The URL can be used to link to this page

Home My WebLink About06-4884 GOLDBECK McCAFFERTY & McKEEVER . By: JOSEPH A. GoLDBECK, JR, ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF LONG BEACH MORTGAGE COMPANY, A DEL WARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 ()~ -""ii (!,(c>/\~ I ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION - LAW SHERVONIA JONES Mortgagor and Real Owner 367 W. North Street Carlisle, PA 17013 ACTION OF MORTGAGE FORECLOSURE Defendant Term CIVIL AC'flbN: MORTGAGE Ji'QII!@CL08UfltE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTlFICARIO, 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 LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT, ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of WM-0808. Para informacion en espanol puede communi carse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is LONG BEACH MORTGAGE COMPANY, A DELWARE CORPORATION, 1270 Northland Drive, Ste. 200, Mendota Heights, MN 55120. 2. The name and address of the Defendant is SHERVONIA JONES, 367 W. North Street, Carlisle, PA 17013, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On February 04, 2005 mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to LONG BEACH MORTGAGE COMPANY, A DELA WARE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1896, Page 3009. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 10 19(9); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 01, 2005, and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 06/01/2005 through 08/31/2006 at 9.0500% Per Diem interest rate at $18.91 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 07/01/2005 to 08/31/2006 Monthly late charge amount at $37.05 Costs of suit and Title Search Escrow Advance Fees Recoverable Balance $76,285.13 $8,641.87 $3,814.26 $518.69 $900.00 $881.00 $92.60 $921.50 $92,055.05 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or and "in oersonam" judgment) against the Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. 'Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $92,055.05, together with interest at the rate of$18.9l, per day and other expenses costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By: G B CK McCAFFERTY & McKEEVER By. OSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF ()b6~6 7~97~ A2~ VERIFICATION I, D?lJfJ~ ~~~y , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa, C,S. 4904 relating to unsworn falsification to authorities, Date: 9,-I-d-cXJ~ DONNA HARDY V.P. OEPARTW.ENT MMU'??:F1 L g Beach Mortgage Company, a Delaware corporation #0666875976 - SHERVONIA JONES ~hi6it .Jl EXHIBIT A AI." l1IA T CERTAIN messuage and 101 of JI'OUIICIIIituaIe in Ihe Fourth WIII'CI of the Borou&h of C"..II'lisIe. Cwnba'1III1d County, PcnnsyMnia bounded and &scl'ibed lIII follow. to wit: BEING 1.01 No, 185 on the GmcraI Plan of Additional Buildins 1.olJ laid out by GcorF L. Oermeyer. JI'.. in the Fourth Ward onlle 8orou&h ofC~. aforesaid. wbichP1an is n:c:onIecI in lbeOffice ofthc Recorderof Deeds in and for Cumhcrllll1d County. aforesaid, in Misc:cllaD"""1S Docket No.9. PIIac BO. houncIaIlIId cIctcribed u fullowll, l<1 wil: On the South by West '/llorth Street; on the Eutbylot now or fOl'lllel'lyofWi1liam Miller, on tilt North by an alley I:! fCd wide: md on the Wtst by In! now or formn1y ofW. S. Cin:uon. Containina30 feal. in ftont 011 North S\Jee\, IIId cxtcndins at an nm wid\h 120 feet in hat on North St1\1llt. and cxtmdiDll at lIII cwn width 120 fi:et in dI:plh III the alley aforeWd: hI1vinB thereoo mcll:d a two-IlIory flame dwellina house with. two- story f1'8lllC bac1c-bui1diua and o\ho:r i~vcnoCil1lo IIlUniciJllllly known md numbera 811 367 West Nclrth Slrftt, Carlisle, Pamaylvania, BEING the SIImr premillCll which Geir Majpwaon. by Dc:c:d dated 1uly 18, 2003. and recon1cd AuguAt 6. 2003 in Cumberland COlIIll)'. Pcnnsyl~..nia. Deed BooIt 258. Page 2846. gl\IfIWd and conveyed III Gerald Fair and M~ Ann I:.ir, hu&blnd and wife:. I: . I : " (; '.. . I.J ".. . . '. ':. ',', o . .. .. ". .1," ".' .. .." . " -. '. . II , , . , . \ I ",.J .~ :.... .... I ,..,.....I...!.()fIJ. , J ......\.1\...--.. "",\:, ~ BK IBg6PG30 16 ~fti6it (B Washington Mutual PO Box 2441 Mailstop NOI0207 c:nats,"orth,<:~91313-2441 111111111111111111 0666875976 7100 4047 5100 2b39 4351 May 26, 2006 OOQ12'S IPC SHERVONIA JONES 367 W NORTH ST CARLISLE PA 17013 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE OF COLLECTION ACTIVITY RE: ~CCOUNT # 0666875976 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thi!ll. j" An official noti"A that the mortuge on vnnr 110m.. 1!l in default aTld the Ip-ndlfl!t' in;..nilllt to forec1OSf! !i;n<<".ific infnnnatinn .lInnt the. nature of the default i!i prnvidNl in tl1e attlu~hf'.d pave The. HOMEOWNFR'S MORTnAGF ASS1ST ANfE PROGRAM (JIEMAP) mAV he a.ble to help to lUlWl vaUI' home... This Nnti".f! p.1tI)1ain!l hnw the p1"ODTam wnrks To!W! if HRMAP rAn hp.ln vnll mu!d MFFT WITH A C.ONSlJMRR l"'1lpnrr C.OlJNSRLTNO A(jF..NrY WITHIN 30 DAYS OF THR DATE OF rutS NOTIC':E Take thi!l Notice with you when you meet with the C.oun!llelin2 Apmr.v Thll!! DlImp. AddrMCI and phOriA numM:r of c.on!lump.r C.