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Home My WebLink About06-1846 GOLD-BECK McCAFFERTY & McKEEVER B\': JOSEPH A. GOLDBECK, JR. ATTORNEY J.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION . LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff ~r;o~ -If'll:, C;c..>.-tT'i:Rh CIVIL ACTION: M~TGAGE FMilCL~URF vs. WILLJAM E. CAMPBELL GENA L. CAMPBELL Mortgagors and Real Owners 105 Shed Road Newville, PA 17241 Defendants NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE 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, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, P A 17013 A VISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DlAS 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 ESTA 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 PROVISlONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROP lED AD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS 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 A venue 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. I). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of SPS-0744. Para informacion en espanol puede communicarse con Loretta aI215.825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. VERIFICATION I, Adam Shields, as thc representative of the Plaintitl corporation within namcd do hcrehy vcrity that I am authorized to and do makc this verilication on bchalf ofthc Plaintiff corporation and the lacts sct fllrth in thc foregoing Complaint arc truc and correclto the best of my knowledge, infonnation and belief I undcrstand that false statements thcrein are made subjcct to thc penalties of 18 Pa, C.S. 4904 relating to unSWOn1 falsification to authorities. Datc ;- 2 &--0-6 . - ' A hields SELECT PORTFOLIO SERVICING p,~lii6it Jl \lnilld Gonerao T"'l_ COrnpony ComrnilrnBnt Number: 2002...., CAMP8eLl.., W SCHllDUI$ C P_TY DESCRIPTION The ~ ~ \0 in lMI Commitment.. de_bed IS foftOW..: AIIlhat_lOl..p;.coOlgroon._In1heT....,.hipollowo'_, countyjCwn_ .nd ComMOOWMllh oIPennoy1vonio.... being """" fuNy _In". _"'01 01 C......,rtond e""nty In DSV 241, pogo 'Z7I17. ..... 1113012001 and ....,rdod 12/1012G01. BeIng &llso kDOWft aa lax I.D.'15-Oe-0038-o13. AlTAComrnItmMr ....... e (1OC'tNMc.tMPBEU.. W.,f!fOI2OO2 CAMf'8eU.. WI1) BKl784PGI291 I P,~lii6it (]3 Ai ACT 91 NOTICE DATE OF NOTICE: February 22,2006 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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. This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help. yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when yOU meet with the Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If yOU have any questions. YOU may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any 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 derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente lIamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo par el programa lIamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, P A 19106 Fax (215) 627-7734 1 Date: February 22, 2006 Homeowners Name: WILLIAM E. CAMPBELL and GENA L. CAMPBELL Property Address: 105 Shed Road, Newville, PA 17241 Loan Account No.: 0004051058 Original Lender: PEOPLE'S CHOIC HOME LOAN INC. Current Lender/Servicer: SELECT FIDELITY NATIONAL FORECLOSURE SOLUTIONS HOMEOWNERS' 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. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one ofthe designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one ofthe consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set 2 forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-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 ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortl!;al!;e Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine: it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 105 Shed Road, Newville, P A 17241 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 (a) Monthly payment from 07/01/2005 thru 2/22/2006 (8 mos. at $786.73/month) $6,293.84 (b) Late charges from 07/01/2005 thru 2/22/2006 $393.40 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $6,687.24 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $6,687.24, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERlOD. Payments must be made either bv cashier's check, certified check or money order made payable and sent to: SELECT PORTFOLIO SERVICING LOSS MITIGATION DEPARTMENT 3815 South West Temple Salt Lake City, UT 841 15 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS ofthe date ofthis Notice, the lender intends to exercise its riehts to accelerate the morteaee 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. 