The URL can be used to link to this page

Home My WebLink About06-3140GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D.#16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagors and Real Owners 54 W. Big Spring Avenue Newville, PA 17241 Plaintiff Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE Term TGA?E AcT?;M°?` IN ACTION NOTICE You have been sued in court. If you wish to defend against the clai you must take action within twenty (20) days after the Complaint and notice appearance personally or by attorney and filing in writing with the court yot claims set forth against you. You are warned that if you fail to do so the ca: judgment may be entered against you by the Court without further notice fo of for any other claim or relief requested by the Plaintiff. You may lose mo important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT OI LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT Hl IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFIC YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 s set forth in the following pages, are served, by entering a written r defenses or objections to the may proceed without you and a any money claim in the Complaint rey or property or other rights ;E. IF YOU DO NOT HAVE A FFICE SET FORTH BELOW. NG A LAWYER. MAY BE ABLE TO PROVIDE -GAL SERVICES TO ELIGIBLE CUMBERLAND COUNTY BAR ASSOCIA' 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA Dl QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUI DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y Al NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CO PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA I DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, FENDERSE CONTRA LAS USTED RESPONDA DENTRO [SO. PARA DEFENDERSE ES lTE EN FORMA ESCRITA, EL AS QUEJAS EN ESTA DE PROSEGUIR CON EL NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSE? ABOGADO, VAYA O LLAME POR TELPFONO LA OFICINA FIJADA PUEDE PROVEERF, CON INFORMACION DE COMO CONSEUIR UD SI USTED NO PUEDE PAGARLE A UN ABOGADO, EST) INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER S ELIGIBLE AQ UN HONORARIO REDUCIDO LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR. 2 Liberty Avenue Carlisle, PA 17013 ACT NOW! Even though your lender (and our client) has filed an Action of still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call the fol 2). Call the Consumer Credit Counseling Agency at 1-800-989-21 3). Visit HUD'S website www.hud.jzov for Help for Homeowners 4). Call the Plaintiff (your lender) and ask to speak to someone ab( Retention options. 5). Call or contact our office to request the amount to bring the ac( or request a Loan Workout / Home Retention Package. Call Beth at 215-8; figure and/or package you requested will be mailed to the address that you message with that information. The attorney in charge of our firm's Home Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please re WM-0776. UIDA. SI USTED NO TIENE UN AQUI ABAJO. ESTA OFICINA ABOGADO. OFICINA PUEDE PROVEERE .VICIOS LEGAL A PERSONAS GRATIS. TION Foreclosure against you, you wing number: 717-243-9400. for free counseling. cing the Loss of Their Homes. Loss Mitigation or Home current, or payoff the mortgage 29 or fax 215-825-6429. The ;st or faxed if you leave a r Retention Department is David ,ce our Attorney File Number of Para informacion en espanol puede communicarse con Loretta al 21 This Action of Mortgage Foreclosure will continue unless *ou take action to stop it. 1. Plaintiff is LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, 1270 Northland Drive, Ste. 200, Mendota Heights, MN 55120. 2. The names and addresses of the Defendants are CANDY L. BAJ' 54 W. Big Spring Avenue, Newville, PA 17241 and HAROLD R. BAKER JR., 54 W. Big Sp.'}11ing Avenue, Newville, PA 17241, who are the mortgagors and real owners of the mortgaged premise hereinafter described. On November 30, 2005 mortgagors made, executed and delivered hereinafter described to LONG BEACH MORTGAGE COMPAN' which mortgage is recorded in the Office of the Recorder of Deeds 1933, Page 2358. The Mortgage and assignment(s) are matters of r this reference in accordance with Pennsylvania Rule of Civil Proce Plaintiff from its obligation to attach documents to pleadings if tho record. 4. The Property subject to the Mortgage is more fully described in the "A" ("Property„). 5. The mortgage is in default because the monthly payments of prir for January 01, 2006 and each month thereafter and by the terms payments for a period of one month or more, the entire principal charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 12/01/2005 through 05/31/2006 at 8.4000% Per Diem interest rate at $18.60 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 01/01/2006 to 05/31/2006 Monthly late charge amount at $36.93 Costs of suit and Title Search Escrow Fees Monthly Escrow amount $157.56 mortgage upon the Property A DELAWARE CORPORATION, )f Cumberland County as Book iblic record and are incorporated by ure 1019(g); which Rule relieves the e documents are matters of public description set forth as Exhibit d and interest are due and unpaid Mortgage, upon default in such race and all interest due and other 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's than the amount demanded based on work actually performed. The t conformity with the Mortgage and Pennsylvania law. Plaintiff is ent to 5% of the remaining principal balance in the event the Property is Sheriff's Sale or if the complexity of the action requires additional fa demanded in the Action. 8. Plaintiff' is not seeking a judgment of personal liability (or an "in pers? Defendants in this Action but reserves its right to bring a separate Act right exists. If Defendants have received a discharge of their personal proceeding, this Action of Mortgage Foreclosure is, in no way, an atte liability that was discharged in Bankruptcy, but only to foreclose the D pursuant to Pennsylvania law. $80,800.00 $3,385.20 $4,040A0 $184.65 $900.00 $235.88 $83.70 :s set forth above may be less mey's Fees requested are in d to collect Attorney's fees of up d to a third party purchaser at in excess of the amount m" judgment) against the to establish that right, if such oility in a Bankruptcy t to re-establish the personal tgage and sell the Property 9. Notice of Intention to Foreclose and a Notice of Homeowners' Ei been sent to Defendants by certified and regular mail, as required Commonwealth of Pennsylvania, on the date(s) set forth in the to attached hereto as Exhibit "B". The Defendants have not had the the required time and Plaintiff has no knowledge of any such mee through the Plaintiff, the Pennsylvania Housing Finance Agency, Counseling Agency. rgency Mortgage Assistance has r Act 160 of 1998 of the and correct copy of such notice(s) quired face-to-face meeting within ig being requested by the Defendants any appropriate Consumer Credit WHEREFORE, Plaintiff demands a de terris judgment in mortgage forecl sure in the sum of $89,629.43, together with interest at the rate of $18.60, per