-redh C""nunV!1in17 Avn~ill!.<l !iervinr ynllr rnun(y are H!lIted at the Pond of thill Nnt;NI! If ynl1 h"W! any c::J1ll!!ltlOn" you mav call the Penn!llylvania Homnn, Finance Anncv toll free at l-RflO,.:W'~2397 lPeI'!V'm" with impail'pil hiWine: can (",all 017) 7Rll- tRl1Q) Thil Notice contains important legal infonnation. If you ha~ any questiODl, representatives at the Coruumer Credit CouD.Je1in1 Asency may be able to help explain It. You may also want to contact an attorney in ,our aRa. The local bar aasoclatlon may be able to help you Ond a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VlVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAClON OBTENGA UNA TRADUCClON INMEDrrAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENClONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDlDA DEL DERECHO A REDlMIR SU HIPQTECA. SP999 . HOMEOWNER'S NAME(S): Shervonia Jones PROPERTY ADDRESS: 367 W. North St. CarlisIe PA 17013 0666875976 Lbrn WashinJton Mutual Bank WAN Acer. NUMBER: ORIGINAL LENDER: CURRENT LENDERlSERVICER: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL As''11STANCE WIDCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTIJRE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE Acr OF 1983 (THE "Acr"), YOU MAY BE ELlGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECr OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TF.M'PnRARV ~TAV OF FnRIU''''J''WIJRF. - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from tl1e date of this Notice. During that time you must arrange and attend a "faaHo-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TRM MRF.TTN"G MTJ!irr tvY"ITR WITHTN THR N1l.:YT ~l n... Yfi: IF YOU nn NOT APPI Y FOR EMRRGF.NCY MORTGAGF ASSlsTAN<:E. YOU MUST 'RRlN(; YOUR MORTGAGE UP TO DATE THE PART OF THIS NnTIr.F. CAT T PO "HOW TO r.lJRR VOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MnRTOAGE lIP Tn DATE r.ONSlrMF.R rRF.nlT lYJIJN~R.I.'Nc:. AGR.NCTF,g M If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you. for thirty (30) days after the date of this meeting. The n~m_ addr.......... and tl!lenhnnp. nllmMr<I of ll-.iV"atp.d C'nnlllumer credit oonnlll.P.liny Sl.if'nC'ieA fm' the {'!\unty in "niron tne VnJIP.TtJ.' 111. llY'~ted are set fnrtn at the end nf thi!li NntiCl! It is only necessary to schedule one face-to~face meeting. Advise your lender immAdiately of your intentions. APPJ.lr.ATlnN li'llR MORTr:ACF. AJlfU~ANrR M Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried. and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application. with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIMI! PI!RIODS SIlT FORTH IN THIS LI!'ITI!R, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. A.GENCY AMION - Available funds for emergency mortgage assistance a.re very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTI!CI'I!D BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLl!CJ' THE DEBT. (If )'ou have filed. bankruptcy, )'OU can still apply for Emergency Mortgage Auistance.) . 000' 2~fSP999 HOW TO CURE YOUR MORTGAGE DEFAm.T (BriOII' it uo to dat..\. NATURE OF THF. OEFAULT ~ The MORTGAGE debt held by the above lender on your property located at: 367 W. North St. Carlisle PA 17013 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 07/0112005 0810112005 09/0112005 1010112005 1110112005 1210 112005 0110112006 0210112006 0310112006 0410112006 05/0112006 $617.57 $617.57 $617.57 5617.57 5617.57 $617.57 $617.57 $617.57 $617.57 $617.57 $617.57 Other charges (explainlitemize): Uncollected Late Charges Uncollected Fees: Corporate advances Less Credits TOTAL AMOUNT PAST DUE: $440.00 $17.80 $92I.5U $0.00 S817257 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACfION (NGt applicable): HOW m CURE THE DR.FAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOlJNT PAST DlJE TO THE LENDER. WlfiCH IS $8172.57. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaVtnll'!nt.!Iil mn!lt he made P.it'hfl!T hv l'Jl!llh l"A"hip.r'!II. ~hpr.k certified r.heck nr mnnay order mAdl! pavahle and ~nt to' Washington Mutual Bank 9451 Corbin A...eD11e NorlhrldJe. CA 91324 You CaIL cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): 111' VOlT on NOT MTRF. THF. DEFAULT- If you do not cure the default within TlDRTY (30) DAYS of the date of this Notice, th~ I_d.... IrlMnd. to IMrl!l"clu its I1thts to JI__ll!ratf! the m"rtVI~ liMIt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose tbe the chance to pay the mortgage in mOIlthIy installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to "'..