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Home My WebLink About06-4930GOLDBECK 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 OL. -4?36 Ctu?ttc r GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 VS. MARY K. MULLHOLLAN JOHN P. MULLHOLLAN Mortgagors and Real Owners 1308 Mallard Drive Camp Hill, PA 17011 Plaintiff Defendants CIVIL ACWN: MORTQAGE FORECLO"IF NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O 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 NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUT ABAJO. ESTA OFICINA PUEDE PROVEERR CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, PSTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call 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.eov 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 GMAC-0066. Para informacion en espanol puede communicarse 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 GMAC MORTGAGE CORPORATION, 3451 Hammond Avenue, Waterloo, IA 50702. 2. The names and addresses of the Defendants are MARY K. MULLHOLLAN, 1308 Mallard Drive, Camp Hill, PA 17011 and JOHN P. MULLHOLLAN, 1308 Mallard Drive, Camp Hill, PA 17011, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On January 09, 1996 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to HART MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1299, Page 329. The mortgage has been assigned to: GMAC MORTGAGE CORPORATION by assignment of Mortgage, which is lodged for recording. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May 01, 2006 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance Interest from 04/01/2006 through 08/31/2006 at 7.6250% Per Diem interest rate at $16.66 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 05/01/2006 to 08/31/2006 Monthly late charge amount at $43.46 Costs of suit and Title Search Corporate Advance Escrow Monthly Escrow amount $271.16 $79,744.01 $2,548.98 $3,987.20 $173.84 $900.00 $101.86 $559.18 $88,015.07 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 is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in ILersonam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $88,015.07, together with interest at the rate of $16.66, 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 Sheriff's Sale of the Property. G DB CK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Robert Lelli, 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: S Wra/k// G C TGAGE CORPORATION E?Q,-hi6itA EXHIBIT "A7 • AT,L 2NAT CERTAIN plot o ground situate in the rownship?4'Bast Penaeboloc Connty OI Cumberland and state of Pennsylvania, bounded and desori ed as follows, to wit, BEGINNING at a point on the wort side of Mallard Road at the corner of Lot No. 92 an shown in the hereinafter mentioned plan of Iota) thence along the line of said Lot tic. 91, south 79 degrees 24 minutes went, one hundred twenty-ono and sixty-two hundredths {121.81) feet to a point; thence along other land now or formerly of Clyde o. smyssr and Esther smyear, his wife, north 18 degrees 23 minutes west, eighty-five and seventy-nine hundredths 185.79) feet to a point; thence along the line of Lot No. 94, as shown in the hereinafter mentioned plan of Iota, north 79 degrees 24 minutes east, one hundred thirty-three and twenty-four hundredths (133.24) feet to a point on the west aide of Mallard Road aforesaid; thence along the want side of Mallard Road, south 10 degrees 36 minutes east eighty-five (85) feet to a point at the corner of Lot No. 92 aforesaid the place of BEGINNING. aDING Lot Mo. 93 in the plan of lots known as Plan No. 3, wart croak Hills, laid out by D.P. Raffoneperger on J%ly 16, 1967 And revised November 21, 1967, said revised plan being recorded in the office of the Recorder of Deeds in and for Cumberland county in Plan Book 19, at page 47. RAVING thereon erected a brick and aluminum bi-laval dvalling, known and numbered as 1308 Mallard Road. F x' Socd,283 PARE 335 a ord ; Fer y naylvdnia )) d ?? `ph mend f SS d f o off)ce tot the r '{.YA,1fjt)yt1 betand Cou??dtdV of Dead,; [his J'}jaf of Gffl e / 79 (P Ey,ki6it B 08/21/06 11:20 FAR MORTGAGE LOAN SERV R002/007 GMAC Mortgage Corporation 3451 Hammond Ayenne Waterloo 1A $0702 Date: 07/03106 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thr i 20 offleial notice flat the mortgaoe on your home is in default, and the lender ialends to fo om SDeeifte information about the nature of the default is provided in the atmdAW Daacs The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may he le to help to save your home. This Notice explains how the program works. