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Home My WebLink About06-1762 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) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY vs. KRISTA A. KRICK CHARLES W. KRICK Mortgagors and Real Owners 913 W. Trindle Road Mechanicsburg, PAl 705 5 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term ' , J No. tJh - 17b,;;'" Ct.-t4I' CIVIL ACTION: MORTGAGE NOTICE .' F You have been sued in court. If you wish to defend against the clai~Th~~e 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 INFORMA TlON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Defendants LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRIT A, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTlCIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMAND ANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST{\. DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE P AGARLE A UN ABOGADO, EST A OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call 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.govforHelp for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) 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 I Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SPS-0763. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is UBS REAL ESTATE SECURITIES INC., 1270 Northland Drive, Ste. 200, Mendota Heights, MN 55120. 2. The names and addresses ofthe Defendants are KRISTA A. KRICK, 913 W. Trindle Road, Mechanicsburg, PA 17055 and CHARLES W. KRICK, 913 W. Trindle Road, Mechanicsburg, PA 17055, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On August 21, 1998 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to CONTIMORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1477, Page 843. The mortgage has been assigned to: UBS REAL ESTATE SECURITIES INC. by assignment of Mortgage which assignment is lodged for recording. The Mortgage and assignment( s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 10 19(9); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 26, 2005 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 06/26/2005 through 03/3112006 at 9.9000% Per Diem interest rate at $19.52 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 07/2612005 to 03/3112006 Monthly late charge amount at $33.07 Costs of suit and Title Search Escrow Recoverable Balance Suspense $71,996.48 $5,446.07 $3,599.82 $1,025.17 $900.00 $193.20 $11.35 -$321.59 $82,850.50 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liilbility that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date( s) set forth in the true and correct copy of such notice( s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $82,850.50, together with interest at the rate of $19.52, 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 /' 0, / ~ v I LD CK McCAFFERTY & McKEEVER 'By: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF .~ VERIFICATION I, Adam Shields, as the representative of the Plaintifl corporation within named do hereby verify that] am authorized to and do make this verification on behalfofthe Plainti ff corporation and the facts set f()rth in the foregoing Complaint are true and correct to the best of my knowledge, inf(lnl1ation and belief I understand that false statements therein are made subject to the penalties of 18 Pa, CS, 4904 relating to unswol11 falsification to authOlities, Dale ~- 2 3> -(k, A m Shields SELECT PORTFOLIO SERVICING p,~lii6it jl - - . . ~11\10 IIlllU","""ComP""Y :o"""'"""'tNU~ ~6 sc;l\eOU\.l! C I'll~~ "\llll1and""""""to"'llI\5C~tls~"'\<llI-; ...-".__......_.....~_.__._...~ 5_ 01 pel\l'll'Jl"""\a. tjOun<led.nd d~ as ~ to"'" _..,..,.~_r.3~-~..r.'.:;".;r.::..,~~ ~~.::."'.:'.:=,.,.;,,..,':l~._._.""t::'.~. ':'..;.~~~~:t':w30~~...:E~~~~~ol~ ~.~---_.~- -- -_..- ~- - . ~-_......__.....-..-..,-,...... Mech8l\lCSVU<!l. PfIN'O~.' (1~ ~ ~~".: ~- ..).' " . }, ~'> ". . ...;.'~" .~.~f1'i:i":'~iltf~:... ., ~'1f~';' ,~~. '. ~..~.~. . L J~~~ :~i' " "~~~~If ;:1:',' ',i <~~".~ .J~::' " ..:.l'_.~:'~~ ;;" . ,'\"";~ ,~.. .' . ~'iF~~ h '. . c'~Jt{~ ;,,: ?, ,,4,'::" : :;. ~-~, ~'~ir:; \ ".; - ,~',_., SfflSE~T Po lio SE VICNO, i= P.O. Box 551170 Jacksonville, FL 32255-1170 7182 6389 3060 0705 2515 October 25, 2005 #BWNJXZF KRIST! A KRICK 913 W. TRINDLE ROAD MECHANICSBURG,PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the morl2a2e on vour home is in default. and the lender intends to foreclose. Snecific information about the nature of the default is nrovided in the attached Daees. The HOMEOWNER S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to heln to save vonr home. This Notice emlains how the nrooram works. To see if HEMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counseliml Aeencv. The name. address and obone number of Consumer Credit Counselio!! Mendes servim! your Countv are listed at the end of this Notice. If vou have any Questions. vou may call the Pennsvlvania Housiotl Finance Aeencv toll-free at (8001 342-2397. Penons with Imnalred hearin2 can caD (7171 7/m-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in your area. The local bar association may he able to help you find a lawyer. LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO COPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIRLE PARA UN PRESTAMO POR EL PROBRAMA LLAMADO HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Homeowner'sName: Property Address: KRIST! A KRICK. 