--1_ Ilnon yf)ur mortRaRI!CI DI'ODerty. *1" THR MnRTGAGR It; ll'nD1l'rl.nRlm ITPnN The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your cue to its attorneys., but you cure the delinquency before the lender begins legal proceedings against you, you will still be required. to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $SO.OO. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. I' yOIl cu~ the dJalllt within the THIRTY (:\I)) DA V period YOU will not be rMUirerl to nay attorney'. ree. nTHRR LENORR RF.M17.Dln - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. SPm .. RIGHT TO r.IJRF. THF. DRFAl11.T PRIOR TO RHRRTFF"S SALE..lfyou have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yol] mAV!IInn hAVP. the right tn r..u:rP. the dmlllt And prevent thIP. ulp. at Any timf! lIn to one hour before the Shf!riff'!Ii Sale You m.l\Y do !IO hy navin, the total amount then pad dUll! lJ]U!II any late or other charp t'hp.n due 1"ea.'innahle a.ttornev'!11 fio..u and CCl8t.'l cnnnecw with the mrec]rllilUM ale and any nthm- CCl8~ t'nnnectM with the Sheriff'!II SlI.lp. 11.'1 'q)"'t";nM in writinw hy the 1"'011",1" and hv 1V!MnTminr AnV nthfll" req.JliremP.nt!i nndl'll" the mnrtnv Curinl your default in the manner set forth in this notice will restore your mortpge to the same poIition as if you had never defaulted.. RA RI.IRfi Pfllq,qIRI E liilHJi'.RTli"F'S liil.4.'.F. DATR . It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO mNTACT THE LENDER, Name of Lender: Address: Washinaton Mutual Bank 9451 Corbin Avenue Northrlqe, CA 91324 1-ll88-852-1745 1-818-775-Q1iO Collection Department www w..muhomeloanll Pnm Phone Number: Fax Number: Contact Penon: Email Address: EFFF~ OF l'iilHF.Rlli'F'!iI l'iilA1.F.. ~ You should realize that a Sheriff's Sale will end your ownership of the mortgaged. property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale. a lawsuit to remove you and your furnishings and other belonging!! could be started by the lender at any time. AS.cnJMPTION OF MORTGAGF.. You _ mayor ..x.ma)' not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY AI.V) HAVR THR RIGHT- . TO SELL TIlE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTIlER LENDING INSTITUTION TO PAY OFF TInS DEBT. . TO HAVE TIlE DEFAULT CURED BY ANY THIRD PARTY AcnNG ON YOUR BEHALF. . TO HAVE TIlE MORTGAGE RESTORED TO THE SAME POSmON AS IF NO DEFAULT HAD OCCURRED,IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TInS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSlITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BEUEVE YOU MAY HAVE TO SUCH AcrlON BY TIlE LENDER. . TO SEEK PROTEcnON UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We I1l8y report information about your account to credit bureaus. Late payments, misaed. payments or other defaults on your account may be reftected in your credit report. SPm .. ~ ~ ~ 'l ~ Irt I-J C> - p:: ~ f" -:t ~ ~ :e ~ -C, ~ '-J:: (;) ~ ~ Q "'" ~'. ;: ~:nr- '"'t-:.' C..: ,........, 1"':' G') -r1 1.J4 - '~J "r' ~ ;~(:) "C' :11 :... -0 i~~(~ ~CJ ~ .(~(Tl ~, C1 0:? ~. p'(':': ~ ~~ en :.< ~ 0:> 0" SHERIFF'S RETURN - REGULAR CASE NO: 2006-04884 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LONG BEACH MORTGAGE COMPANY VS JONES SHERVONIA KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon JONES SHERVONIA the DEFENDANT , at 0016:36 HOURS, on the 13th day of September, 2006 at 367 W NORTH STREET CARLISLE, PA 17013 by handing to JAMES CURTIS WILKINSON (ADULT IN CHARGE) a true and attested copy of NOTICE together with COMPLAINT IN MORTGAGE FORECLOSURE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.40 .00 10.00 .00 32.40v' Cf/J. "1/0(, So Answers: ~~~~~ R. Thomas Kline L~ 09/14/2006 GOLDBECK, MCCAFFERTY, MCKEEVER of A.D. Sworn and Subscibed to By: before me this day In the Court of Common Pleas of Cumberland County . . LONG BEACH MORTGAGE COMPANY, A DEL WARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. SHERVONIA JONES (Mortgagor(s) and Record Owner(s)) 367 W. North Street Carlisle, P A 17013 No. 06-4884 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against SHERVONIA JONES by default for want of an Answer. Assess damages as follows: Debt $92,999.01 Interest from 10/17/06 to Date of Sale Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERT AIN ~ THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivere4 to tJ1epk against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at lefast ten d'y; prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237. J .;:. _\~. Joseph A. Goldb~k, r. Attorney for Plain~ I.D. #16137 ) AND NOW Qc..:l: J I ,.:2 (Xl b '-4gmentiS entered in favor of LONG BEACH MORT AGE COMPANY, A DELW ARE CORPORATION and against SHERVONIA JONES by default for want of an Answer and damages assessed in the sum of $92,999.01 as per above certificatio . Pro It 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 DELW ARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff No. 06-4884 vs. SHERVONIA JONES (Mortgagors and Record Owner(s)) 367 W. North Street Carlisle, P A 17013 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. :~.