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may she want to contact an attorney in your area. The local bar association may be able to help you fled a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VI%UNDO EN SU CASA. S1 NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION 1NMEDIA.TAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PURDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM," EL CUAL PUEDE SALVAR SU CASA DE LA PERDH)A DEL DERECHO A REDIMM SU HIPOTECA. HOMEOWNER'S NAME(S): ADDRESS: LOAN ACCOUNT NUMBER: ORIGINAL LENDER: CURRENT LENDERISERVICRR: JOHN P. MULHOLLAN 1308 MALLARD DR CAMP HILL PA 17011 0306833403 GMAC Mortgage Corporation GMAC Mortgage Corporation 3451 Hammond Avenue Waterloo IA 50702 Date: 07/03/06 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM," EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): ADDRESS: LOAN ACCOUNT NUMBER: ORIGINAL LENDER: CURRENT LENDER/SERVICER: MARY K. MULLHOLLAN 1308 MALLARD DR CAMP HILL PA 17011 0306833403 GMAC Mortgage Corporation This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one 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 names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender is on your property located at 1308 MALLARD DR CAMP HILL PA 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 05101106 through 07/01/06. See attached Exhibit for payment breakdown. Monthly Payments $ 2607.78 Late Charges $ 65.08 NSF $ 0.00 Inspections $ 71.86 Other (Default Expenses and Fees) $ 0.00 Optional Insurance $ 30.00 Suspense $ 0.00 TOTAL AMOUNT PAST DUE: $ 2774.72 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 2774.72, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check or certified check made payable and sent to: GMAC Mortgage Corporation ATTN: Payment Processing 3451 Hammond Avenue Waterloo IA 50702 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) Not Applicable IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the 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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYS ,period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, You still have the right to cure the default and prevent the mortaQe. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: GMAC Mortgage Corporation Address: 3451 Hammond Avenue Waterloo I IA 50702 Phone Number: 800-850-4622 Fax Number: 319-236-7437 Contact Person: Collection Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTAGE - You MAY or MAY 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 ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ENCLOSED Applicable law requires us to inform you we are attempting to collect a debt and any information you provide will be used for that purpose. If you disagree with our assertion that a default has occurred with your mortgage loan, please contact our office immediately at 800-850-4622 and speak with one of our loan counseling representatives. Thank you for your prompt response concerning this matter. Collection Department Loan Servicing 5041 EXHIBIT 05/01/06 through 07/01/06 Mo. Pmt. Amt. $ 879.26 io. UZ N CV) tv -?i A. SHERIFF'S RETURN - REGULAR CASE NO: 2006-04930 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS MULLHOLLAN MARY K ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MTTT.T.T40T.T.ANT MAPV V the DEFENDANT , at 1912:00 HOURS, on the 28th day of August , 2006 at 1308 MALLARD ROAD CAMP HILL, PA 17011 JOHN P MULLHOLLAN, HUSBAND by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13.20 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 41.20,/ 08/29/2006 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: before me this day eputy Sherif of A.D. *- ("ASE NO: 2006-04930 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ('MAC MORTGAGE CORPORATION VS NULLHOLLAN MARY K ET AL S3ARON LANTZ , Sheriff or Deputy Sheriff of 0imberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MULLHOLLAN JOHN P the DEFENDANT , at 1912:00 HOURS, on the 28th day of August , 2006 at 1308 MALLARD ROAD CAMP HILL, PA 17011 JOHN P MULLHOLLAN by handing to a :rue and attested copy of COMPLAINT - MORT FORE together with anc'. at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 ` Se:-vice .00 j` ?P Af:=idavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00/ 08/29/2006 GOLDBECK MCCAFFERTY MCKEEVER Swozn and Subscibed to By: before me this day eputy her ff of A.D. fi GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION 3451 Hammond Avenue Waterloo, IA 50702 Plaintiff VS. MARY K. MULLHOLLAN JOHN P. MULLHOLLAN Mortgagors and Record owners 1308 Mallard Drive Camp Hill, PA 17011 NO. 06-4930 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Lisa A. Lee Attorney for OF n?or?arrorMnr 2009 OCT -- i PM 3: 05 CUM ; : s 1 v? UNTY PENNSMANA