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 foreclose upon your morteaged uropertv. IF THE MORTGAGE IS FORECLOSED UPON - 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 brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all reasonable attorney's 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, which may also include other reasonable costs. If yOU cure the default within the THIRTY (30) DAY period. yOU will not be reauired to pav attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEF AUL T PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time UP to one hour before the Sheriffs Sale. You may do so bv paving 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 Sheriffs Sale as specified in writing by the lender and bv performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. 4 EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale ofthe mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SELECT PORTFOLIO SERVICING Address: 3815 South West Temple Salt Lake City, UT 84115 Phone Number: 888-818-6032 Contact: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may 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 ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEF AUL T 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 THE 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 DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. 5 * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Loss Mitigation Department Phone Number: 888-818-6032 6 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYL VANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 54t-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234.5925 FAX (717) 234.9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 30 I G Street Carlisle, P A 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139.143 Carlisle Street Gettysburg, P A 17325 (717) 334-1518 FAX (7\7) 334.8326 ~ ~ (0 U( ~ ~ U\ - )J B ~ ~ -J ~ ~ r- ~ w :p J:- ~ f ~ C) \ ~ >. l, '"11 ,....,-' ..-! .. 7\,,-1 ",,) \'-1 , ( , , -...., ~.., . \ GOLDBECK Mc AFFERTY & McKEEVER By: JOSEPH A. GOLDB CK, JR. ATTORNEY lD. #16132 SUITE 5000 - MELLON NDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19 06-1532 (215) 627-1322 ATTORNEY FOR PLAINT F IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CNIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE LASALLE BANK NA ONAL ASSOCIATION, AS TRUSTEE, IN TRUST OR THE HOLDERS OF STRUCTURED ASSE INVESTMENT LOAN TRUST MORTGAGE SS THROUGH CERTIFICATES, SER S 2003-BC2 1270 Northland Drive, S e. 200 Mendota Heights, MN 5 120 Term No. 06-1846 Plaintiff vs. WILLIAM E. CAMPBE L GENA L. CAMPBELL 105 Shed Road Newville, PA 17241 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate he Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER ~~~ By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff ~ = <::::;> c;r. c.... c::: ->.'1'">" ~ o -n :t r1'i;22 -elm }~ yl ..J(.!..l i i~ ~fj ;1.0 c~5m ':i~:! ::n -< I cr. -0 ~~ f)? -.J I '.. SHERIFF'S RETURN. REGULAR CASE NO: 2006.01846 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOCIAT VS CAMPBELL WILLIAM E ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT. MORT FORE was served upon CAMPBELL WILLIAM E the DEFENDANT , at 1605:00 HOURS, on the 5th day of April 2006 at 105 SHED ROAD NEWVILLE, PA 17241 by handing to WILLIAM E CAMPBELL 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 10.56 .00 10.00 .00 38.5~ r~~/<-~ R. Thomas Kline 04/06/2006 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before By: /f,t ~ me this 1'1""" day of \~ .2tnl(, A.D. Prothonotary " ~ SHERIFF'S RETURN - REGULAR CASE NO: 2006-01846 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOCIAT VS CAMPBELL WILLIAM E ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CAMPBELL GENA L the DEFENDANT , at 1605:00 HOURS, on the 5th day of April , 2006 at 105 SHED ROAD NEWVILLE, PA 17241 by handing to WILLIAM E CAMPBELL, 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: 6:~~ -"~ ~~ .00 7 ' -1~ 10.00 R. Thomas Kline .00 16.091 04/06/2006 ~ GOLDBECK MCCAFFERTY MCKEEVER N\..