~~ ../ 11~ 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, P A 19106 215-627-1322 WM-0808 .. THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU Wll..L BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF TIllS NOTICE: October 4, 2006 TO: SHERVONIAJONES 367 W, North Street Carlisle, PA 17013 LONG BEACH MORTGAGE COMPANY, A DELW ARE CORPORATION 1270 Northland Drive, Ste, 200 Mendota Heights, MN 55120 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff vs, SHERVONIA JONES (Mortgagor(s) and Record Owner(s)) 367 W. North Street Carlisle, PA 17013 Action of Mortgage Foreclosure Term No. 06-4884 Defendant(s} TO: SHERVONIA JONES 367 W. North Street Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN 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 INF'ORMA TION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TIlAT MAY OFFER LEGAL SERVICES TO ELlGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle. P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 Joseph JI qoUf6ect Jr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr" Esq. Attorney for Plaintiff Suite 5000 -701 Market Street. Philadelphia, P A 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation wi thin 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, SHERVONIA JONES, is about unknown years of age, that Defendant's last known residence is 367 W. North Street, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and sailor,~ivil Relief Action of Congress of 1940 and its Amendments. Date: -'" GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr, Attorney I,D, # 16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELWARE CORPORATION 1270 Northland Drive, Ste, 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs, CIVIL ACTION LAW SHERVONIA JONES (Mortgagor(s) and Record owner(s)) 367 W. North Street Carlisle, PA 17013 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-4884 ORDER FOR JUDGMENT Please enter Judgment in favor of LONG BEACH MORTGAGE COMPANY, A DEL WARE CORPORATION, and against SHERVONIA JONES 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 th~e of ~~ce of the Complaint, in the sum of $92,999.01. \ \// \ l I \. I \ / / \~ i.,) Joseph A. Goldbeck, Jr. '\:'--_ Attorney for Plaintiff GOLDBECK McC BY: JosephA. Gol Attorney for Plainti I hereby certify that the above names are correct and that the preci resi creditor is LONG BEACH MORTGAGE COMPANY, A DEL WARE CO Ste. 200 Mendota Heights, MN 55120 and that the name(s) and last known ad SHERVONIA JONES, 367 W. North Street Carlisle, PA 17013; " ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $76,285.13 Interest from 06/01/2005 through 10/16/2006 $9,511.73 Reasonable Attorney's Fee $3,814.26 Late Charges $592.79 Costs of Suit and Title Search $900.00 Escrow Advance Fees Recoverable Balance $881.00 $92.60 $921.50 $92,999,01 GOLDBECK McCAFF Y & McKEEVER BY: Joseph A. G:~eck,.n-.; Attorney fo' PI" L AND NOW, this :J Ir+- dayof{)c..+ , 2006 damages are assessed as above. i~ ~ ~ ~ ~ tv "{) ("" ~ ~ .(q. \ 6 ~ D , ~ l.S r- ~ ~ J:- r-..:l c:> () ~~ -n Co ::? ~~ fil ::D \ ~...) r"l"i q 1,> : ',~~ ~~ ~ U1 ::..1 .< . ... PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R,C,P 3180-3183 .. Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CIVIL ACTION - LAW SHERVONIA JONES Mortgagor(s) and Record Owner(s) 367 W. North Street Carlisle, P A 17013 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-4884 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $92,999.01 Interest from 10/17/06 to Date of Sale at 9.0500% (Costs to be added) ~ ~ ~ ~ ~ < =w ~ ~ ~~ ~~ ~o u~ ~1~ ~~ ~o.o ~~ 7.~ t.?o ~ ~u 8 ~ ~ ~ ~ ~ ~ ~ t.? 6 ,J tr ~ t.....: o u.J ../ rf.~:. q'c, 0'.'. :. .0.- ;l uJ u-::c t- '6 ,;, .. ;:::; .!:-- a3 I;/'l~"'" ~o~~ ~"'d~- o~1::l0 ....81;/'l~ <~'€< ~ "'d 0 p...~ o ~',Z.~ ~~~~ ~"'-"t-~ ~~\OU I;/'l ~~ ~ o '6 - lD 0' ~.~-':-- ~ ,c; - C'? ,...- <.-) c:> ...p CC' c:::> ,:-1 ~;1~,~ :5 o ~ ..... ~ e ai ~.i O~ 100 ~~ ~~ ~= f;Iil ~ \ ~.~ --.d1 ~~ -<) \ C ~ . . \J) C'( --~ ~ ... .... ... .. .... - \ a g ~~ .... ... ... ... , \) 11) . ~ - .. .... ... ~ .... ~ ':;l o .