day and other expenses, cos s 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 d Sheriffs Sale of the Property. By: G DBIWK McCAFFERTY & McKEEVER BV- JOSEPH A. GOLDBECK, JR , ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, ??kVP hmkok , as the the Plaintiff corporation within named do heret representative of verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set fort in the foregoing Complaint are true and correct to the best Iof my knowledge, information and belief. I understand that falselstatements therein are made subject to the penalties of 18 Pa. C unsworn falsification to authorities Date: S?"1G? S00&\ Delaware Cc V.P. DER (( #069'703138.3 - CANDY L. BAKER and HAROLD R. BAKER 9909 relating to e Company, a on. JR. MANAGER ?hibit,A r EXHIBIT A ALL that certain tract of land situate on Big Spring Avenue, in Newville Borough Cumberiand County, Pennsylvania, and being the southern part of Lot 43 in th Plan of Building Lots in said Borough laid out by P. A. Ahl, being mor particularly bounded and described as follows, to wit: BEGINNING at a comer of lot now or formerly of Charles Grimm on said Bid Spring Avenue; thence by said Avenue North 17 Y. degrees East 31 feet to : point on said Avenue, a corner of lot now or formerly of Church of God; thence bl said lot, South 73'/4 degrees East to a point on Chestnut Street; thence aionl Chestnut Street, South S5'/, degrees West to the northeastern corner of Lot nov or formerly of Charles Grimm; thence by same North 73 % degrees West 101 'i feet to the Place of BEGINNING. BEING improved with a 2 %= story frame dwelling house and concrete bloc) garage known and numbered as No. 54 Big Spring Avenue, Newville Pennsylvania. Eys.hibit B Washington Mutual PO Box 2441 Mailstop N010207 Chatsworth, CA 91313-2441 March 22, 2006 #BWNCLNN# #0906979031938392# CANDY L BAKER 54 W BIG SPRING AVE NEWVILLE PA 17241 003188 /PA WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT ANY INFORMATION OBTAINED WILL BE USED PLEASE REVIEW THE DEBT VALIDATION NOTICE OF COLLECTION RE: ACCOUNT # 0697031383 0697031383 COLLECT A DEBT, AND P THAT PURPOSE, ENCLOSED ACT 91 NOTICE TAKE ACTION TO SA YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at a Consumer Credit Couuxling Agency may be able to help explain it. You may also want to contact en attorney in your area. The 1 1 bar apedatiou may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUBS AFECfA SU DER O A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTEND)O DE ESTA NOTIFICACION OBTENGA UNA UCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CAR AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRBSTAMO FOR EL PROGRAMA LLAMADO "ROMEO IS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DER 0 A REDDVUR SU HIPOTECA. Washington Mutual PO Box 2441 Mailstop N010207 Chatsworth, CA 91313-2441 March 22, 2006 #BWNCLNN# #0906979031938392# HAROLD R BAKER JR 54 W BIG SPRING AVE NEWVILLE PA 17241 003187 /FA WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT ANY INFORMATION OBTAINED WILL BE USED PLEASE REVIEW THE DEBT VALIDATION NOTICE OF COLLECTION RE: ACCOUNT # 0697031383 0697031383 COLLECT A DEBT, AND [>; THAT PURPOSE. ENCLOSED ACT 91 NOTICE TAKE ACTION TO SA YOUR HOME FROM FORECLOSURE This Notice contains important legal information. U you have any questions, representatives at {he Consumer Credit Counseling Agency may be able to help explain it. You may alto want to contact an attorney In your area. The 1 bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SOMA IMPORTANCIA, PUSS AFECfA SU DER O A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTMCACION OBTENGA UNA UCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGO? AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMED 'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDMA DEL DER "O A REDSM SU HIPOTECA. SPM HOMEOWNERS NAME(S): Harold R. Baker Jr. PROPERTY ADDRESS: 54 W. Big Spring Ave Newville PA 11241 LOAN ACCT. NUMBER: 0697031383 ORIGINAL LENDER: Lbm CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EMERGENC 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASS] IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUI IF YOU HAVE A REASONABLE PROSPECT OF BRING ABLE TO PAY YOUR N IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE AGENCY. PROGRAM MORTGAGE ASSISTANCE ACT OF CONTROL. PAYMENTS, AND HOUSING FINANCE TEMPORARY STAY OF FORECLOSURE. - Under the Act, you are entitled to a temporary rte 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- -face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING Tut r_pT [OCCUR W IIW THE NEXT (M DAYA. IF YOU DO CONSUMER CREDIT COUNSEL ING AGENCIES - if you meet with one of the consumer cre t counseling agencies listed at the and of this notice, the lender may NOT take action against you for thirty (30) days after the date of th meeting. Then es addresses and ens of ? It is only necessary to schedule one face-to-face meeting. Advise your lende# immodiAWy of your intentions. APPLICATION FOR MDgTr AG.. ASSISTANCE - Your mortgage is in default for the reasolL9 t forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unab] to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergmcy Mortgage istance Program. To do so, you must fill out, sign and We a completed Homeowner's Emergency Assistance Program Application wit one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies h ave applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agene . Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR OME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY AMM - Available funds for emergency mortgage assistance are very limited. They Il be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty ( ) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if y have met the lime requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its do" on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITI IN BANKRUPTCY, THE - FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES O Y AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT' TO COLLECT THE DE (If you have filed bankruptcy, you can still apply for Emergency Mort age Assistance.) 