(u. ,,1.b1l (. A . D . I Sworn and Subscribed to before By: me this f9~ day of Prothonotary In the Court of Common Pleas of Cumberland County . LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. No. 06-1846 WILLIAM E. CAMPBELL GENA L. CAMPBELL (Mortgagor(s) and Record Owner(s)) 105 Shed Road Newville, PA 17241 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 WILLIAM E. CAMPBELL and GENA L. CAMPBELL by default for want of an Answer. Assess damages as follows: $98,823.73 Debt Interest - 06/0112005 to 07/11/2006 Total (Assessment of Damages attached) 1 CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFI AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN 0 THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered is to be entered and to his attorney of record, ifany, after the default occurred and at Ie filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 party against whom judgment days prior to the date of the Joseph A. Gold Attorney for P . J.D. #16132 ANDNOW ~l.UJe /4 , :JC)(""j~ ,Judgmentis entered in favor of LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 and against WILLIAM E. CAMPBELL and GENA L. CAMPBELL by default for want of an Answer and damages assessed in the sum of$98,823.73 as per the above certification. Prothonotary . Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff No. 06-1846 vs. WILLIAM E. CAMPBELL GENA L. CAMPBELL (Mortgagors and Record Owner(s)) 105 Shed Road Newville, PA 17241 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 Notice is given that a judgment in the above-captioned matter has been entered against you. ~~th~lt ' ~ ~ By: "du,) . "1- Deplll) 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-0744 TIns 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: June 30, 2006 TO: GENA L. CAMPBELL 105 Shed Road Newville, PA 17241 LASALLE BANK NATIONAL ASSOCIATION, AS lRUSTEE, IN lRUST FOR THE HOLDERS OF SlRUCTURED ASSET INVESTMENT LOAN lRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 MendotaHeights, MN 55120 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs. W1LUAM E. CAMPBELL GENA L, CAMPBELL (Mortgagor(s) and Record Owner(s)) 105 Shed Road Newville, PA t7241 Tenn No. 06-1846 Dejendant(s) TO: GENA L. CAMPBELL 105 Shed Road Newville, PA 17241 IMPORT A NT NOTTCF. YOU ARE IN DEF AUL T BECAUSE YOU HA VE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Josepli)l qolif6e(~", Jr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 70 I Market Street. Philadelphia, PA 19106 215-825-6318 SPS-0744 TIns 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: June 30, 2006 TO: ~L~E.CAMPBELL 105 Shed Road Newville, PA 17241 In the Court of Common Pleas of Cumberland County LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR 1HE HOWERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS TIlROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 MendotaHeights, MN 55120 CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs, WILLIAM E, CAMPBELL GENA L, CAMPBELL (Mortgagor(s) and Record Ownet(.)) 105 Shed Road Newville, PA 17241 Term No. 06-1846 Defendant(s) TO: WILLIAM E. CAMPBELL 105 Shed Road Newville, PA 17241 IMPORT ANT NOTICF. 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 TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES 1NC 8 Inrine Row Carlisle, PA t 70B 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Josep6)if qoUlEecf.., Jr 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, GENA L. CAMPBELL, is about unknown years of age, that Defendant's last known residence is 105 Shed Road, Newville, PA 17241, 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 therwise wi thin the provisions of the Soldiers' and Sailors' C' il 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, WILLIAM E. CAMPBELL, is about unknown years of age, that Defendant's last known residence is 105 Shed Road, Newville, PA 17241, 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' i'l Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER . BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE WILLIAM E. CAMPBELL GENA L. CAMPBELL (Mortgagor(s) and Record owner(s)) 105 Shed Road Newville, PA 17241 No. 06-1846 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2, and against WILLIAM . C BELL and GENA L. CAMPBELL for failure to file an Answer in the above action within (20) da s ( ixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in s of $98,823.73. Joseph A. Goldbeck, Attorney for Plainti ide ce address of the judgment UST FOR THE HOLDERS SS THROUGH CERTIFICATES, 55 20 and that the name(s) and last 10 Shed Road Newville, P A 17241 I hereby certifY that the above