913 W TRlNDLE ROAD MECHANICSBURG PA 17055 2070710203 Loan Acct No.: Original Lender Current Lender / Servicer: Select Portfolio Servicing, Inc. EFCl<VItlNCPIJ-% SJJSSE~ar Po lio . BE VICINO, i= P.O. Box 551170 Jacksonville, FL 32255~1170 7182 6389 3060 0705 1228 October 25, 2005 #BWNJXZF CHARLES W KRICK 913 W. TRINDLE ROAD MECHANICSBURG,PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort!!8!!e on vour home is in default. and the lender intends to foreclose. Soecific Information about the nature of the default is orovided in the attached oaf!es. The HOMEOWNER S MORTGAGE ASSISTANCE PROGRAM iliEMAPl mav be able to helo to save vour home. This Notice emlains how the "fngram works. To see if HEMAP cao helo. von must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with von when von meet with the Counseline A!!encv. The name. address and ohane Dumber of Consumer Credit Counselinl! ARendes servin!! your Countv are listed at the end of ibis Notice. Ifvou have any ouestions.. vou may call the Pennsylvania Homine: Finance At1encv toll-free at (8001 342-2397. Persons with imoaired hearin!! can caD (7171 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in your area. The local bar associatioo may be able to help you find a lawyer. LA NOTIFlCACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. Sf NO COPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENClONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PRESTAMO POR EL PROBRAMA LLAMADO HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMlR SU HIPOTECA. Homeowner'sName: Property Address: CHARLES W KRICK, 913 W TRINDLE ROAD MECHANICSBURG PA 17055 2070710203 Loan Acct No.: Original Lender Current Lender / Servicer: Select Portfolio Servicing, Inc. EFI;4V",,*CPIJ--G5 HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGffiLE 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 ELIGffiLE 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 ELIGffilLITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under 1he Act, you are entitled to a temporary stay of foreclosure on your mortgage for 1hirty (30) days from 1he date of1his Notice. During 1hat time, you must arrange and attend a face-to- face meeting wi1h one of 1he consumer credit counseling agencies listed at 1he end of 1his Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30\ DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. TIffi PART OF TIllS NOTICE CALLED HOW TO CURE YOUR MORTGAGE DEFAULT EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES If you meet wi1h one of1he consumer credit counseling agencies listed at 1he end of1his Notice, 1he lender may NOT take action against you for 1hirty (30) days after 1he date of1his meeting. The names. addresses and telenhone numbers of desimated consumer credit cOtUlseline al!encies for the county in which 1he orooertv is located are set forth at 1he end of1his Notice. It is only necessary to schedule one face-to-mce meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE your mortgage is in demurt for 1he reasons set forth later in 1his Notice (see following pages for specific information about 1he nature of your demult). lfyou have tried and are unable to resolve this problem with 1he lender, you have the right to apply for financial assistance from 1he Homeowner s Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner s Emergency Assistance Program Application wi1h one of 1he designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to 1he Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-ta-face meeting. YOU ~ FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION Available funds for emergency mortgage assistance are very limited. They will be disbursed by 1he Agency under 1he eligibilily criteria established by 1he Act. The Pennsylvania Housing Finance Agency has sixly (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you jf you have met the time requirements set forth above. Yau will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your applicaticm. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECf THE DEBT (If yoo have filed bankruptcy yoo can slillapply fur Emergancy Mortgage Assistance) LR064 EBOOOS/!iCl'~()4 HOW TO CURE YOUR MORTGAGE DEFAULT ffirin2 it un to date) NATURE OF THE DEFAULT: The MORTGAGE debt held by the above lender on your property located at: 913 W TRINDLE ROAD MECHANICSBURG PA ]7055 ]S SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payment of $755.46 per month due from 07/26/2005 through 09/26/2005 payment (a total of 3 months) : {Mortgage payment includes Escrow Payment of $94.11 per month) : Accrued Late Charges Non-Sufficient Punds (NSP) / Return Check Fees Escrow Advances for Hazard Insurance.. Real Bstate Taxes and/or Municipal Liens: Other Advances (Property Preservation) : Funds on Account: ** Total Amount Due: $ 2,266.38 $ 1,025.17 $ 0.00 $ 193.20 $ 0.00 $ 321. 59 $ 2,969.96 ** Funds on A ccounl typically represent a partial pqyment of principal and interest received that cannot be applied to the loan. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use ifnot applicable) HOW TO CURE THE DEFAUL T You may cure the default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,969.96, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE TIlIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier s check. certified check or mooev order made oavable and sent to: Select Portfolio Servicing, Inc. Remittance Processing P.O Box 900] 710 Louisville, KY 40290-17]0 You can cure any other default by taking the following action within TIllRTY (30) DAYS of the date of this letter: (do not use if not applicable) IF YOU DO NOT CURE TIlE DEFAULT If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rigbts to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. ]ffull payment of the total amount past due is not made within TIllRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinqueney before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney s fees that were actua1ly incurred, up to $50.00. However, if/egal proceedings are started against you, you wilI have to pay all reasonable attorneys fees actually incurred by the lender even if they exceed $50.00. Any attorney s fees will be added to the amount you owe the lender, LR064 EBOOOTINCPf9-000 which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney s fees. OTHER LENDER REMEDIES The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. fiGHT TO CURE THE DEFAULT PfiOR TO SHERIFF S SALE If you have not cured the delimIt within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney s fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice win restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF S SALE DATE It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: PHONE NUMBER: FAX NUMBER: Contact Person: Select Portfolio Servicing, Inc. P.O. Box 65250 Salt Lake City, UT 84165-0250 1-800-635-9698 (801) 293-2600 Michael Vanstaveren NAME OF LENDER: Address: EFFECT OF SHERIFF S SALE You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the properly aller the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE Under the terms of your mortgage and note, it may, or may not, be possible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney s fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. You may find out at any time if your loan is assumable by contacting your lender as provided herein. YOU MAY ALSO HAVE THE fiGHT TO: . SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . HAVE THE MORTGAGE RESTORED TO THE SAME POSlTlON AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT HAVE THIS RIGlIT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) . ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY LR064 EBCl[K)UINCP!<l-{14 Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, P A 17325 (717) 334-1518 CCCS ofWestemPA 2000 LinglestownRoad Harrisburg, PA 17102 1-888-511-2227 Community Action Commission of Captia1 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 Philade1phiaAvenue Waynesboro, P A 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, P A 1711 0 1-800-342-2397 ""'_''''C~I2-~ ~~ ~. ~. :J~ ~ C\ ,0 ~"~ '0'0 J' V'\:p., 0\,\ ' ~ N \.r.. \.'" ,'" ~ ~\ " , ,\ ), " " ~\~ ~ .~~ ~ r t "l ? ~~.J\(r\\ :~i -",. -...,.- S<:, \~l-i::: ~.~ :-:,1~~\ -0 :3t. .,'u; (:' _"""n. '-!? ':.\ _~,:.~ :D ctJ ...< In the Court of Common Pleas of Cumberland County UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. KRISTA A. KRICK CHARLES W. KRICK (Mortgagor(s) and Record Owner(s)) 913 W. Trindle Road Mechanicsburg, P A 17055 No. 06-1762 Defendant(s) PRAECIPE FOR JUDGMENT TIDS 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 KRISTA A. KRICK and CHARLES W. KRICK by default for want of an Answer. Assess damages as follows: Debt $83,795.04 Interest - 0612612005 to 0511512006 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. Joseph A. Attorney fo PI I.D.