0031871SP999 NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your 54 W. Big Spring Ave Newville PA 17241 IS SERIOUSLY IN DEFAULT BECAUSE- Non-payment A- YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following past due: Monthly Installments: 011OL2006 0210112006 03101/2006 Other charges (explam/itemize): Uncollected Late Charges Uncollected Fees: Corporate advances Less Credits TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CARE THE DEFAULT - You may cure the default within THIRTY (30) DAYS TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 52439A5, PLUS ANY b WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments most be check . or money order made p"le and gent to. Washington Mutual Bank 9451 Corbin Avenue Northridge, CA 91324 located at and the following amounts are now $773.12 $773.12 $773.12 $110.79 $8.90 $0.00 $0.00 82439.05 date of this notice BY PAYING THE SAGE PAYMENTS AND LATE CHARGES You can cure any other default by taking the following action within THIRTY (30) DAYS of date of this letter: (Not applicable): IF YOU DO NOT CI RR THE DEFA t T - B you do not cure the default within THIRTY (30) AYS of the date of this Notice, the 1mAe?. intend, mortgaged prouerty THE .. ererdee MORTGA ita 11.9 r1g1.N FOR to r•rnc D accelerate the UPON The mortgaged property will be sold by the S 'H to pay off the mortgage debt. if the lender refers your case to its attorneys, but you cure the delinquency before the lender begins proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to 550.00. Hovew , if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even if they $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If_vw cura the default withi, the THIRTY LID) DAY pedod ynu will not he required to pay ay t??j f 1_ mortgage debt This means that the entire ou g balance of this debt will be considered due immediately, and you may lose the the thence to pay the mortgage in monthly installmen If full payment of the total amount pest due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to legal action to gnw•i.... .,m.. Your OTHEA s.F.NDEn RF.MF.DTFC -The lender may also sue you personally for the upaid principal mortgage. and all other sums due under the SP999 and foreclosure SALE -If you have not cured the 4afault within the THIRTY (30) DAY restore your mortgage to the same position as if you had never Caring your defaidt in the manner set forth in FARt rFST POMTHt.E SHERiFFIS SALE DATE - It is estimated that the earliest date that could be held would be approximately 9 months from the state of this Notice. A notice sent to you before the sale. Of course, the amount needed to cure the default will increase time exactly what the required payment or action will be by contacting the lender. Name of Lender: Washington Mutual Bank Address: 9451 Corbin Avenue Northridge, CA 91324 Phone Number: 14338852-1745 Fu Number: 1-818.775-6260 Contact Person: Collection Department Email Address: www wa,nnhomelow s.com EFFECTS OF SHF.RIFFM HALE: - You should realize that a Sheriff's Sale will and your own right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not sell or transfer your mortgage debt, provided that all the outstanding payments, charges, and attorney's fees a the other requirements of the mortgage are satisfied. • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR It a Sheriff's Sale of the mortgaged property the actual date of the Sheriff's Sale will be longer you wait. You may find out at any of the mortgaged property and your re you and your furnishings and other a buyer or transferee who will assume the are paid prior to or at the sale, and that OR TO BORROW MONEY FROM • TO. HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NOD AULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YO DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR We may report information about your account to credit bureaus. Late payments, account may be reflected in your credit report. OR ANY OTHER LAWSUIT BY THE LENDER. ARE ATTACHED payments or other defaults on your ? o V ?l stn C iJ ?h v In the Court of Common Pleas of Cumberland County LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagor(s) and Record Owner(s)) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) PRAECIPE FOR JUDGMENT No. 06-3140 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 CANDY L, BAKER and HAROLD R. BAKER JR. by default for want of an Answer. Assess damages as follows: Debt Interest - 12/01/2005 to 08/02/2006 Total (Assessment of Damages attached) $91,384.70 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at ?le,"n days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 n? ?/ Adbeck, Jr. Plaintiff AND NOW a26o L y , Judgment is entered in favor of LONG BEACH MORTGAGE OMPANY, A DELAWARE CORPORATION and against CANDY L. BAKER and HAROLD R. BAKER JR. by default for want of an Answer and damages assessed in the sum of $91,384.74 as per the above certification. /7 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. No. 06-3140 CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagors and Record Owner(s)) 54 W. Big Spring Avenue 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. Curt Long Prothono By: 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 WM-0776 , THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: July 19, 2006 TO: HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 VS. CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagor(s) and Record Owner(s)) 54 W. Big Spring Avenue Newville, PA 17241 TO: HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 06-3140 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT 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 COUNT? BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 4nupfi A go&$eck jr GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 WM-0776 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: July 19, 2006 TO: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagor(s) and Record Owner(s)) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) TO: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 06-3140 TWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT 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 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, CANDY L. BAKER, is about unknown years of age, that Defendant's last known residence is 54 W. Big Spring Avenue, 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' Civil Relief Action of Congress of 1940 and its Amendments. Date: ? V(e 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, HAROLD R. BAKER JR., is about unknown years of age, that Defendant's last known residence is 54 W. Big Spring Avenue, 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' Civil Relief Action of Congress of 1940 and its Amendments. Date: ? V,,W v GOL•DBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. 416132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagor(s) and Record owner(s)) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 06-3140 ORDER FOR JUDGMENT Please enter Judgment in favor of LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, and against CANDY L. BAKER and HAROLD R. BAKER JR. for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $91,384.70. A ddbeck, Jr. Plaintiff I hereby certify that the above names are correct and thIfthe precise residence address of the judgment creditor is LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 and that the name(s) and last known address(es) of the Defendant(s) is/are CANDY L. BAKER, 54 W. Big Spring Avenue Newville, PA 17241 and HAROLD R. BAKER JR., 54 W. Big Spring Avenue Newville, PA 17241; _ GOLCi41cCAFFERTY BY: p Goldbeck, Jr. ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $80,800.00 Interest from 12/01/2005 through $4,557.00 08/02/2006 Attorney's Fee at 5.0000% of principal $4,040.00 balance Late Charges $295.44 Costs of Suit and Title Search $900.00 Escrow $708.56 Fees $83.70 ($0.00) $91,384.70 GOLD AFFERTY & Iv BYi Goldbeck, Jr. AttornAND NOW, this day of pu, , 2006 damages are assessed as above. Pro Prothy (, •tq. tv .,q ? ? `? w ? `' ? s ? r (, -- ? ..