names are correct and that the precise creditor is LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTE OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGA SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, known address(es) of the Defendant(s) is/are WILLIAM E. CAMPBELL and GENA L. CAMPBELL, 105 Shed Road Newville, P A 17241; ASSESSMENT OF DAMAGES . TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $80,057.39 Interest from 06/0 I /2005 through 07/11/2006 $10,016.02 Reasonable Attorney's Fee $4,002.87 Late Charges $550.76 Costs of Suit and Title Search $900.00 Escrow Advance Fees NSF Charges Recoverable Balance Suspense $1,106.70 $448.48 $20.00 $2,575.20 -$853.69 GOLDBECK M BY: Joseph A. Goldbe Attorney for Plaintiff AND NOW, this /q/-'- day of J~ ' 2006 damages are assessed as above. c 7;:) \.) ~ it- " ~ 9h \) - \) ~ ~ :'-",) - ~ ,'-"'~ () ~ ~ ,--',--, 'n -, L_ -l 0. B r-; c. T'-r~ 1"- f(l-""' ~ /- f1.,J f): 1 - , '::J C) r 4--. Q,- L' " c.. ~.,,: ",', ..... --" - , r:----.. 1-' .~ i-n c.... , h" ,., P,..) 'J "" <....' : =<. ~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 . 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 MendOla Heights, MN 55120 Plaintiff vs. WILLIAM E. CAMPBELL GENA L. CAMPBELL Mortgagor(s) and Record Owner(s) 105 Shed Road Newville, P A 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-1846 TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount Due Interest from 06/01/2005 to 07/11/2006 at 11.2500% (Costs to be added) $98,823.73 <f1 ln~ ~ O~ .o~<f1 ~ 6<11 cfi. "" ~~~~ ;. 55S~ ~ ~~~~ ~ ~~~~ ~~ ~\-',...et) ,,~a ~~tf)~6~ 1ii..o~ 01'0< ~'" \-,00 .....,... 08 0"" '.<~""€!l'" ~~ ~~~.~ a ~~<~ III ",,'Cl <- ~ ~~~~ '!: ~~u~ ~\-'~\-' ~ ,..~ "'~ '.r> "b'-," c--'> .", (]; \-~. ,.,\.)- -- '(..,.~~;:,:c, '~ ;.,~, ..::r ,;~\\j:. ~1 -;}u..J :--:-J \J..-- -j;. --') Y" ..;.0 .:.:! \.y c~:> 0 o ~ ~, :rl ()l:'::l:~::::: r- '-' () I \ \ c~~':r vi ~ j ~ ~ ("4) - \'"f) $ 1 'tl ::l::l! :;; ~~""'"9N ~t '8 ~'.: ea ~ "lOI < ~ ~ u ~ '1 Po. ~ u., i<f1~ ~~~~~.; ';Z; 5.- 0,) ~~~ ~ 'b .. ~ ... ~ ~e ~\ l~ ~ ~.. III S i ~ ... ~ ~ .... ~ ': ~ \ \ \ ~a~~ J. ~ 0:- f) '::' ~ ~~ - \ () G <:I 0 () Vi .....:.. ("'( ~ '<:Yj- 0- - i& . ~\ ~u % ~ -g ~\"'~'" t16 ....~ <'" i f~~ .~j~"? ~lo~~ JI,,\r-,l! l~ €. '%~ r,:)'\:! <f1 1 ~ ~ ~ g.1 ~ - ~& ~ . All that certain lot or piece of ground situate in the Township of Lower Miftlin, County of Cwnberland and Commonwealth of Pennsylvania and being more fully described in the Recorder of Deeds Office of Cwnberland County in DBV 249, page 2707, dated 11/30/2001 and recorded 12/10/2001. Being also known as Tax I.D. #15-06-0035-013. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1846 Civil CNIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2, Plaintiff (s) From WILLIAM E. CAMPBELL AND GENA L. CAMPBELL (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 $98,823.73 Interest FROM 6/1/05 TO 7/11/06 AT 11.2500% Atty's Comm % Atty Paid $192.00 Plaintiff Paid Date: JULY 14, 2006 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG proth2: P 7@ '-....llY.: ~~ J . 'CP.Q<~~r- Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQillRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPillA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 - tioidbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, S1o. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE WILLIAM E. CAMPBELL GENA L. CAMPBELL (Mortgagor(s) and ReconJ Owner(s)) 105 Shed Road Newville, PA 17241 No. 06-1846 Defendant( s) AFFIDAVIT PURSUANT TO RULE 3129 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003- BC2, 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: 105 Shed Road Newville, PA 17241 l.Name and address ofOwner(s) or Reputed Owner(s): WILLIAM E. CAMPBELL 105 Shed Road Newville, PA 17241 GENA L. CAMPBELL 105 Shed Road Newville, PA 17241 2. Name and address ofDefendant(s) in the judgment: WILLIAM E. CAMPBELL 105 Shed Road Newville, PA 17241 GENA L. CAMPBELL 105 Shed Road Newville, PA 17241 . }. N.m.e and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, P A 17105-2675 WILLIAM G. BARKLEY AWAITING ADDRESS 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANT~OCCUPANTS 105 Shed Road Newville, PA 17241 (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 e alties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBECK McC BY: Joseph A. Goldb Attorney for Plaintiff DATED: Julv 11. 2006 c (i~: ---;'~ \" . ~ . ~:~~ 0" (-- c:~ .- s;~ C? N U'\ ~' .. 