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Home My WebLink About06-5449 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, P A 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Ol. - .sl.Jq~ (]1t;,CT~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LA W vs. TONY A D. MORRIS Mortgagor and Real Owner 205 W. Springville Road Boiling Springs, PA 17007 ACTION OF MORTGAGE FORECLOSURE Defendant Term CIVIL AerION: MQiqTGAGE ~rcL08U~E 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 INFORMA nON ABOUT HIRING A LA WYER. 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 ASSOCIA nON 2 Liberty Avenue Carlisle, P A 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENT ADAS, ES ABSOLUT AMENTE 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 EST A DEMANDA. RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A 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, V A Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE P AGARLE A UN ABOGADO, EST A OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 TIDS 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 ofthe 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 800-211-6926 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 AMQ-I086. Para informacion en espanol puede communicarse con Loretta aI215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The name and address of the Defendant is TONY A D. MORRIS, 205 W. Springville Road, Boiling Springs, P A 17007, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On September 10, 2004 mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1882, Page 3010. The mortgage has been assigned to: WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 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 January 01, 2006, 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 12/01/2005 through 09/30/2006 at 7.8500% Per Diem interest rate at $29.14 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 01/01/2006 to 09/30/2006 Monthly late charge amount at $58.59 Costs of suit and Title Search Fees Recoverable Balance Suspense Balance $133,635.52 $8,858.56 $6,681.78 $878.85 $900.00 $106.00 $1,345.00 -$70.20 $152,335.51 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff 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 personam" judgment) against the Defendant in this Action but reserves it's right to bring a separate Action to establish that right, ifsuch 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 oflntention 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 $152,335.51, together with interest at the rate of $29.14, 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. By: ~~~~~CL L ECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 1,_ Nanci Jimenez -' 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:Q3. IS. oC ~i6it jl , . Stewart Title Guaranty Company SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Policy is described as follows. ALl. THAT CERTAIN lot of ground situate in South Middletown Township, Cumberland County. Pennsylvania, bounded and described as follows BEGINNING at a point on the south side of Springville Road, T-537, at line of land now or formerly of Raymond E Diehl; thence by said Diehl land South 20 degrees 39 minutes East 150.73 feet to a point; thence by land of John P. McCoy et ai., South 75 degrees West 136.05 feet to a point; thence by Lot NO.5 of the hereinafter mentioned Subdivision Plan North 15 degrees West 150 feet to a point on the south side of said Road; thence by the south side of said Road North 75 degrees East 121 21 feet to a point, the place of of BEGINNING. CONTAINING 19,297 square feet, more or less SUBJECT, HOWEVER, to a 15 foot drainage easement along the western Side thereof as shown on said SubdiVISion Plan. IT BEING Lot NO.6 of the Final Subdivision Plan for John P. McCoy, et ai, as recorded in the office of the F~ecorder of Deeds In and for Cumberland County, Pennsylvania, in Plan Book 38. page 9 Parcel #-10-28-2098-032 i'd.TA. PoliCY SchedUlE:; C (2004080235 P "'0/2004080235122) ~i6it cB ~ r!mAMC P.O. Bo, "000 MORTGAGE SERVICES SaDta_An~.C~_91711-10()() July 18, 2006 #BWNKZZS TONY A D MORRIS 205 W SPRINGVlLLE RD BOILING SPRINGS, PA 17007-9530 2 I NMR 1,.,111."111",11",1",11,1,,, 1.1,.,11,11,.,11,. ,,1,1 ",11,1 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS OFPOLIC~ Loan Number: Property Address: Original Lender: Current LenderlServicer: 0093042489 205 W SPRINGVILLE RD, BOILING SPRINGS PA,17007 AMC Mortgage Services, Inc. AMC Mortgage Services, Inc. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the morte:ae:e on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pae:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour ~ome. This Notice explains how the proe:ram works. To see if HE MAP 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 Counseline: Ae:ency. The name. address and phone number of Consumer Credit CounseIine: ARencies servine: your County are listed at the end of tbis Notice. If vou have any Questions, you may call the Pennsvlvania Housine: Finance ~~ncy toll free at 1-800-342-2397.(persons with impaired hearine: can call (717) 780-1869). This Notice contains important legal infonnation. If you have any questions, representatives atthe Consumer Credit Coucseling Agency ma)' 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. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ["f' "",1" /,!~;rf";~... 0" /\Jso doing business as Delaware AMC Mortgage Services, Ine, in the states of Texas. Rhode Island, and New Hampshire _\RRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAI.Y AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 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 offoreclosure Ol' 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. TIDS M~~TfflGJ~!!J1'.LQ.n21J...!!. WrrIDN THE NE~IJ30) DAYS. IF YOU DO NOT APP!:Y FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTgAGE lJP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE QEfAlJLT" EXPLAINS HOW TO-SRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the l::_c:l.l!!!umer credit counseling ag(:l!~yJiJ;1ed ~11l1..~_end_of this notice. the lender may NOT take action a~ainst you for thirty (30) dayS after the date ()f this meetingTh~ lllllIles, adclresses and telep_holl(:n!l!l!~r~~fd_es~natedc.(m~um~rcredit991111s_(:ling agencies for the county in which the property is locate<tare_s<<tforth_atthe end oftl1i~J\rotic~. It is only necessary to schedule one fa;;Ho-face meeting Advise your lender iIllIIlediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in a default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) !fyou 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 Honsing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days ofyonr face-to-face meeting YOU MUST FU,E YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FO"!:,I,OW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE >,.,~(HSTANCE WILl. BE DENTED. 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 six!" (60) days to make II 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. F~'lll("').Nrpl:>-')", July 18, 2006 Loan Number: 0093042489 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 Emer"{enc)' Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Drin!! it uo to date). NATURE OF THE DEF AUL T -The MORTGAGE debt by the above lender on your pIOperty located at: 205 W SPRINGVILLE RD, BOILING SPRINGS, PA 17007 IS SERIOUSLY IN DEFAULT because: A. YOU HA VB NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 01/01106 thru 07/01/06 at $976.51 per month Monthly Payments plus late charge or other fees: $8900.63 Total Amount to Cure Default: $8900.63 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not aoplicable): N/A HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date ofthis notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER., WHICH IS $8900.63 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cll.shier's~heck, certified check or money order made payable and sent t(): AMC Mortgage Services 505 City Parkway West, Suite #100 Orange, CA 92868 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use ifnot applicable.) N/A IF YOU DO NOT CURE THE DEFAUL T--Ifyou do not cure the default within THIRTY (30) DAYS of the date of this Notice, thele~~e!"j~te!lJJ!!t(Ll<.x~rci!!l<its xigbt~to_!!ccelerate the m~r1!!a!!e d~l!t. 