- ??y . ..- PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) r' P.R.C.P 3180-3183 r Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-6627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. CIVIL ACTION - LAW CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County ACTION OF MORTGAGE FORECLOSURE No. 06-3140 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 12/01/2005 to 08102/2006 at 8.4000% (Costs to be added) $91,384.70 BY: koskph jk. Goldbeck, Jr. & McKEEVER -4. E 11*- Ca a 9' tn R? `° `? O Q ? w. ^ w h ?\ r _ w Gam. ? o 3 ,. a ? w a v? d y G ?w?Wy,?apia ?3 O O w o Q ?? 6 O le H 4 ?. phi F^ ? d w > ?p+ .m. ae O O ? W 0 a Q w 0 U All that certain tract of land situate on Big Spring Avenue, in Newville Borough, Cumberland County, Pennsylvania, and being the southern part of Lot 3 in the Plan of Building Lots in said Borough laid out by P. A. Ahl, being more particularly bounded and described as follows, to wit: Beginning at a comer of lot now or formerly of Charles Grimm on said Big Spring Avenue; thence by said avenue north 17 '/4 degrees east 31 feet to a point on said avenue, a corner of lot now or formerly of Church of God; thence by said lot south, 73 '/4 degrees east to a point on Chestnut Street; thence along Chestnut Street, south 65 '/4 degrees west to the northeastern corner of lot now or formerly of Charles Grimm; thence by same north 73 '/4 degrees west 101 %: feet to the place of beginning. Being improved with a 2 '/: story frame dwelling house and concrete block garage known and numbered as No. 54 Big Spring Avenue, Newville, Pennsylvania. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 54 W. Big Spring Avenue Newville, PA 17241 SOLD as the property of CANDY L. BAKER and HAROLD R. BAKER JR. TAX PARCEL #28-20-1754-003 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3140 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff (s) From CANDY L. BAKER AND HAROLD R. BAKER, JR. (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $91,384.70 L.L. $.50 Interest FROM 12/1/05 TO 812/06 AT 8.4000% Atty's Comm % Due Prothy $1.00 Arty Paid $155.04 Other Costs Plaintiff Paid Date: AUGUST 3, 2006 CURTIS I- LONG Frothono (Seal) Y. 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 / 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 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagor(s) and Record Owner(s)) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 06-3140 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 54 W. Big Spring Avenue Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 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 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: LONG BEACH MORTGAGE COMPANY 1400 S. Douglass Road, Suite 100 Anaheim, CA 92806 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 54 W. Big Spring Avenue 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 to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: August 2, 2006 N Jr -4 06-3140 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CANDY L. BAKER HAROLD R. BAKER J& Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 Term No. 06-3140 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: BAKER, CANDY L. CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 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 $91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 .r 06-3140 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff 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, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ?J Q? (y^?_t t C' w r ? 06-3140 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 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 ACTION OF MORTGAGE FORECLOSURE Term No. 06-3140 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: BAKER, JR., HAROLD R. HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 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 $91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The We will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 v n 06-3140 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff 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, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ?. ?? ?c? ac SHERIFF'S RETURN - REGULAR i ."W, CASE NO: 2006-03140 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LONG BEACH MORTGAGE COMPANY VS BAKER CANDY L ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BAKER CANDY L the DEFENDANT , at 1344:00 HOURS, on the 28th day of June 2006 at 54 W BIG SPRING AVENUE NEWVILLE, PA 17241 CANDY L BAKER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 2 9 . 0 4;%5` Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 57.04,/ 06/29/2006 n zY?` GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: before me this day Deputy She f of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-03140 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LONG BEACH MORTGAGE COMPANY VS BAKER CANDY L ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BAKER HAROLD R JR the DEFENDANT , at 1344:00 HOURS, on the 28th day of June 2006 at 54 W BIG SPRING AVENUE NEWVILLE, PA 17241 by handing to CANDY L BAKER, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 Affidavit .00 e Surcharge 10.00 R. Thomas Kline .00 16.00,1 06/29/2006 ?1 7ry_Q? GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: before me this day Deputy Sher' f 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 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) WM-0776 CF: 06/01/2006 SD: 12/06/2006 $91,384.70 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 06-3140 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( Personal Service by the Sheriffs Office%emge4wA (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. R", pectfu sub B o h A. oldbec r. A ornfor Plaintiff ,n CERTIFIED MAIL. RECEW! Q- (Domestic w ru e pHIC M yes ° CerUftd Fee o ° 54 s ° (EndoreemeM =i ed H GVpc t? ° Restrkxed DeOveeryquired) Fee "?yOJ ? (Endorsemerd R 7.04 1d° M Total Postage & Fees $ 19 ?n 76 NO C3 FAKER, JR. , . r- ;iaKo; 54---W-:.... Bi-9-- S{?? i?a g A.venu? - ocAOaarrnb NAP , 'NWW11e:...PA.__17241 sire For delivery infortnatiorl visit our website at ru . . 2 -USE `n Postage $ 1 H1( q? "? crCa ° Cerd%d Fee Yes ° t > Return Receipt Fee ° (ErxbrsemeM Required) ere ° Restrlcled DelNeryFee rR (Endoreeme I Required) 7. 04 ? rg1?i M Total Postage & Fees $ 7 6 NOS 11.11 ° 3FnMKER, CANDY . ° 5A...6L_.._Si.9---aP r-i_n 9__A\d en_u e.----- PO BoxW _. Newville. PA 17241 i ti: sre °--------------------------------.-----.... 