06-1846 _.~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16l32 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS IN THE COURT OF COMMON PLEAS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH of Cumberland County CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 CNIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE WILLIAM E. CAMPBELL GENA L. CAMPBELL Mortgagor(s) and ReconJ Owner(s) Tenn No. 06-1846 105 Shed Road Newville,PA 17241 Defendant( s TillS 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: CAMPBELL, GENA L. GENA L CAMPBELL 105 Shed Road Newville, PA 17241 Your house at 105 Shed Road, Newville, P A 17241 is scheduled to be sold at Sheriff's Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$98,823.73 obtained by LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: .. ~ .. 06-1846 1. The sale will be cancelled if you pay to LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the 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 of 71 7-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of7l7-240-6390. 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 HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ~- . 8 .-..' 0 '"7<~) c;:~:> -;1 ~--.. \ <-- .~< c c~ _J_-r1 ,""" n,p;-:; iT1 C':-) .r- ;: 0:) \".) ::0 (,i -< 06-1846 - .. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS IN THE COURT OF COMMON PLEAS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH of Cumberland County CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 CNIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE WILLIAM E. CAMPBELL GENA L. CAMPBELL Mortgagor(s) and Record Owner(s) 105 Shed Road Newville, P A 17241 Term No. 06-1846 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: CAMPBELL, WILLIAM E. WILLIAM E. CAMPBELL 105 Shed Road Newville, PA 17241 Your house at 105 Shed Road, Newville, P A 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $98,823.73 obtained by LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: ,. - 06-1846 I. The sale will be cancelled if you pay to LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2, the back payments, fate 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. 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 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 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 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 A venue Carlisle, P A 17013 - ~ . 8 .", C;'".'l ,;:;::: () "";-1 ..... ~~;D 0=, ,r;" " .:'- ~ Cf? \") cr: I{ '.. SHERIFF'S RETURN - REGULAR CASE NO: 2006-01846 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOCIAT VS CAMPBELL WILLIAM E 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 CAMPBELL WILLIAM E was served upon the , 2006 DEFENDANT at 105 SHED ROAD , at 1959:00 HOURS, on the 9th day of June NEWVILLE, PA 17241 WILLIAM E CAMPBELL by handing to 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 18.00 11.44 .00 10.00 .00 39.44./ Q.. ~/D3/0~ Sworn and Subscibed to before me this day of So Answers: ~~~~~ R. Thomas Kline 06/12/2006 GOLDBECK MCCAFFERTY MCKEEVER By, W l~ tLu..))1 / eputy Sheriff A.D. -, SHERIFF'S RETURN - REGULAR CASE NO: 2006-01846 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOCIAT VS CAMPBELL WILLIAM E 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 CAMPBELL GENA L the DEFENDANT , at 1959:00 HOURS, on the 9th day of June , 2006 at 105 SHED ROAD NEWVILLE, PA 17241 by handing to WILLIAM E CAMPBELL, 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: 6.00 .00 .00 10.00 .00 16.00/ Cfv.- 7J()3fi~ Sworn and Subscibed to ~/'? g.~~.I' . ~'/...?~ ., . ,...:;~f# :'~~-<. ..~L:::/I""~ ! . , .",/ " R. Thomas Kline 06/12/2006 GOLDBECK MCCAFFERTY MCKEEVER By: '~~~~ . ~ epu y Sheri day before me this of A.D. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 SPS-0744 CF: 03/29/2006 SD: 12/06/2006 $98,823.73 IN TIlE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. Term No. 06-1846 WILLIAM E. CAMPBELL GENAL.CAJdPBELL Mortgagor(s) and R~ord Owner(s) 105 Shed Road Newville, P A 17241 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (e) (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: ()CJ Personal Service by the Sheriffs Office/esft'J.l'eteat a~btl..(copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant( s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. U S PI.! '" !.ll SerVICi CF H T IF lED MAIL RECEIP r (Uomestlc Mail Only; No Insurance Coverage Frovided) r- nJ m m ..D ..D m Ltl Ltl c:J c:J Return Receipt Fee c:J (Endorsement Required) c:J Restricted Delivery Fee M (Endorsement Required) cO c:J Total Postage & Fees $ ..D c:J c:J r- l}(: rLI t\!c..