#1613 party against whom judgment days prior to the date of the I certify that written notice of the intention to file this praecipe was mailed or delivere is to be entered and to his attorney of record, if any, after the default occurred and at I filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 AND NOW fY/';:::JfFt J b , .;(Q?b REAL ESTATE SECURITIES C. and against KRISTA A. KRICK and CHARL . KRICK by default for want ofan A_. ~d"""'" ~""" m" - of"',"'.............. '"""'21 '~ /I~ Prothonotafy Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYL VANIA CIVIL ACTION - LAW UBS REAL ESTATE SECURITIES INe. 1270 Northland Drive, Ste. 200 MendOla Heights, MN 55120 Plaintiff No. 06.1762 vs. KRISTA A. KRICK CHARLES W. KRICK (Mortgagors and Record Owner(s)) 913 W. Trindle Road Mechanicsburg, P A 17055 Defendant(s) 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. NOTICE By: Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 SPS-0763 TIDS 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: May 3, 2006 TO: KRISTA A. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 MendotaHeights, MN 55120 In the Court of Common Pleas of Cumberland County Plaintiff CIVIL ACTION - LAW vs. KRISTA A. KRICK CHARLES W. KRICK (Mortgagor( s) and Record Owner( s)) 913 W. Trindle Road Mechanicsburg, PA 17055 Action of Mortgage Foreclosure Tenn No. 06-1762 Defendant(s) TO: KRISTAA. KRICK 913 W. Trind1e Road Mechanicsburg, PA 17055 IMPORT.4 NT NOTTCF. YOU ARE IN DEF AUL T BECAUSE YOU HA VB FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITII THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTII AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITIIOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW. TIllS OFFICE CAN PROVIDE YOU WITII INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAYBE ABLE TO PROVIDE YOU WITII INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 JOSeph)1 f.}oUf6ect Jr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, P A 19106 215-825-6318 SPS-0763 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF TIllS NOTICE: May 3, 2006 TO: CHARLES W. KRICK 913 W. Toodle Road Mechanicsburg, PA 17055 UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 In the Court of Common Pleas of Cumberland County Plaintiff CIVIL ACTION - LAW vs. KRISTA A. KRICK CHARLES W. KRICK (Mortgagor(s) and Record Owner(s)) 913 W. Trindle Road Mechanicsburg, PA 17055 Action of Mortgage Foreclosure Term No. 06-1762 Defendant(s) TO: CHARLESW.KRICK 913 W. Trindle Road Mechanic,burg, PA 17055 TMPORT ANT NOTTeF, YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TIlE COURT YOUR DEFENSES OR OBJECTIONS TO TIlE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIlE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIlER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU 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 IWw Carlisle, PA 17013 717-243.9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Jowpfi)l q^,,(dhpct _qr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 -701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, KRISTA A. KRICK, is about unknown years of age, that Defendant's last known residence is 913 W. Trindle Road, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' 'viI Relief Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CHARLES W. KRICK, is about unknown years of age, that Defendant's last known residence is 913 W. Trindle Road, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' '1 Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. KRISTA A. KRICK CHARLES W. KRICK (Mortgagor(s) and Record owner(s)) 913 W. Trindle Road Mechanicsburg, P A 17055 CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-1762 ORDER FOR JUDGMENT Please enter Judgment in favor of UBS REAL ESTATE SECURITIES INC., and against KRISTA A. KRICK and CHARLES W. KRICK for failure to file an Answer in the aho action within (20) days (or sixty (60) days if defendant is the United States of America) froln the date of se i e fthe Complaint, in the sum of $83,795.04. I hereby certify that the above names are correct and that the p creditor is UBS REAL ESTATE SECURITIES INC. 1270 Northland 55 120 and that the name( s) and last known address( es) of the Defen Trindle Road Mechanicsburg, PA 17055 and CHARLES W. KRICK, 17055; cise sidence address of the judgment , Ste. 200 Mendota Heights, MN . areKRISTAA.KRICK,913W. . Trindle Road Mechanicsburg, PA GOLOB BY: Josep Attorney fi ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $71,996.48 Interest from 06/26/2005 through 05/15/2006 $6,324.47 Reasonable Attorney's Fee $3,599.82 Late Charges $1,091.31 Costs of Suit and Title Search $900.00 Escrow Recoverable Balance Suspense $193.20 $11.35 -$321.59 GOLDBE BY: Joseph A. Attorney for P AND NOW, this J I. +,- day of ~ , 2006 damages are assessed as above. >ro{L~ e:1- '!