4L Q o 0 { Z O(D a N Uw ? ? r`P v ? t? o u. can 0 0 0 CD t5 ? tl1 ?? LL Q ? Z5 ? O ' 1 0 c rS c ? c p - m W 0v o e n ?? E U 0 o O V- Uy ? U m ca ?C0? s ti Wv (0 = Om a t? w Z ° - U- O - N LO 6 F- Q O O CL ?? O y! y o E - g o ~ Wpm tC w ?a ?r2tin. = U 3 E O ?i0ai x? RR3d 1-} c'an' Z 0N D1 Q O X 7 W CO 0. U U 0 w -. CEl E? (1) 1-- 5 X N m LO W t6 w m N N f6 ? ? O p0 m3:: a J L aU . w z 0) o De CL ? N 4 SG w a cr ce) ?mo Qoto O)OW z0 MCAr.a? F- ? c CL. ¢ U U 'r OdQa ?CL Z m c? W V F- LO Z 1 ?r. c6 ,r N d d 0 C O C E a a N nom. I? O z c 0. C ' a° m 0 C P a E U D.' Y m N ? O io vi J ? °oN 2 - Z, 06 W 3 u. r: Q f0 $ 0~0 0 (4 ° -j Z o a LL v? ? a U Long Beach Mortgage Company, a Delaware In the Court of Common Pleas of Corporation Cumberland County, Pennsylvania VS Writ No. 2006-3140 Civil Term Candy L. Baker and Harold R. Baker Jr. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 15, 2006 at 1800 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: Candy L. Baker and Harold R. Baker Jr., by making known unto Candy Baker personally and wife of Harold R. Baker, Jr., at 54 W. Big Spring Ave., Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her 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 1633 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 Candy L. Baker and Harold R. Baker, Jr. located at 54 West Big Spring Ave., 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: Candy L. Baker and Harold R. Baker Jr., by regular mail to their last known address of 54 W. Big Spring Ave., Newville, PA 17013. These letters were mailed under the date of October 10, 2006 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff BY ?JC , ' Sn-UC t. Real Estate ergeant GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 06-3140 AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 54 W. Big Spring Avenue Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 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 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: LONG BEACH MORTGAGE COMPANY 1400 S. Douglass Road, Suite 100 Anaheim, CA 92806 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 54 W. Big Spring Avenue 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 to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: November 21, 2006 GOI pB CK McCAFFERTY & McKEEVER BY: os h A. Goldbeck, Jr., Esq. foAttorne r Plaintiff r, N' ?' Go k: Long Beach Mortgage Company, a Delaware In the Court of Common Pleas of Corporation Cumberland County, Pennsylvania VS Writ No. 2006-3140 Civil Term Candy L. Baker and Harold R. Baker Jr. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 15, 2006 at 1800 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: Candy L. Baker and Harold R. Baker Jr., by making known unto Candy Baker personally and wife of Harold R. Baker, Jr., at 54 W. Big Spring Ave., Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her 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 1633 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 Candy L. Baker and Harold R. Baker, Jr. located at 54 West Big Spring Ave., 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: Candy L. Baker and Harold R. Baker Jr., by regular mail to their last known address of 54 W. Big Spring Ave., Newville, PA 17013. These letters were mailed under the date of October 10, 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 instruction from Attorney Joseph Goldbeck. Sheriff s Costs: Docketing 30.00 Poundage 13.73 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 19.36 Certified Mail 3.52 Levy 15.00 Surcharge 30.00 Law Journal 281.00 Patriot News 260.66 Share of Bills 15.94 Total 700.71 ? C' /1/-11]6(, So Answers: R. Thomas Kline, Sheriff BY Real Est Sergeant ?' ??I?5t,?14 I 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 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagor(s) and Record Owner(s)) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-3140 AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 54 W. Big Spring Avenue Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 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 06-3140 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 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 ACTION OF MORTGAGE FORECLOSURE Defendants; Term No. 06-3140 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: BAKER, CANDY L. CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 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 S91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 06-3140 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff 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, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 06-3140 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.4 16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 ACTION OF MORTGAGE FORECLOSURE Defendant(s Term No. 06-3140 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: BAKER, JR., HAROLD R. HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 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 $91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 All that certain tract of land situate on Big Spring Avenue, in Newville Borough, Cumberland County, Pennsylvania, and being the southern part of Lot 3 in the Plan of Building Lots in said Borough laid out by P. A. Ahl, being more particularly bounded and described as follows, to wit: Beginning at a corner of lot now or formerly of Charles Grimm on said Big Spring Avenue; thence by said avenue north 17 '/4 degrees east 31 feet to a point on said avenue, a corner of lot now or formerly of Church of God; thence by said lot south, 73 '/4 degrees east to a point on Chestnut Street; thence along Chestnut Street, south 65 '/4 degrees west to the northeastern corner of lot now or formerly of Charles Grimm; thence by same north 73 '/4 degrees west 101 '/2 feet to the place of beginning. Being improved with a 2 '/2 story frame dwelling house and concrete block garage known and numbered as No. 54 Big Spring Avenue, Newville, Pennsylvania. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 54 W. Big Spring Avenue Newville, PA 17241 SOLD as the property of CANDY L. BAKER and HAROLD R. BAKER JR. TAX PARCEL 428-20-1754-003 WRIT OF EXZCUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-3140 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff (s) From CANDY L. BAKER AND HAROLD R. BAKER, JR. (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $91,384.70 L.L. $.50 Interest FROM 12/1/05 TO 8/2/06 AT 8.4000% Atty's Comm % Due Prothy $1.00 Atty Paid $155.04 Other Costs Plaintiff Paid Date: AUGUST 3, 2006 CURTIS R. LONG Prothonota (Seal) B : ' 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 # 64 On September 11, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA Known and numbered as 54 W. Big Spring Ave., 0 Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 11, 2006 By: R a Estate ergeant f I MY 90Q1 41 J:7 1 ;~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 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 SALE #64 4/C 0. M 1'bi ?.,•rc? ICM crornmc an cm? REAL ESTATE SALE #64 Writ No. 2006-3140 Civil Term Long Beach Mortgage Company, a Delaware Corporation F Vs. ? Candy L. ker and c Harold Baker Jr. Atty. Jose h Goldbeck DES IPTION ALL THAT CERTAIN tract of land situate on Big Spring Avenue, in Newville Borough, Cumberland County, Pennsylvania, and being the southern part of Lot 3 in the plan of Building Lots in said Borough laid out by P.A. Ahl, being more particularly bounded and described as follows, to wit: -- u I -- of W nnu? n, fnamarly of Sworn to and subs ib d be e me this I My Notariai Seai Terry L. Russell, Notary Pur7lic; ly Of Narrisbu, Dauphin County Commiss*n ExpireF JMe 6, 2010 Member. Penn, van' A aiion of Notaries NOTARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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. 