~~~t'l,. CFHl11IFPMAIl HI' :1' ('Domestic Mail Only; No Insurance Coverage Provided; nJ r- m m ..D ..D rn Ltl Ltl Certified Fee t:l t:l Return Receipt Fee t:l {EndOl'S6IlIent Required) c:J Restr\Clad Delivery Fee M (EndorSement ReqUIred) cO t:l Total postage & Fees $ ..D t:l c:J r- .. 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('oIg ~ 6' O.3lIN\'\ 0 0 n '\ tJ' ",' .' 2~_ r~ SiE cO ,....: 00 I 15. i 2' :j 'l5 ~ 01 ~ lii l1. f l1. I~ 'l5~ ~C1. ~1ii ~j ]j'~ ~o:. ~ lij ~l> ]j~ i~~ G) f ~ I. c o .. c G) E ! .. VI ~ ~ ~ 'C 11. G) G) VI C QI a. - c '0 a. ii lD .. o ~ .5 ..- s 'i ! >- .a S QI Q. E {5 N '0 ~ III ~ ~ o C'l ~ ~ -2 I.L ,..: " ClC) ~ C"') ;:! g 0 I.L en lJ) Q. a.. (/) 1" -- j j ....J -oJ W m Q. ~ <3 ..J <( Z W C) ~ -oJ ....J W m 0.. ~ (3 uj ~ <( ::::i -oJ ~ LaSalle Bank National Association, as Trustee In Trust for the Holders of Structured Asset Investment Loan Trust Mortgage Pass Through Certificates Series 2003-BC2 VS William E. Campbell and Gena L. Campbell In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-1846 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on September 22, 2006 at 1555 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: William E. Campbell and Gena L. Campbell, by making known unto William Campbell personally and husband of Gena L. Campbell, at 105 Shed Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2006 at 1816 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of William E. Campbell and Gena L. Campbell located at 105 Shed Road, Newville, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: William E. Campbell and Gena L. Campbell, by regular mail to their last known address of 105 Shed Road, Newville, P A 17241. These letters were mailed under the date of October 05, 2006 and never returned to the Sheriffs Office. ~_o"-~~:~b-~ ~~~ f R. Thomas Kline, Sheriff By,J. Real Estate I ergeant GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. WILLIAM E. CAMPBELL GENA L. CAMPBELL Mortgagor(s) and Record Owner(s) Term No. 06-1846 105 Shed Road Newville, P A 17241 Defendant(s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003- BC2, 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: 105 Shed Road Newville, P A 17241 l.Name and address ofOwner(s) or Reputed Owner(s): WILLIAM E. CAMPBELL 105 Shed Road Newville, P A 17241 GENA L. CAMPBELL 105 Shed Road Newville, P A 17241 2. Name and address ofDefendant(s) in the judgment: WILLIAM E. CAMPBELL 105 Shed Road Newville, P A 17241 . . . GENAL.C~PBELL 105 Shed Road Newville, P A 17241 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 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 WILLIAM G. BARKLEY C/O CARL THOMAS BARKLEY 107 SHED ROAD NEWVILLE, P A 17241 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 105 Shed Road Newville, P A 17241 (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: November 21,2006 Q C ~i ~H: Z,'1~ ~., - t~ ~~~: 2' !..::':.:. ~Q ~(~! y'C -z: :2 'C:i c;;:;) f:T' S .c::: N 0.) -0 :1t ~ C.fI Q ~ ~~ -,,?m :XJt.f go ::;..;-r. -.s:!) <,."....0 om ---I ~ =< 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County No. 06-1846 Plaintiff vs. WILLIAM E. CAMPBELL GENA L. CAMPBELL (Mortgagor(s) and Record owner(s)) 105 Shed Road Newville, PA 17241 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. jjIt~ JOSEPH A. GOLDBECK, JR., ESQUIRE ~ ';5 <- ~ l U:J g -7 >, --00' mq:\ ?J" .?'(' m.f.;::, ...~ ..~,. ~c. 1';(. ~, , :P-C ~ ~ cr: (J"\ e,...) f6 ~ rn~ ""t1}9 '0, '00 ;:::...j. "il ::c --n '~5 ..-rrt 9 ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN,TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. No. 06-1846 WILLIAM E. CAMPBELL GENA L. CAMPBELL (Mortgagor(s) and Record owner(s)) 105 Shed Road Newville, P A 17241 PRAECIPE TO SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Settled, Discontinued and Ended upon payment of your costs only. fJ't~- JOSEPH A. GOLDBECK, JR., ESQUIRE Q (:. ,0,"1' ?" itO.'.l .(1'- "7.) '. ~.C~. 01,..... 7. ,: ~_c '""l.";:~ ....r-~ ":Z: {.-' ~ '(-:~ ...... :::7'. 2 ~ ~ <- ~ \ -..P ~ dJ .. c.f\ (JJ ~ ~ ~~ ~i.:? 