made by Gerrit J, Registered Surveyor, dated November 10, 1972, as follows, to wit: BEGINNING at a hub on the south side of Del-Brook Road (50 feet wide), at the comer of Lot No, 3, said point being measured along the said side of Del-Brook Road 249.50 feet West of the southwest comer of Del Brook Road and St, Mark's Road; thence extending from said point of beginning and along the division line between Lots 3 and 4 South 23 degrees 00 minutes East the distance of 130 feet to a hub at the comer oflands now or formerly ofB&K Realty; thence along lands now or formerly of B&K Realty South 67 degrees 00 minutes West the distance of 65 feet to a hub at the comer of Lot No. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub at the comer of Lot no. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub on the said side of Del-Brook Road; thence along said side of Del-brook Road North 67 degrees 00 minutes East the distance of 65 feet to a point, the place of BEGINNING. BEING Lot No.4 on the Plan ofSt. Mark's Place, recorded in Plan book 8, Page 8, BEING known as No, 4706 Del-Brook Road. UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, mservations, conditions, and rights of way of record '. . . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-288 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff(s) From RACHEL MUKORA (1 ) You are directed to levy upon the property of the defendant (s )and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $118,141.16 Interest FROM 7/1/05 TO 2/23/06 AT 8.9300% L.L. $.50 Atty's Comm % Arty Paid $187.63 Plaintiff Paid Date: FEBRUARY 28, 2006 Due Prothy $1.00 Other Costs (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 ~ ~ ~ Real Estate Sale # 66 On March 06, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, P A Known and numbered as 4706 Delbrook Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 06,2006 By: J~chj f md4 Real Estate Sergeant L 11 :01 'V l- HVH qOOl 'v d '}.. l N I'll) J CH.~rj \ ~L:i ~H"m J :HIB3HS 3Hl .:10 3JI.:HO ,f .. .) 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 #66 NOT Y PUBLIC My commission expires June 6, 2006 . 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. TO AND SUBSCRIBED before me this day of April. 2006 NOT AR L SEAL lOIS E. SNYDER, Notary Public CarHsle Boro, Cumberland County My Commission Expires March 5. 2009 REAL ESTATE 8ALIt NO. 66 Writ No. 2006-288 Civil Long Beach Mortgage Company. a Delaware Corporation vs. Rachel Mukora Atty.: Joseph Goldbeck ALL THAT CERTAIN piece or parcel ofland with the buildings and improvements thereon erected situ- ate in Hampden Township, Cumberland County, Pennsylvania, and described according to a sur- vey made by Gerrit J. Registered Surveyor. dated November 10. 1972, as follows, to wit: BEGINNING at a hub on the south side of Del-Brook Road (50 feet wide), at the corner of Lot No. 3, said point being measured along the said side of Del-Brook Road 249.50 feet West of the southwest corner of Del Brook Road and St. Mark's Road; thence extending from said point of beginning and along the division line between Lots 3 and 4 South 23 degrees 00 minutes East the distance of 130 feet.to a hub at the corner of lands now or formerly of B&K Realty; thence along lands now or formerly of B&K Realty South 67 degrees 00 minutes West the distance of 65 feet to a hub at the comer of Lot No.5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub at the corner of Lot no. 5; thence along the dividing line between Lots 4 and 5 North 23 degrees 00 minutes West the distance of 130 feet to a hub on the said side of Del-Brook Road; thence along said side of Del-brook Road North 67 degrees 00 minutes East the distance of 65 feet to a point, the place of BEGINNING. BEING Lot No. 4 on the Plan of St. Mark's Place, recorded in Plan book 8, Page 8, BEING known as No, 4706 Del-Brook Road. UNDER AND SUBJEcr, NEVER- THELESS, to easements, restric- tions. reservations, conditions, and rights of way of record.