64 Writ No. 2006-3140 Civil Long Beach Mortgage Company, a Delaware Corporation vs. Candy L. Baker and Harold R. Baker, Jr. Atty.: Joseph Goldbeck All that certain tract of land situ- ate on Big Spring Avenue, in Newville Borough, Cumberland County, Pennsylvania, and being the south- ern part of Lot 3 in the Plan of Build- ing Lots in said Borough laid out by P. A. Ahl, being more particularly bounded and described as follows, to wit: Beginning at a corner of lot now or formerly of Charles Grimm on said Big Spring Avenue, thence by said avenue north 17 1/4 degrees east 31 feet to a point on said av- enue, a corner of lot now or for- -111 of 0111-1, of Cnd- thence by Marie Coyne, SWORN TO AND SUBSCRIBED before me this 3 day of November, 2006 NOTARIAL SEAL LOtS E. SNYDER, Notary Pubf;c Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 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 19106-1532 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 06-3140 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 8/3/06 to Date of Sale at 8.4000% (Costs to be added) $91,384.70 GOLDBECK AFFERTY & McKEEVER BY: Joseph A. dbeck, Jr. Attorney for Plaintiff a w A d M o o ,? gco ?o H a 0 0 o x H 0 a N ;..,_e C V'3 ?.. c O w o 0 ? 0 d 0 Q a; w? wt 04 V v w y • V ti U l F+ Nr L7 ti w U ? U ? ?? ,dam 'c' N ao a w L4 q ..`` C?o Ao i ;3 ?3 ;3 Li 01-1 0 r v A-V All that certain tract of land situate on Big Spring Avenue, in Newville Borough, Cumberland County, Pennsylvania, and being the southern part of Lot 3 in the Plan of Building Lots in said Borough laid out by P. A. Ahl, being more particularly bounded and described as follows, to wit: Beginning at a corner of lot now or formerly of Charles Grimm on said Big Spring Avenue; thence by said avenue north 17 '/ degrees east 31 feet to a point on said avenue, a corner of lot now or formerly of Church of God; thence by said lot south, 73 '/ degrees east to a point on Chestnut Street; thence along Chestnut Street, south 65 '/ degrees west to the northeastern corner of lot now or formerly of Charles Grimm; thence by same north 73 '/ degrees west 101 '/2feet to the place of beginning. Being improved with a 2 '/2 story frame dwelling house and concrete block garage known and numbered as No. 54 Big Spring Avenue, Newville, Pennsylvania. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 54 W. Big Spring Avenue Newville, PA 17241 SOLD as the property of CANDY L. BAKER and HAROLD R. BAKER JR. TAX PARCEL #28-20-1754-003 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3140 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff (s) From CANDY L. BAKER AND HAROLD R. BAKER, JR. (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $91,384.70 L.L. Interest FROM 8/3/06 TO DATE OF SALE AT 8.4000% Atty's Comm % Due Prothy $1.00 Atty Paid $868.25 Other Costs Plaintiff Paid Date: MARCH 13, 2007 Curtis R. Long, (Seal) rBy: REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Deputy IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CHAPTER 7 PROCEEDING HAROLD RICHARD BAKER, JR. CASE NO: 1-06-bk-02794 RNO aka HAROLD RICHARD BAKER CANDY LEE BAKER aka CANDY : LEE GOODHART, . Debtors EMC MORTGAGE CORPORATION, Movant V. HAROLD RICHARD BAKER, JR. CANDY LEE BAKER . and ; LEON P. HALLER, ESQUIRE, Respondent ORDER Upon consideration of EMC Mortgage Corporation's Motion for Relief from Stay, it is hereby ORDERED AND DECREED that the Automatic Stay be modified to permit, EMC Mortgage Corporation and/or its successors and assigns to proceed with foreclosure on the property located at 54 W. Big Spring Avenue, Newville, PA 17241 and obtain all other Relief available under the Non-Bankruptcy law. It is further ORDERED AND DECREED, that relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. Dated: February 7, 2007 6Z,5? y. gi?p -r Robert N. Op414 Bankruptcy Judge This document a etectrtmically xgned and ftdad on the same date. ma 1 S Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. CANDY L. BAKER HAROLD R. BAKER JR. (Mortgagor(s) and Record Owner(s)) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 06-3140 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 54 W. Big Spring Avenue Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 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 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: LONG BEACH MORTGAGE COMPANY 1400 S. Douglass Road, Suite 100 Anaheim, CA 92806 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 54 W. Big Spring Avenue 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 to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: March 12, 2007 GOLDBEC C ERTY & McKEEVER BY: Joseph oldbeck, Jr., Esq. Attorney for Plaintiff r 5 C -D 06-3140 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 ACTION OF MORTGAGE FORECLOSURE Defendant(s Term No. 06-3140 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: BAKER, CANDY L. CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 06-3140 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff 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, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 06-3140 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 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 our toll free number at 1-866-413-2311 or via email at homeretention(a,goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of WM-0776. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 0 D71 06-3140 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) Term No. 06-3140 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: BAKER, JR., HAROLD R. HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 17241 is scheduled to be sold at Sheriff s Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311 and C 06-3140 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff 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, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 06-3140 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 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 our toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of WM-0776. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. C3 0 ' C.t ` ; 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 WM-0776 CF: 06/01/2006 SD: 06/13/2007 $91,384.70 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 06-3140 Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( Personal Service by the Sheriffs Office/renVetmt t (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. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Re ectfully u W B : J ep . Goldbeck, Jr. At y for Plaintiff 15282804302007 Mercer County Page 1 SOS835 Docket Entries 4/3D/2007 Case No 2007-00561 P WELLS FARGO BANK NA AS TRUSTEE (VS) BRUCE BAKER CHRISTINE BAKER f Date Filed -------------------------------------------------------------------------------- 3/05/07 COMPLAINT IN MORT AGE FORECLOSURE WITH NOTICE TO DEFEND, FILED. TIME STAMPED 2/21/07 TWO PAPERS RECEIVED ON THIS DATE FOR SERVICE TO BRUCE BAKER AND CHRISTINE BAKER FROM ATTY JOSEPH GOLDBECK. $75.00 CHECK RECEIVED FROM GOLDBECK MCCAFFERTY MCKEEVER. -------------------------------------------------------------------------------- 3/13/07 SHERIFF'S FILE RETURNED TO PROTHONOTARY'S OFFICE, FILED. Case Tyyppe: COMPLAINT-MORTGAGE Ret Type.: Regular Litigant.: BAKER BRUCE Add ess..: 2222 MERCER WEST MIDDLESEX RD Ctyyr/St/Zp WEST MIDDLESEX, PA 16159 Hnd To: KARA BAKER ADULT IN CHARGE Shf /D ty.: CHP?D F?OWE Date/Time: 03/12/2007 1445:00 Costs....: $68.00 Pd By: GOLDBECK MCCAFFERTY MCKEEVER -------------------------------------------------------------------------------- 3/13/07 SHERIFF'S FILE RETURNED TO PROTHONOTARY'S OFFICE, FILED. Case Type: COMPLAINT-MORTGAGE Ret Type.: Regular Litigant.: BAKER CHRISTINE Add ess..: 2222 MERCER WEST MIDDLESEX RD Ctyy/rSt/Z WEST MIDDLESEX, PA 16159 Hna To: KARA BAKER ADULT IN CHARGE DatShf/ 03 12 20007 445:00 Costs....: $0.00 Pd By: 00/00/0000 -------------------------------------------------------------------------------- 4/19/07 SWRIT ERVICOF EXECUTION FILED. TIME STAMPED WRIT RECEIVED THIS DATE FOR ON THE DEPENDANTS -------------------------------------------------------------------------------- 4/27/07 SERVICE. TIME STAMPED SERVED THE DEFENDANTS ?+ BRUCE BAKER AND CHRISTINE BAKER, BY HANDING TO KARA BAKER, bAUGHTER AT 2222 MERCER-WEST MIDDLESEX RD WEST MIDDLESEX, PA AT 1:4?PM THIS DATE TWO COPIES OF THE ORIGIRAL WRIT OF EXECUTION AND NOTICE OF SHERIFF SALE DEPUTY ARTHUR LEVIED ON THE FOLLOWING: SPLIT LEVEL STYLE DWELLING, RED BRICK AND TAN VINYL SIDING IN GOOD REPAIR -------------------------------------------------------------------------------- 4/30/07 MAILED A COPY OF THE SHERIFF'S RETURN TO GOLDBECK THIS DATE DATE: April 30, 2007 •JIV??.7/ William H. Romine, Jr. Sheriff of Mercer County ? Cp S ' ? '0 o ' o Qz -J T Z D o S N v ? ?• d m G ? K CD v W O W o 0 it 9. 11. ?o ?c w o v Z 'C 3 O 'G O .9 e m a C?1 0 a 90 y? O N? C t<y 3 ? N 02 ?o Q y Cm O $?v Z ?c N.r?t?`?10?a N '? m W e (Sf 0000 to rn OS OX n in q 7 0 b N C7 - rv am ' 'r ?= ? t1} Z w ? rn c: -n O ?Q[]? 3 3 z 03 d ?m m N 1 m r o ? v ?R m v w o x IIA 401 ""- o a ?wr?ps 0 T M N ?C: I o o? a T pl GOLDBECK McCAFFERTY & MCKEEVER BY*Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 06-3140 54 W. Big Spring Avenue Newville, PA 17241 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 54 W. Big Spring Avenue Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 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 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: LONG BEACH MORTGAGE COMPANY 1400 S. Douglass Road, Suite 100 Anaheim, CA 92806 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 54 W. Big Spring Avenue 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 to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: May 16, 2007 "aAly-"A GO DB CK cCAFFERTY & McKEEVER BY: JoKeph A. Goldbeck, Jr., Esq. Attorney for Plaintiff `?-' --? ?? i=ce a `j ?:.' ,?? ?"t } ? ? l ,?,3 r ?? c.s? .^r ?,.,. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Emc Mtg Cori is the grantee the same having been sold to said grantee on the 13th day of June A.D., 2007, under and by virtue of a writ Execution issued on the 13th day of March, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 3140, at the suit of Long Beach Mtg Co against Candy L Baker & Harold R Jr is duly recorded in Deed Book No. 281, Page 76. IN TESTIMONY WHEREOF, I have reunto set my hand an d eal of said office this day of 41, VL .4 n_ N f9soordsr of Dsods, cwnosdsnd c", cm*, PA My 04M6" M Evhs the FUet Monday of Jw 2010 Long Beach Mortgage Company, a Delaware In the Court of Common Pleas of Corporation Cumberland County, Pennsylvania VS Writ No. 2006-3140 Civil Term Candy L. Baker and Harold R. Baker, Jr. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on March 26, 2007 at 1936 hours, he served a true copy of the within Real Estate Writ, Notice and Description, the above entitled action, upon the within named defendants to wit: Candy L. Baker and Harold R. Baker, Jr., by making known unto Candy L. Baker, personally and adult in charge for Harold R. Baker, Jr., at 54 West Big Spring Ave., Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1507 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Candy L. Baker and Harold R. Baker Jr., located at 54 West Big Spring Ave., 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: Candy L. Baker and Harold R. Baker, Jr., by regular mail to their last known address of 54 West Big Spring Ave., Newville, PA 17241. These letters were mailed under the date of April 5, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 13, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck, on behalf of EMC Mortgage Corp. It being the highest bid and best price received for the same, EMC Mortgage Corp., of 2780 Lake Vista Drive, Lewisville, TX 75067-3884, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $939.02. Sheriffs Costs: Docketing $30.00 Poundage 18.42 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 1.00 Mileage 23.04 Levy 15.00 Surcharge 30.00 Law Journal 355.00 Patriot News 297.89 Share of Bills 16.17 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 939.02 v,-' F/0 t. / il I (?, So s' y Thomas Kline, Sheriff BY? PAA 6a• f y?`? Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Sie. 200 Mendota Heights, MN 55120 Plaintiff vs. CANDY L. BAKER HAROLD R. BAKER JR.. (Mortgagor(s) and Record Owner(s)) 54 W. Big Spring Avenue Newville. PA 17241 De endant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL. ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-3140 AFFIDAVIT PURSUANT TO RULE 3129 H MOR [U?\GF. 0 A'k ,E ?ti lt10'i -ih(". ,?: _!Ction_ h" :*s ?!t'- - !? :.i?l? .?. C?l;ldt)CCh, fl.. 1?JC(llll L. JC[? .,i a?? i';d IC IfIC pmccli.)c i)-[ )ilC ,its Ilicd Illc. following information concerning the real property located at: 54 W. Big Spring Avenue Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: CANDY L. BAKER 54 W. Big Spring Avenue Newville, PA 17241 HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 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 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: LONG BEACH MORTGAGE COMPANY 1400 S. Douglass Road, Suite 100 Anaheim, CA 92806 5. Name and address of every other person who has any record interest in or record lien on the property, and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1 f3i_S},, (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 unswom falsification to authorities. DATED: March 12. 2007 GOLDBEC C FERTY & McKEEVER BY: Joseph. oldbeck, Jr., Esq. Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 06-3140 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. CANDY I.. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Accnuc Newville, PA 17241 Defendant(s'? 'I crm No. 06-3140 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: BAKER, CANDY L. CANDY L. BAKER 54 W. Big Spring Avenue Newville. PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 06-3140 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2 You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happe.ncd_ 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. S. You have a right to remain in the property until the full amount due is paid to the ShcritC and the ?h :rift cr At that time. the buyer may bring legal proceedings to evict you. 6. You may be emitted to a share of the money which ?%as paid tOr 'wur u"u?< 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, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 i 06-3140 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 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 requcsi the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Judy at 215-325-6329 or fax 215-825-64,29. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message l'I li that (1llorFn.a ii. + flG ?ttR)rRC`?? l[1 l aCi;? : ilt[ :;i ill KlltliCti":I1c ' P' C f lli(Utl iiti;partmellt 1S D,£lti 16 [':;lfl 'A W cilfl DC 5. Please reference our Attorney File Number of WM-0776. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. I 1 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 06-3140 LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. CANDY L. BAKER HAROLD R. BAKER JR. Mortgagor(s) and Record Owner(s) 54 W. Big Spring Avenue Nt--v, : ille. PA 17241 ACTION OF MORTGAGE FORECLOSURE Term No. 06-3 l 40 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: BAKER, JR., HAROLD R. HAROLD R. BAKER JR. 54 W. Big Spring Avenue Newville, PA 17241 Your house at 54 W. Big Spring Avenue, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $91,384.70 obtained by LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I . The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and .06=3140 " 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the P,u?er is not paid to the Sheriff, you will remain the owner ui thl property as if the sale never happened. 5. You have a ri_ht 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. [llt.? hC h t.UCt'1 t? ._.-:l,t 11W Mt 111', `,?i l 1,:il '.l ?!S Mtld 1')r',0itr hoasC. 'GC[h: "J,- ! Ch:.Cr]C)lR ??u . << v1C UL_I C: J ili a 1V [i?? j(lCllit l?l(iiin tflli[b ??1? ?121?? 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, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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. 06-3140 1). 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 mort?age or request a Loan Workout / Hume Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention &goldbecklaw.com. Call Judy 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 me«aI(_'e with that information. The attorney in charge of our Jinn's Homeowner Retention Denartment is David Fein xho can be reached it ? 1 (R r F.r,(: 21;-8') > 1 q Para inforrnacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain tract of land situate on Big Spring Avenue, in Newville Borough, Cumberland County, Pennsylvania, and being the southern part of Lot 3 in the Plan of Building Lots in said Borough laid out by P. A. Ahl, being more particularly bounded and described as follows, to wit: Beginning at a corner of lot now or formerly of Charles Grimm on said Big Spring Avenue; thence by said avenue north 17 % degrees east 31 feet to a point on said avenue, a corner of lot now or formerly of Church of God; thence by said lot south, 73 `/ degrees east to a point on Chestnut Street; thence along Chestnut Street, south 65 '/ degrees west to the northeastern corner of lot now or formerly of Charles Grimm; thence by same north 73 '/ degrees west 101 '/2 feet to the place of beginning. Being improved with a 2 '/2 story frame dwelling house and concrete block garage known and numbered as No. 54 Big Spning.Avenue, Newville, Pennsylvania. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 54 W. Big Spring Avenue Newville, PA 17241 SOLD as the property of CANDY L. BAKER and HAROLD R. BAKER JR. TAX PARCEL #28-20-1754-003 1 4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3140 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELAWARE CORPORATION, Plaintiff (s) From CANDY L. BAKER AND HAROLD R. BAKER, JR. (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $91,384.70 L.L. Interest FROM 8/3/06 TO DATE OF SALE AT 8.4000% Atty's Comm % Atty Paid $868.25 Plaintiff Paid Date: MARCH 13, 2007 (Seal) Due Prothy $1.00 Other Costs Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 107 On March 16, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA Known and numbered as 54 West Big Spring Ave., (?iD.. cu@; Newville, more fully described on Exhibit "A" filed with this writ and by this reference G° incorporated herein. Date: March 16, 2007 By: , (j Real E to Sergeant C I ?f, L?J! PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 20, 27, May 4, 2007 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. .w is arie Coyne, E for SWORN TO AND SUBSCRIBED before me this 4 _day of May, 2007 L(.!r r. " .', ": am P h!±C P REAL ESTATE SALE NO. 107 Writ No. 2006-3140 Civil Long Beach Mortgage Company, a Delaware Corporation vs. Candy L. Baker and Harold R. Baker, Jr. Atty.: Joseph Goldbeck All that certain tract of land situ- ate on Big Spring Avenue, in Newville Borough, Cumberland County, Pennsylvania, and being the south- ern part of Lot 3 in the Plan of Build- ing Lots in said Borough laid out by P. A. Ahl, being more particularly bounded and described as follows, to wit: Beginning at a corner of lot now or formerly of Charles Grimm on said Big Spring Avenue; thence by said avenue north 17 1/4 degrees east 31 feet to a point on said av- enue, a corner of lot now or for- merly of Church of God; thence by said lot south, 73 1 /4 degrees east to a point on Chestnut Street; thence along Chestnut Street, south 65 1 /4 degrees west to the north- eastern corner of lot now or formerly of Charles Grimm; thence by same north 73 1 /4 degrees west 101 1 /2 feet to the place of beginning. Being improved with a 2 1/2 story frame dwelling house and con- crete block garage known and num- bered as No. 54 Big Spring Avenue, Newville, Pennsylvania. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 54 W. Big Spring Avenue, Newville, PA 17241. SOLD as the property of CANDY L. BAKER and HAROLD R. BAKER JR. TAX PARCEL #28-20-1754-003. t 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 Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. 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 SALE#107 Sworn to and subscribesa before me this 18th day of May 2007 A.D. COMMONWEALTH OF PENNS'TV,aNIA Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County My mmission Expires June 6, 2010 Mem r Ppnnp + ri : L+?. ,ocintion of Notaries NO ARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013