~ ~~ 'dp... 'O~ t.?r.S .J.~ e .g.o ~~ o .... \ a ::r . ~ - ......... a3 100 "'a ~ ~ ~u ~ ~ ~ g \0 o~ 0 ~~"Oc;. oa~g-~ ~~hJ)<~ };."'d.....p...~ ~.s~ ~t- ~~~:a~ uS~,B<.A i~C;~N ;J.\t-;a ~g p... ~o _lr'\ ~2 .~ ~ 'Z) () d ~ l/,) 'bf- . - "6). ... -J ~ .... ..... ~ ~.. ~ Q-- C ~~ C"( -- 1st All that certain messuage and lot of ground situate in the Fourth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows, to wit: Being Lot No. 185 on the General Plan of Additional Building Lots laid out by George L. Germeyer, Jr., in the Fourth Ward of the Borough of Carlisle, aforesaid, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, aforesaid, in Miscellaneous Docket No, 9, Page 80, bounded and described as follows, to wit: On the South by West North Street; on the East by lot now or formerly of William Miller, on the North by and alley 12 feet wide; and on the West by lot now or formerly ofW.S, Greason, Containing 30 feet in front on North Street, and extending at an even width 120 feet in front on North Street, and extending at an even width 120 feet in depth to the alley aforesaid; having thereon erected a two-story frame dwelling house with a two-story frame back-building and other improvements municipally known and numbered as 367 West North Street, Carlisle, Pennsylvania, Tax parcel no: 05-20-1798-182 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4884 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELW ARE CORPORATION, Plaintiff (s) From SHERVONIA JONES (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $92,999.01 L.L. $.50 Interest FROM 10/17/06 TO DATE OF SALE AT 9.0500% Atty's Conun % Atty Paid $114.40 Plaintiff Paid Date: OCTOBER 31,2006 Due Prothy $1.00 Other Costs C (Seal) Deputy REQUESTING PARTY: Name JOSEPH A, GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 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 DELW ARE CORPORATION 1270 Northland Drive, Ste, 200 Mendota Heights, MN 55120 Plaintiff IN THE COURT OF COMMON PLEAS vs, of Cumberland County SHERVONIAJONES Mortgagor(s) and Record Owner(s) 367 W. North Street Carlisle, PA 17013 CIVIL ACTION - LAW Defendant( s) ACTION OF MORTGAGE FORECLOSURE NO, 06-4884 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney action, and I further certify that this property is subject to Act 91 of 1983 and t the provisions of the Act. rd for the Plaintiff in this PIa' i' as complied with all Joseph A. be k, Jr, Attorney t:: 1"....) -::;> ~,;;;".) <::r" o n -\ c...J o -n -~ :::r.-n nlp= :f18 . ~~ ~~}, :~~~ '';?- ~~ ~lli ->- :]:= \9 (...'1 \. --".. Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr, Attorney I.D, #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELWARE CORPORATION 1270 Northland Drive, Ste, 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW SHERVONIAJONES (Mortgagor(s) and Record Owner(s)) 367 W. North Street Carlisle, PA 17013 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No, 06-4884 AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, ADELWARE 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: 367 W. North Street Carlisle, P A 17013 I.Name and address of Owner(s) or Reputed Owner(s): SHERVONIA JONES 367 W, North Street Carlisle, PA 17013 2. Name and address ofDefendant(s) in the judgment: SHERVONIA JONES 367 W. North Street Carlisle, P A 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ~ ..,.. 5, Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 367 W. North Street Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the nalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBECK McC E BY: Joseph A. Gold eck, Attorney for Plainti DATED: October 27.2006 Q S.o;c "':;-. r-.:> ,= c':"':3 c::i" o c" -\ (...) ~~ :1.-n PiC '~""10 -'\ \_; "-:t ~?, '~~) :--;:':::,l. ~?tn .."~:"" -p -:;:,-",. ......0 (..1"\ - ""J ::'< It 06-4884 .~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DEL WARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. SHERVONIAJONES Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 367 W. North Street Carlisle, P A 17013 Term No. 06-4884 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JONES, SHERVONIA SHERVONIA .JONES 367 W. North Street Carlisle, P A 17013 Your house at 367 W. North Street, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 07,2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $92,999.0 1 obtained by LONG BEACH MORTGAGE COMPANY, A DEL W ARE 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 DELW ARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. ~ . 06-4884 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of7 1 7-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 o <;=- ~ ~ c::-..> {:)'" o (0 (,;.) ,-p- c,'\ - i' ~~:!