00 ~~ (:2 t2 f5:((\ _\ ~ ::4 LaSalle Bank National Association, as Trustee In Trust for the Holders of Structured Asset Investment Loan Trust Mortgage Pass Through Certificates Series 2003-BC2 VS William E. Campbell and Gena L. Campbell In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-1846 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on September 22, 2006 at 1555 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: William E. Campbell and Gena L. Campbell, by making known unto William Campbell personally and husband of Gena L. Campbell, at 105 Shed Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on October 10,2006 at 1816 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of William E. Campbell and Gena L. Campbell located at 105 Shed Road, Newville, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: William E. Campbell and Gena L. Campbell, by regular mail to their last known address of 105 Shed Road, Newville, P A 17241. These letters were mailed under the date of October 05, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of instruction from Attorney Joseph Goldbeck. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills 30.00 1601.15 15.00 15.00 .50 1.00 21.12 9.56 15.00 30.00 155.00 199.46 15.94 n $2108.73 / I J 0 q Ie '( '----r So Answers: r~/~ R. Thomas Kline, SherTIf"~ j . A ,,-J{ B y j C l~ cl,Jn\..i..\ '\. Real Estate Sergeant I; p'b C-K- 5' G. 'f {, I L if1 '136 ," I # Goldbeck McCafferty & McKeever BY: JosepfA. Go1dbeck, Jr. Attorney LD. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE WILLIAM E. CAMPBELL GENA L. CAMPBELL (Mortgagor(s) and Record Owner(s)) 105 Shed Road Newville, P A 17241 No. 06-1846 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003- BC2, 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: 105 Shed Road Newville, P A 17241 l.Name and address ofOwner(s) or Reputed Owner(s): WILLIAM E. CAMPBELL 105 Shed Road Newville, P A 17241 GENA L. CAMPBELL 105 Shed Road Newville, P A 17241 2, Name and address of Defendant(s) in the judgment: WILLIAM E. CAMPBELL 105 Shed Road Newville, P A 17241 GENA L. CAMPBELL 105 Shed Road Newville, PAl 7241 - 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: ~ DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEP AR TMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 WILLIAM G. BARKLEY A WAITING ADDRESS 4. Name and address of the last recorded holder of every mortgage of record : 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 105 Shed Road Newville, P A 17241 (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 the e alties of 18 Pa. CoSo Section 4904 relating to unsworn falsification to authorities. GOLDBECK McC RTY & McKEEVER BY: Joseph A. Goldbe k, r., Esq. Attorney for Plaintiff L/ DATED: July I L 2006 ~ 06-1846 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney l.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS IN THE COURT OF COMMON PLEAS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH of Cumberland County CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE WILLIAM E. CAMPBELL GENA L. CAMPBELL Mortgagor(s) and Record Owner(s) Term No. 06-1846 105 Shed Road Newville, P A 17241 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: CAMPBELL, WILLIAM E. WILLIAM E. CAMPBELL 105 Shed Road Newville, P A 17241 Your house at 105 Shed Road, Newville, P A 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, December 06,2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $98,823.73 obtained by LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 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: ~ 06-1846 1. The sale will be cancelled if you pay to LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2, You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of7 1 7-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out 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 ifthe sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, P A 17013 06-1846 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS IN THE COURT OF COMMON PLEAS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH of Cumberland County CERTIFICATES, SERIES 2003-BC2 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE WILLIAM E: CAMPBELL GENA L. CAMPBELL Mortgagor(s) and Record Owner(s) Term No. 06-1846 105 Shed Road Newville, P A 17241 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: CAMPBELL, GENA L. GENA L. CAMPBELL 105 Shed Road ;. Newville, P A 17241 Your house at 105 Shed Road, Newville, P A 17241 is scheduled to be sold at Sheriff's Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$98,823.73 obtained by LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2 against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 06-1846 1. The sale will be cancelled if you pay to LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2, 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. 