-- ~~ ~ <:> ~ ~ ~ (.J ~ ~ '- \> D (). V( rY ""V y- ~ t- :g. ..-L, 2- ~" -oC'. 11'1,;'. '~-\. ::;:> r;; C ~:,C~ ?- (, y(~ z 3. ~ c;, d"" ~ :::::. -- 0"' ...., ~ s;: ~ ~~ -0,11 -1.jC) ~(') l .,0 :...,;-""'f' c- .....) (}'(:') Z-r'O g -z:. 2l -- o ... PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County KRISTA A. KRICK CHARLES W. KRICK Mortgagor(s) and Record Owner(s) 913 W. Trindle Road Mechanicsburg, P A 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-1762 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $83,795.04 Interest from 06/26/2005 to 05/15/2006 at 9.9000% (Costs to be added) McKEEVER r- ~ i.~ - ~~ c:f' "3~' (1~ ? .~ __ ::z -- ~ <g:. .,:. ~ ~ ";'7:. "'"tiC\', e:;,~-:V ~c "0,': ':%' f.2.C. ~c be; yC ~ ~ -S ~ u ~ ~ =- ~ ~ ~ l 0 ~o ~ ~u i8~ ~ b, "'" 0... fJl :z;~ ~ o ~ u ~ ~ ~ ~ ~ 1~11~ ~;:;;!1~-< u~ ~~ a~ 1 ~ ~ .t.fJl\lb,1 -< -;;,~'s "'" i:;'<'>.a ~ '~i ~ C) ~ - C' ..:::r ',>.)-7 __ ~:s a: (J- ~1"' 'j..-~.:, C(CI oJ:) OC:C~ - u.JO- ,..... ftU-l 4 ~ ~ u. 'is o c-l ~ ~)<i Cr~ c'O; '1-;'" . "~" !c::;; ',:,ro ;.00- S :5 <.} ~ ~ C ~e ro1~ ~l ~~ go ~ ~ =- ... t~ ~~ ioil" 'S i ~il ~ N all fJl-<~ ~ 'i$1~~ Ii 8 ~'J. u::: ~.- "~;;~'" ~\""::a 1~ ~ .,,'" ~2 ~'a fJl ~ "-I) ~ J4 -+:: 's!. ~ .~ ~ o it. IJ- ~ - - --Jl ~ ~ - ~ - - ctPl - ~ 1:- - ~ "-'\ C; -ti ~ ~ ~ ::: ~ ~ ~ - - ~ .c ~ a t--- ~<;::::)! \ \ \ !.I) ') - \ Q J , . I ~ () -~ lL ~ Cl-32Baln z:- 't>)- ( ()t-: '01~ri Q- 'CJ Gj ~ ~ \0 .:Z-- - ~V) ~ . All that parcel house and Lot of Ground situate in the Township of Monroe, County of Cumberland and the State of Pennsylvania, bounded and described as follows, to wit: . Beginning at a point in the center of the Trindle Road, said point being three hundred forty (340) feet measured Westwardly along the center of the Trindle Road from property now or late ofR.C. Meyers; thence South 8 degrees 30 minutes East, two hundred fifty (250) feet to a point at lands of Helen A. Hall; thence by said lands of Helen A. Hall, South 70 degrees 30 minutes West, eighty-five (85) feet to a point; thence North 8 degrees 30 minutes West, two hundred fifty (250) feet to a point in the center line of the Trindle Road; thence by the center line of the Trindle Road, North 70 degrees 30 minutes East, eighty-five feet to a point, the place of beginning. Having thereon erected a single family dwelling known and numbered as 913 West Trindle Road, Mechanicsburg, Pennsylvania. Tax Parcel No: 22-24-0738-020 tI) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1762 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfY the debt, interest and costs due UBS REAL ESTATE SECURITIES, INC., Plaintiff (s) From KRISTA A. KRICK AND CHARLES W. KRICK (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. AmountDue $83,795.04 Interest FROM 6/26/05 TO 5/15/06 AT 9.9000% L.L. $.50 Atty's Comm % Atty Paid $149.76 Plaintiff Paid Date: MAY 16, 2006 Due Prothy $1.00 Other Costs ~IS R. ~O~G (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 70IMUUUKETSTREET PIDLADELPIDA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court 1D No. 16132 . ,.....EIl1dbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. AttorneyI.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. KRISTA A. KRICK CHARLES W. KRICK (Mortgagor(s) and Record Owner(s)) 913 W. Trindle Road Mechanicsburg, PA 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-1762 AFFIDAVIT PURSUANT TO RULE 3129 UBS REAL ESTATE SECURITIES INC., 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: 913 W. Trindle Road Mechanicsburg, P A 17055 I.Name and address of Owner(s) or Reputed Owner(s): KRISTA A. KRICK 913 W. Trindle Road Mechanicsburg, P A 17055 CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 2. Name and address ofDefendant(s) in the judgment: KRISTA A. KRICK 913 W. Trindle Road Mechanicsburg, P A 17055 CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 .. Carlisle, PA 17013 .. PA DEPARTMENT OF PUBLIC WELFARE - Bureau 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: MERS, INC., SOLELY AS NOMINEE FOR HOUSEHOLD FINANCE 4318 Miller Road Flint, Ml 48507 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~TS 913 W. Toodle Road Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subjec penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBEC BY: JosephA. Attorney for P DATED: May 15.2006 .. .. ~ -;.. .....iTl rT'(T\ ~{ U}. ~[~. ~(] ~<c~, z '2 g Cf' :s: ~ ~ ~~ - ~t:? CJ'I '?i"r', ,--n ~D 0'" ~--1 - ~ -0 :s: .::. c::> v'" . 