~;-Cl ~--,._.",. ':~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttoI'l}eY I.D.#16132 .' Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELW ARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 WM-0808 CF: 08/2212006 SD: 03/0712007 $92,999.01 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE SHERVONIA JONES Mortgagor(s) and Record Owner(s) Term No. 06-4884 367 W. North Street Carlisle, P A 17013 Defendant( s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ~ Personal Service by the Sheriffs Office/1l8IRpet.!l'1lt Malt (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 Mfidavit 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. - . 1 i~~: .. (0 I: ia::ll..j 1:1: III Iu> ll../ i~~! i i ~I Ii! 01 I~OI i.~ - 1:0 i ,-0 }_ i ..'J 1ti;. 'J~ tff ~~L ill15jz ~J~ II ~j ~~ ! ll.. ;c r:. b 15 lj f ~~ I J '~3~ i Jlh ! I)Ji I~ ~ ! ,i i I i a 0000 61 ~ i I I ~ 2 ! i S ~ i i ~I~ II~ o~ ~ ~gi!~ I!i=>-~~ ~ 00 _j ~I-~Ql ~ 000001 ! ::iE 3m J! ! 100016 \' :O()Q..() I ( I I ! I i ! ! ! I ~ ! I! )Z ti ,:OJ ~ w~: ji 1'0 ~J': ! (I).... : I ~otifNI: i Uo~..Jf') '2W~o::WlI)i ftIlXl II( ~ ... . ;9~:E..J~i ~g5~X;i :..... ""0....n.... , ~ IL._N I irli~ ~ ~ Eg iil~o:: ::::Jw' ~ Q.. 1:: Q ..... u. &,:2 ~ o o.lD 0 I-::J! ... ZCl)~ ..... W:2QlIt):( ~ t5 3: 101~ <_'t)N~ Q..oi~::J w iE ml~ ~~mQ~ Q.. lD I Q..1I , i N ;(") ..; & 0 ~~ I IJJi ~~ ff -l ~ .',- Q€\J : t ~i Q5: :!1 I ~ 't 28 I c rS:. .."'!l I 0 ~t>'jj~'1 N I I 1: ~ [dfP ~ e I ! ~ ~ ~.:i ~ If I i ~~ ;5~O ~ U) Q~./hvn <'v g !!i ! ' ~ 00 I I I f; I I ~ i I a. I I ! ,Lri c . II. 1: '0 II. i :I .. I 0 JZ .E I J I I I ~ go I :1 Q. S 15 I ~ " 0- J 0- I~ N ll'! a I~ ..- i il !!::. f3 N rn f w J<" z 0 LL .., g <C '151 co z 10 f') 2 0 z~ ~ ~ ~ ~I w . . :I: cd i""': ;co ~ 3: rn , ... Long Beach Mortgage Company, A Delaware Corporation VS Shervonia Jones In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-4884 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on December 13,2006 at 1937 hours, he served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Shervonia Jones, by making known unto Shervonia Jones personally, at 367 W. North Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 17,2007 at 1554 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 Shervonia Jones located at 367 W. North Street, Carlisle, 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 defendant, to wit: Shervonia Jones, by regular mail to her last known address of 367 West North Street, Carlisle, P A 17013. This letter was mailed under the date of January 12, 2007 and never returned to the Sheriffs Office. So Answers: r~/~ , R. Thomas Kline, Sheriff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 , , Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-825-6320 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. SHERVONIA JONES Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 367 W. North Street Carlisle, P A 17013 Term No. 06-4884 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, ADELWARE 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: 367 W. North Street Carlisle, PA 17013 I.Name and address ofOwner(s) or Reputed Owner(s): SHERVONIA JONES 367 W. North Street Carlisle, P A 17013 2. Name and address ofDefendant(s) in the judgment: SHERVONIAJONES 367 W. North Street Carlisle, P A 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: , .~ J. 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 367 W. North Street Carlisle, P A 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: February 21,2007 o c: '-- 'C5 ::3 ~-',"" -'- ~,.$' ..,. ?0 \ CO -c _,r ~> ~ .-l :r: -n \lip --,-.(1\. :;)q . ~\ ..... ~::~ ~)\ .~.~~ S ~'j:? :2. '!! N - -- COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Residential Funding Co LLC is the grantee the same having been sold to said grantee on the 7th day of march A.D., 2007, under and by virtue of a writ Execution issued on the 31 st day of Oct, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 4884, at the suit of Long Beach Mtg Co against Shervonia Jones is duly recorded in Deed Book No. 279, Page 1376. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this Ilh day of -~ , A.D. ~oO 7 ~f3_~/~ Recorder of Deeds ~ of Deecia. l,;lImbet1end~. CdIIe. PA ~~ &pns tie FiIIt MoftdIyol JIn. 2010 { ~ -- Long Beach Mortgage Company, A Delaware Corporation VS Shervonia Jones ill the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-4884 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on December 13,2006 at 1937 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: Shervonia Jones, by making known unto Shervonia Jones personally, at 367 W. North Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy ofthe same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 17, 2007 at 1554 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 Shervonia Jones located at 367 W. North Street, Carlisle, 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 defendant, to wit: Shervonia Jones, by regular mail to her last known address of 367 West North Street, Carlisle, P A 17013. This letter was mailed under the date of January 12,2007 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 March 07, 2007 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Attorney Joseph Goldbeck, on behalf of Residential Funding Company, LLC. It being the highest bid and best price received for the same, Residential Funding Company, LLC, of 4828 Loop Central Drive, Houston, TX 77081, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$ 910.78. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail $30.00 17.86 15.00 15.00 30.00 10.00 .50 1.00 8.80 1.22 , t f Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed So Answers: r:~ ~~ R. Thomas Klint S'h:riff -- 15.00 20.00 355.00 310.07 16.83 25.00 39.50 $ 910.78 y ~Jd.1JO 7 9.- ~bP- jO-{J-O 1.50 ~S7t)J:U 02u. /t(b(,~t ~ . ; Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney J.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DEL WARE CORPORA nON 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. SHERVONIA JONES (Mortgagor(s) and Record Owner(s)) 367 W. North Street Carlisle, P A 17013 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-4884 AFFIDAVIT PURSUANT TO RULE 3129 LONG BEACH MORTGAGE COMPANY, A DEL WARE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 367 W. North Street Carlisle, P A 17013 l.Name and address ofOwner(s) or Reputed Owner(s): SHERVONIA JONES 367 W. North Street Carlisle, P A 17013 2. Name and address ofDefendant(s) in the judgment: SHERVONIA JONES 367 W. North Street Carlisle, P A 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, P A 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: , . , 5. Name and address of every oth... p"""n who has any record mfer",' m or record lien on the property and whose in'erest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record mterest in the property which may be affected by the sale. 7. Name and address of every oth... person of whom the plaintiff has knowledge who has any mt...es' in the property wlU,h may be affected by the sale. TENANTS/OCCUPANTS 367 W. North Street Carlisle, P A 170 I3 (attach separate sheet ifmore space is needed) I verify that the statements made m this affidavit are true and "">Teet to the best of my P"""nal knowledge or infonnation and belief. I understand that false statemen" herem are made subject to the nalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: October 27, 2006 GOLDBECK McC E BY: Joseph A. Gold eck, Attorney for Plainti -- -- -- 06-4884 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff LONG BEACH MORTGAGE COMPANY, A DELWARE CORPORATION 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION - LAW SHERVONIA JONES Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 367 W. North Street Carlisle, P A 17013 Tenn No. 06-4884 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. TO: JONES, SHERVONlA SHERVONIA .JONES 367 W. North Street Carlisle, P A 17013 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To prevent this Sheriffs Sale you must take immediate action: NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE Your house at 367 W. North Street, Carlisle, PAl 70 1 3 is scheduled to be sold at Sheriffs Sale on Wednesday, March 07, 2007, at 10:00 AM, in COmmissioners Hearing Rm 2nd FL Courthouse to enforce the coUrt judgment of$92,999.01 obtained by LONG BEACH MORTGAGE COMPANY, A DELW ARE CORPORATION against you. 1. The sale will be cancelled if you pay to LONG BEACH MORTGAGE COMPANY, A DEL WARE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open jUdgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. r 06-4884 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 STll..L BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. Yon may be able to petitioo the COUrt to set aside the sale if the bid price -. 