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 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 fmd 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 ifthe 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 ASSOCIATION 2 Liberty A venue Carlisle, P A 17013 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 105 Shed Road Newville, PA 17241 SOLD as the property of WILLIAM E. CAMPBELL and GENA L. CAMPBELL TAX PARCEL #15.06.0035.013 All that certain lot or piece of ground situate in the Township of Lower Mifflin, County of Cumberland and Commonwealth of Pennsylvania and being more fully described in the Recorder of Deeds Office of Cumberland County in DBV 249, page 2707, dated 11130/2001 and recorded 12/10/2001. Being also known as Tax LD. #15-06-0035-013. WRIT OF EXECUTION and/or ATTACHMENT COMMON'NEAL TH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1846 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE HOLDERS OF STRUCTURED ASSET INVESTMENT LOAN TRUST MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2003-BC2, Plaintiff(s) From WILLIAM E. CAMPBELL AND GENA L. CAMPBELL (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 ofthe 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 $98,823.73 Interest FROM 6/1/05 TO 7/11/06 AT 11.2500% L.L. $.50 Atty's Comm % Atty Paid $192.00 Plaintiff Paid Date: JULY 14, 2006 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) l>mth02 2 ~ ~ '.at..#> . ~-<-r 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 . - .:) .~:J Real Estate Sale # 21 On August 24, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Mifflin Township Cumberland County, P A Known and numbered as 105 Shed Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 24, 2006 By: \jori I J S . fMtL~ Real E~te Sergeant E S : I d h I lnr QOOl , .j, :...~ /\ ~'.( i i :..1 .~,: :,1111:3 H S; J H.~ .::: n ~.: _: I.:L::H] ., _ _-A - ---I : ~ 1 :::~: '":, .~. -:~; __J Li ,.:.;-c.'.:J \':~-::':?) F'iRI PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA SSe COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is 'exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: October 20, October 27 and November 3, 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. REAL ESTATE SALE NO. 21 Writ No. 2006-1846 Civil Lasalle Bank National Association, as Trustee in Trust for the Holders of Structured Asset Investment Loan Trust Mortgage Pass through Certificates Series 2003-BC2 vs, William E. Campbell and Gena L. Campbell Atty.: Joseph A. Goldbeck, Jr. All that certain lot or piece of ground situate in the Township of Lower Mifflin, County of Cumber- land and Commonwealth of Penn- sylvania and being more fully de- scribed in the Recorder of Deeds Office of Cumberland County in DBV 249, page 2707, dated 11/ 30/2001 and recorded 12/10/ 2001. Being also known as Tax I.D. # 15-06-0035-0 13. SWORN TO AND SUBSCRIBED before me this 3 day of November. 2006 NOTAR AL SEAL LOIS E. SNYDER, Notary Public CarHsle 8oro, Cumberland County My Commission Expires March 5. 2009 . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Conunonwealth 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 Conunonwealth 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 25th day(s) of October and the 1st and 8th day(s) of November 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 #21 C\~~ c--' s";~;;'.;~~~l1t2~1~~~i~~~~~~'R:. t~~>,.ia\ Seal Terry L. ;::,usS8l1, Notary Public City Of Harrisburg, Dauphin County MyCommissio xpires n 6,2010 ~ber p",nr,~\fl ani? As -'Jr.' ion of Notaries //.1~Z~ ~ NOT AR PUBLIC REAL ESTATE SALE 121 Writ No. 2006-1846 ClvilTerm Lasalle Bank National ASSOCiation, as Trustee In Trust for the Holders of Structured Asset Investment Loan Trust Mortgage Pass through Certificates Series 2003-BC2 Vs. William E. Campbell Gena;c L.Pbell Any: Joseph ~' Idbeck, Jr. DESCBI PTlON AIL ~ CER'OON lot or piece of groun: sItuate m the Township of Lower Mi1l1in County of ~and and Commonwealth of Pennsy1vama and being more fully described in the Recorder of Deeds Office of Cumberland County m DBV 249, page 2707, dated 11/301 20~)J and recorded l2JI0I2ool. Bemg also known as Tax I D #: I"'" nM5 013. . . , .rvv-vv,J- CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013