06-1762 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW KRISTA A. KRICK CHARLES W. KRICK Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 913 W. Trindle Road Mechanicsburg, PA 17055 Tenn No. 06-1762 Defendant( s TIDS 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: KRICK, KRISTA A. KRISTA A. KRICK 913 W. Toodle Road Mechanicsburg, PA 17055 Your house at 913 W. Toodle Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$83,795.04 obtained by UBS REAL ESTATE SECURITIES INC. 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 UBS REAL ESTATE SECURITIES INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. . . . 06-1762 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 Sheriff's 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 of7l7-240-6390. 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 Sheriff's 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 (lO) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, P A 17013 2 s: ""O'C.i) l'T1rT.! '-7-) z.(,- Uj'--' r;:fc ';;0 -7 _ ~.:'-J PC ~ ,...., 15 <:1"' ::It ~ # . 0' -0 :J: :.;: o ." :t rnf2 ..",'" ~"9 00 -":1-., A:D z.Q 01" -\ ~ c::> . . 06-1762 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CNIL ACTION - LAW KRlSTA A. KRlCK CHARLES W. KRlCK Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 913 W. Trindle Road Mechanicsburg, PA 17055 Tenn No. 06-1762 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. TIDS 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: KRICK. CHARLES W. CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 Your house at 913 W. Trindle Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$83,795.04 obtained by UBS REAL ESTATE SECURJTIES INC. 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: I. The sale will be cancelled if you pay to UBS REAL ESTATE SECURJTlES INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. " ... 06-1762 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 Sheriff's 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 Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 g ~. '" cr~' cpq :zl (f.!, ::<.. ~'- -".- >?c.,. ~L,l :Pc.: Z :2. ,..., ~ "" :% ~ ,- . - 0' -0 :% r- o. ~ =' rn~ 1\9 (JC~ __._1-,-_ '::c-~ 90 oft1 ;:..j ~ c::> SHERIFF'S RETURN - REGULAR .- .. CASE NO: 2006-01762 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UBS REAL ESTATE SECURITIES INC VS KRICK KRISTA A ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KRICK KRISTA A the DEFENDANT , at 0900:00 HOURS, on the 12th day of April , 2006 at 913 W TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to CHARLES KRICK, HUSBAND 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 23.76 .00 10.00 .00_ 51.76{ Y04/12/2006 V GOLDBECK MCCAFFERTY r~~-'<~J R. Thomas Kline MCKEEVER Sworn and Subscribed to before By: me this /1 ~ day of ~ :JoeL. A.D. Prothonotary SHERIFF'S RETURN - REGULAR ,.:"- . CASE NO: 2006-01762 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UBS REAL ESTATE SECURITIES INC VS KRICK KRISTA A ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KRICK CHARLES W the DEFENDANT , at 0900:00 HOURS, on the 12th day of April , 2006 at 913 W TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to CHARLES KRICK 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: 6J~ r'M:n:"~,~ 10.00 R. Thomas Kline .O~" 16.0~04/12/2006 GOLDBECK MCCAFFERTY MCKEEVER lV\.~ Iq~ day of <loot,. A.D. Sworn and Subscribed to before By: me this Prothonotary GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorn for Plaintiff UBS REAL ESTATE SECURITIES INe. 1270 Northland Drive, Ste. 200 Mendola Heights, MN 55120 SPS-0763 CF: 03/24/2006 SD: 09/06/2006 $83,795.04 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW KRISTA A. KRICK CHARLES W. KRICK Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 06-1762 913 W. Trindle Road Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (\:) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ~r~d.i@~boH1~ W'Ju. 7L~: ~ Personal Service by the Sheriffs Office.'~('lu ~ul.-. t ("''''''YJ BrutUAI .....'" ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriff's Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) ofrecord. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for,Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on alltienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. .1"- lI'" r'I C I"- IT! C U'I OFFICIAL _$ r'I C C -"~Fee C (Cndcnlll'Mlllt ReQuIred) C A_Del_Fee Nl__) oQ r'I """",""Fee 1btaI_&F... $ L1l C 0 R ll6i8i.Ajit.~ICK.,..nCl:WiLE.s...IN..............mm.m.m...... orPCi_..... 913 W. Trindle Road Gliii._."iiA4....n...Mec.lian.IcstYlrr..Q~....P}l,...1.70 N ::r r'I C I"- IT! o U'I OFFICIAL 2.79 "'- $ r'I .0 10 \0 10 tru oQ r'I LrI .0 o l"- Certified Fee Yes Yes Return Receipt Fee (Endoreement Required) Reetrlcted DEtUvery Fee (End0r8Mn8nt Required) Total Postage & Fees $ 7.04 o t ~ . "'$ "'.. C$ "'.. :1:$ "''' 0$ "'.. g~ ~ ~8 !