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 Sheriffwithin 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND our WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 -- All that certain messuage and lot of ground situate in the Fourth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows, to wit: Being Lot No. 185 on the General Plan of Additional Building Lots laid out by George L. Genneyer, Jr., in the Fourth Ward of the Borough of Carlisle, aforesaid, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, aforesaid, in Miscellaneous Docket No.9, Page 80, bounded and described as follows, to wit: On the South by West North Street; on the East by lot now or formerly of William Miller, on the North by and alley 12 feet wide; and on the West by lot now or formerly of W. S. Greason. Containing 30 feet in front on North Street, and extending at an even width 120 feet in front on North Street, and extending at an even width 120 feet in depth to the alley aforesaid; having thereon erected a two-story frame dwelling house with a two-story frame back-building and other improvements municipally known and numbered as 367 West North Street, Carlisle, Pennsylvania. Tax parcel no: 05-20-1798-182 - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-4884 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LONG BEACH MORTGAGE COMPANY, A DELWARE CORPORATION, PIaintiff(s) From SHERVONIA JONES (I) You are directed to levy upon the property of the defendant (s )and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied Upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is eIijoined as above stated. Amount Due $92,999.01 L.L. $.50 Interest FROM 10/17/06 TO DATE OF SALE AT 9.0500% Atty's Comm % Atty Paid $114.40 Plaintiff Paid Date: OCTOBER 31,2006 Due Pro thy $1.00 Other Costs (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Deputy ~ ~ ~ ~ Real Estate Sale # 28 On November 6, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A Known and numbered as 367 W. North Street, Carlisle, more fully described on Exhibit" A" filed with this writ and by this reference incorporated herein. Date: November 6, 2006 By:. , Sh' , JOG~vl '- vvUJ~ . Real Estate Sergeant II :\\ '\! 1- ^ON qnOZ ,-..:: r...i _ .~;; \ t13 1:"\ S ~-_' 1 '"J PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cwnberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cwnberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and Slale 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 fol1owing dates, V1Z: - - January 26, FebrullrJ:: 2 and February 9,2007 = Affiant further deposes that he is authorized to verify this statement by the Cwnberland 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. 28 Writ No. 2006-4884 Civil Long Beach Mortgage Company, A Delaware Corporation vs. Shervonia Jones Atty.: Joseph Goldbeck All that certain messuage and lot of ground situate in the Fourth Ward of the Borough of Carlisle, Cumber- land County, Pennsylvania, bound- ed and deSCribed as follows, to wit: Being Lot No. 185 on the Gen- eral Plan of Additional Building Lots laid out by George L. Germeyer, Jr., in the Fourth Ward of the Borough of Carlisle, aforesaid, which Plan is recorded in the Office of the Re- corder of Deeds in and for Cumber- land County, aforesaid, in Miscella- NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle 8oro, Cumberland County My Commission Expires March 5, 2009 - J. .., 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. Deonlson, heiog duly SWom acoo'ding to law, deposes aod ssyoc Thst be is the ASSistaot Cootrolle, of The Patriot News Co., a '''pomtioo o'gsoized aod existiog uod" the laws of the Commonwealth ofPen",ylvaoia. with;,s principal om" sod pia" ofh",ioess st 812 to 8i8 M"ket Street, in the City of Hanisbmg, County ofDaupbin, State ofPen"'Ylvania, own" sod publisb" of The Patriot. News aod The Suoday Patriot. News newspapers of geoe",1 ''''ulation, p'inted sod publisbed " 812 to 818 M"ket Street, in tbe City, County sod State sforessid; tbst The Patriot.News sod The Sunday Patriot.News were established Ma"b 4th, 1854, and Septemb" 18th, 1949, respectively, and all have been oontinuo",ly published ev" SInce; That the printed noti" 0' publi,ation which is secmely attached hemo is exactly as p'inted and published io theu regul" daily sodlo, SUnday/ Metro editio", which appmed in the 24th and 31st day(s) of Jsonary aod the 7tli day(s) of Feb,uary 2007. That neith" he no, ssid Compsoy is ioterested in the subject ""'''''' of ssid p'inted noti" 0' advertiSing, aod tbat all of the allegatioos of this statemeot as to the time, place sod ,bam't" of publication are true; and That he has p"sonal knOWledge of the facts sforesaid aod is duly autho'ized sod empowe"d to V"ify this statement 00 behalf of The Patriot.News Co. aforessid by virtue sod pmsuant to a resolution unsnimo",ly passed and adopted "vemlly by the sto'kholden; and bO"d of dire'ton; of the ssid Company and subsequently duiy ",..ded in tbe om" f.. the Ree"ding ofDeeds in and fo, said County ofDauphin in Miseeilaneo", Book "M", Volume 14, Page 317. PUBLICATION Copy S ALE #28 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 --..~."Iotot .... .,....."." rI~~~ .1....... .1' .........~. .. 1 ~~~....~ ...~.. ~......,........,. CiellteL ~- ~ ~fllec'" ., of IIIe