~ C 1- ' <> I~ . i. oR ~ ~ 18 nil c z J ~ ~ III .. :l! M a DODD ~ ~ ,( ~ I ~ l5 II i ~ ~ I jcH~ I ~ o~ It h;!l~~ I t;;~~l1; ~ 00000 ~~si ~ 88lr~ j m~ '15 a:- ill tic e ...:1: ~lI:8WA.... l~i~~~ 19~~5$ z03~i:~ ~rn....D.... i z I .,..: "' rn "' I- R ~,.,- ~~Q: 1h~ iil.dl z . c: ~~.. w~i I-a>:l! , ~ ~cpj ~~. 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I ~ ~~ '0 ~Q,~ 1 g>-~(/) ill ~Oll w!::..Js.1 :;; 00 oa:-z ~ 00000 ~~g~ u ~~~~ j Iii '0 Il!~ ~ tii:i ~~Cli:iifN ~wl~u:I~ ~91!!~5d; ~o-..._c ~o%.... t!)U).....l1.!! .ll 5 z ! 1-" N <""i -i <ri ~~ r/I 900~ I ~'\ 11ft )il \~>~ "II '. \;'<;1-... .-&v ....< 7!~j\.C'~ /),' ,'-", ...., i ~......., ., 1 .. e ~ ! ! J g - " I .. J I ~ i ." a. ! I -'-- Ii I Go 1: ~ ~ ~ 0 .. .5 I I ! , II Ii ~ Ii i ... ~ '15 , i :f I .. ..- to ,...: U '15! l~ il 1--.-- 0;; ,~ ~i !~ ~i ....::l 1 - <:...-) ~ (.) ii:: ~ N ~ ~ ! ~ ~ ~ (.) ~ oll ,g ~ .f (.) ,.: ~ ~ 16 <( ! 9 ~ ~ ~ ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 MendOla Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW KRISTA A. KRICK CHARLES W. KRICK Mortgagor(s) and Record Owner(s) 913 W. Trindle Road Mechanicsburg, P A 17055 ACTION OF MORTGAGE FORECLOSURE Tenn No. 06-1762 Defendant( s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 UBS REAL ESTATE SECURITIES INC., 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: 913 W. Trindle Road Mechanicsburg, PA 17055 I.Name and address ofOwner(s) or Reputed Owner(s): KRISTA A. KRICK 913 W. Trindle Road Mechanicsburg, P A 17055 CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 2. Name and address ofDefendant(s) in the judgment: KRISTAA. KRICK 913 W. Trindle Road Mechanicsburg, P A 17055 CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, P A 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MONROE TOWNSHIP MUNICIPAL AUTHORITY 12;1.0 BOILING SPRINGS RD. MECHANICSBURG, PA 17055 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: MERS, INC., SOLELY AS NOMINEE FOR HOUSEHOLD FINANCE 4318 Miller Road Flint, MI 48507 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 913 W. TrindIe Road Mechanicsburg, P A 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August 14, 2006 () ,..., 0 = ~ <-"> "TJ "'" "'Un I :t>o :r rT!f; c::: m::!l Z~. G) "Hi 2': N :00 (;:; W OJ. -<, r:<: . :b: < . -0 ~~: (:):D :J:: ---0 ~;.~rn N ~ Z ?i; :::< ;::- IJ:l -< . . UBS Real Estate Securities, Inc. VS Krista A. Krick Charles W. Krick In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-1762 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 Mileage Share of Bills Patriot News Law Journal 30.00 30.00 1.00 .50 217.20 15.00 15.00 15.00 38.72 19.31 195.80 239.00 $ 816.53 ..( q.)./,()(, ~ S<~,~ ~ R. Thomas Kline, Sheriff -~ / , . ~ ~." j CJc. 5'~,.... , R.u-. JF326f . ! , . .' ., , GtJldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. KRISTA A. KRICK CHARLES W. KRICK (Mortgagor(s) and Record Owner(s)) 913 W. Trind1e Road Mechanicsburg, PA 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-1762 AFFIDAVIT PURSUANT TO RULE 3129 UBS REAL ESTATE SECURITIES INC., 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: 913 W. Trindle Road Mechanicsburg, PA 17055 l.Name and address ofOwner(s) or Reputed Owner(s): KRISTA A. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: KRISTA A. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 , II 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: MERS, INC., SOLELY AS NOMINEE FOR HOUSEHOLD FINANCE 4318 Miller Road Flint, MI 48507 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 913 W. Trindle Road Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subjec penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBEC BY: JosephA. Attorney for P DATED: May 15.2006 L 11 :b '\j b I AVH qUOl g'd '), lr~ \ "J;~ \J .:l:jl~3HS 3111 jO 3Ji.:UO f 06-1762 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW KRISTA A. KRICK CHARLES W. KRICK Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 913 W. Trindle Road Mechanicsburg, PA 17055 Term No. 06-1762 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: KRICK, CHARLES W. CHARLES W. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 Your house at 913 W. Trindle Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$83,795.04 obtained by UBS REAL ESTATE SECURITIES INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to UBS REAL ESTATE SECURITIES INC., the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. , . 06-1762 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may [md 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 Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 ,- 06-1762 J GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW KRISTA A. KRICK CHARLES W. KRICK Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 913 W. Trindle Road Mechanicsburg, PA 17055 Term No. 06-1762 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: KRICK, KRISTA A. KRISTA A. KRICK 913 W. Trindle Road Mechanicsburg, PA 17055 Your house at 913 W. Trindle Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 06,2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$83,795.04 obtained by UBS REAL ESTATE SECURITIES INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to UBS REAL ESTATE SECURITIES INC., the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. ... " 06-1762 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 7 17-240-6390. 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 fmd 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, P A 17013 All that parcel house and Lot of Ground situate in the Township of Monroe, County of Cumberland and the State of Pennsylvania, bounded and described as follows, to wit: . Beginning at a point in the center of the Trindle Road, said point being three hundred forty (340) feet measured Westwardly along the center of the Trindle Road from property now or late ofR.C. Meyers; thence South 8 degrees 30 minutes East, two hundred fifty (250) feet to a point at lands of Helen A. Hall; thence by said lands of Helen A. Hall, South 70 degrees 30 minutes West, eighty-five (85) feet to a point; thence North 8 degrees 30 minutes West, two hundred fifty (250) feet to a point in the center line of the Trindle Road; thence by the center line of the Toodle Road, North 70 degrees 30 minutes East, eighty-five feet to a point, the place of beginning. Having thereon erected a single family dwelling known and numbered as 913 West Trindle Road, Mechanicsburg, Pennsylvania. Tax Parcel No: 22-24-0738-020 WRIT OF' EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UBS REAL ESTATE SECURITIES, INC., Plaintiff (s) NO 06-1762 Civil CIVIL ACTION - LAW From KRISTA A. KRICK AND CHARLES W. KRICK (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 $83,795.04 Interest FROM 6/26/05 TO 5/15/06 AT 9.9000% L.L. $.50 Arty's Corom % Arty Paid $149.76 Plaintiff Paid Date: MAY 16, 2006 Due Prothy $1.00 Other Costs !~i (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 43 On May 22, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA Known and numbered as 913 W. Trindle Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 22,2006 By: 0o~S~ Real Estate Sergeant \.LJ '-.; -- (t ~, L f1 :b 'V b, ^ Vii qUOl '~~1il~UjH~;'~'~ i#3~1~~j8J 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: July 21, July 28, and August 4,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWO 4 TO AND SUBSCRIBED before me this day of August. 2006 NOT ARI L SEAL LOIS E. SNYDER, Notary Public Carlisle Bora, Cumberland County My Commission Expires March 5. 2009 REAL ESTATE SALE NO. 43 Writ No. 2006-1762 Civil UBS Real Estate Securities Inc. vs. Krista A Krick and Charles W. Krick Atty.: Joseph Goldbeck All that parcel house and Lot of Ground situate in the Township of Monroe. County of Cumberland and the State of Pennsylvania. bounded and described as follows. to wit: Beginning at a point in the cen- ter of the Trindle Road. said point being three hundred forty (340) feet measured Westwardly along the cen- ter of the Trindle Road from prop- erty now or late of R.C. Meyers; thence South 8 degrees 30 minutes East. two hundred fifty (250) feet to a point at lands of Helen A. Hall; thence by said lands of Helen A. Hall, South 70 degrees 30 minutes West. eighty-five (85) feet to a point; thence North 8 degrees 30 minutes West. two hundred fifty (250) feet to a point in the center line of the Trindle Road; thence by the center line of the Trindle Road, North 70 degrees 30 minutes East. eighty-five feet to a point. the place of begin- ning. Having thereon erected a single family dwelling known and num- bered as 913 West Trindle Road. Mechanicsburg. Pennsylvania. Tax Parcel No: 22-24-0738-020. 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 July and the 2nd day(s) of August 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 #43 Sworn to and s ... CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 ;, ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-825-6312 Attorney for Plaintiff UBS REAL ESTATE SECURITIES INC. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. KRIST! A. KRICK CHARLES W. KRICK (Mortgagor(s) and Record owner(s)) 913 W. Trindle Road Mechanicsburg, P A 17055 No. 06-1762 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. fJloMsb, JOSEPH A. GOLDBECK, JR., ESQUIRE C" _r.:- c.:ri