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) DA YS, the lender also intends to instruct its attorneys to sta111egal action to fQ~Jo~~lIRl)nY~l.IrlJl()rtgl!ged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property wm be sold by the Sheriff to payoff the mortgage debt: If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal pIOceedings against you, you wm still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings Me 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 wm be added to the amount you owe the lender, which may also include other reasonable costs. I(youeure the clefau!t lVi~hi!l the THIRTY (30) DAY period, you will not be required to pay attorney's f!~~ 9THER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all ()ther 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, }'OJU1illhaYetbeligbno~e1b_~Lckfanlt a_nQJ>!€:yenLtl1e sale~ any time up to one hour before the Sheriffs Sale. You may do so by payin~ the total amount !hen past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's _Saleas~~ifi_ell in writing by the lemler and by EF04QK/NCPj2-OS perfonningany other reqllirements under the mQrtgage. 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 Sheriffs Sale of the mortgaged property could be held would be approximately (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender HOW TO CONTACT THE LENDER: AMC Mortgage Services PO B01 11000 Santa Ana, CA 92711-1000 Phone Number 800-430-5262 Fax Number 714-347-5037 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time ASSUMPTION OF MORTGAGE -- Y ou ~ may or ~ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and ilUomey'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 PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. :: TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. x TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL T 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 OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, " TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. x TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED Very Truly Yours, AMC Mortgage Services Cc. AMC Mortgage Services Attn: Collections Department Loan Number: 0093042489 Mailed by 1st Class Mail and by Certified Mail ::F040L!NCP!2-iJ5 Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, P A 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, P A 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHI"A 2 i 1 North Front Street Harrisburg, P A 17110 1-800-342-2397 APAO~l!NCP,12-l)5 7=>0~ ~ ~ ~ V'\ " )J C> ~ ~ ~ }J ~ f. ~ -L.... ,"",__.1 j" ,:, .=~ -.- c:~. ,. \~ " B \ In the ~ourt of Common Pleas of Cumberland County . WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 . Orange, CA 92868 Plaintiff vs. TONY A D. MORRIS (Mortgagor(s) and Record Owner(s)) 205 W. Springville Road Boiling Springs, P A 17007 No. 06-5449 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 TONY A D. MORRIS by default for want of an Answer. Assess damages as follows: $153,443.45 Debt Interest from NOV. 04,2006 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 CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occ ed and at least ten days p or 0 the ate of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 AND NOW ../I)6('? ,;:) D6~ , Judgment is entered in favor ofWM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE and against TONY A D. MORRIS by default for want of an Answer and damages assessed in the sum of$153,443.45 as per the above certifi ion. . Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff No. 06-5449 vs. TONY A D. MORRIS (Mortgagors and Record Owner(s)) 205 W. Springville Road Boiling Springs, P A 17007 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. By: If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 11 AMQ-I086 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 23, 2006 TO: TONYA D. MORRIS 205 W. Springville Road Boiling Springs, P A 17007 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. TONY A D. MORRIS (Mortgagor(s) and Record Owner(s)) 205 W. Springville Road Boiling Springs, P A 17007 ACTION OF MORTGAGE FORECLOSURE Defendant(s) Term No. 06-5449 TO: TONYA D. MORRIS 205 W. Springvi11e Road Boiling Springs, P A 17007 IMPORT A NT NOTICF. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITInN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGmLE 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 C McCAFFER B oseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon htdependence Center 70 I MaIket Street Philadelphia, PA 19106 215-627-1322 AMQ-1086 .. TIDS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATIEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 23, 2006 TO: TONYA D. MORRIS 312A Zion Road Mt Holly Springs, P A 17065 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. TONYA D. MORRIS (Mortgagor(s) and Record Owner(s)) 205 W. Springville Road Boiling Springs, P A 17007 Term No. 06-5449 Defendant(s} TO: TONYA D. MORRIS 312A Zion Road Mt. Holly Springs. P A 17065 IMPORT ANT NOTIC.R YOU ARE IN DEFAULT BECAUSE YOU HAVE FAll...ED TO ENTER. A WRITIEN APPEARANCE PERSONALLY OR BY ATfORNEY AND FILE IN WRITING wrm TIlE COURT YOUR DEFENSES OR OBJECTIONS TO TIlE CLAIMS SET FORm AGAINST YOU. UNLESS YOU ACf WITHIN TEN (10) DAYS FROM TIlE DATE OF lHIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERlY OR OTIIER IMPORTANT RlGHfS. YOU SHOUlD TAKE TInS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SEf FORm BELOW. TInS OFFICE CAN PROVIDE YOU wrm INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TIIAT MAY OFFER LEGAL SERVICES TO EliGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INe 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUN1Y BAR ASSOCIATION 2 Libaty Avenue Carlisle, P A 17013 JOSeph fl. qoftf6ec~ Jr GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 -701 Marlcet Street. Philadelphia, PA 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-Mili tary Service are true and correct to the best of my knowledge, informdtion 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, TaNYA D. MORRIS, is about unknown years of age, that Defendant's last known residence is 312A Zion Road, Mt. Holly Springs, PA 17065, and lS 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 wi thin the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and Date: IljlBjvy 11 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney J.D. #16132 . Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PAl 9106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION LAW TONY A D. MORRIS (Mortgagor(s) and Record owner(s)) 205 W. Springville Road Boiling Springs, P A 17007 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-5449 ORDER FOR JUDGMENT Please enter Judgment in favor of WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, and against TONYA D. MORRIS for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Com laint, in the sum of $153,443.45. V I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 and that the name(s) and last known addressees) of the Defendant(s) is/are TONY AD. MORRIS, 312A Zion Road Mt. Holly Springs, PA 17065; J . . ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $133,635.52 Interest from 12/0112005 through 11103/2006 $9,849.32 Reasonable Attorney's Fee $6,681.78 Late Charges $996.03 Costs of Suit and Title Search $900.00 Fees $106.00 Recoverable Balance $1,345.00 Suspense Balance .. ($70.20) Total $153,443.45 AND NOW, this ?-+l dayof.;t.::bu , 2006 damages are assessed as above. . t ^" t -'9- 1t ....() . () ~ ~ '" 0 Q r--:> ~ ~ c.:;:, C e~';:j tn ~ _?r 0' ~ -~,~ ....- ~ C) ~ --..... AS I - -I::. -:t:::> C) ~' t: I' co " - I i>" (..:J :~CJ \.D .< 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, P A 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW TONY A D. MORRIS Mortgagor(s) and Record Owner(s) 205 W. Springville Road Boiling Springs, P A 17007 ACTION OF MORTGAGE FORECLOSURE No. 06-5449 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $153,443.45 Interest from NOV. 04,2006 to Date of Sale at 7.8500% (Costs to be added) I.-' I-< ~ g g ~~ ~ ~ ~ ';t. tu ::=:: I.-' ~ ~ ~ ~ if) j;l ~ g '.0 ~ ......, U ~iP I-< e.J 0 0 o {"- ~~ ~-e""'- ~ ~ ~ -e 0 ~ 'p CloO\ rfJ o:l 0 .a ~OO......N I-la fr~ N ~O~~ 0 .;S ~ rfJ<C,cn ~ ~.s ;g \j.l\l.l "B0<c' O~ p... ~ ~ ~ p...~ ~ O\~ ...... I-< ~ ,.....,.:;i( o:l {"- o8~Po< 0 ~rfJ ~S " ..g l.:= ~ ~..... ~ ~o '$~~~ ~ 0 J:: I ~~ ~: 4. ;;.-. u~~.9:'1/') e";'u ,;, A~.e .a e o 0- 0'.0 ~ ?> 'fr i~O~N 1.-'0.0 ~u <C,o:lo.p. 0 rfJrfJ ~t t:: ~I{"-] Z~ ~~ ~~~~ if) <C, 0 e.J0 Po< ~o -. ~o >" :gO I.-' OIl 0 ..... I-l _I/') 0 ~ o:l N 0 U ~ CO ~ ~.~ ~ U 0 U ::i 6 S rfJ \j.l ~ ~ ~ p... ~ ~ -,.. \:if "(;;~', Cl" c0 Cb ~)':1;.~ ~ ....Ld ~ ;i~ ~ ~ ~}~- \ 3 ~ ~ () V\ . . \J') ~ .;;. rq ~ ... ... ~ ..... ... ... ~ .:~ ;-t" - cO \ ,--) '.-'. , II -;"h.0 u--- ?:: \.,l- o -,~ '(-:) -..;.,- ..-r~ \ , () <) f\ ~ () ~ tio:-~ ...0 ~;-" c;::> (;-1 ..... ... .... - \ ...! V, . ~ - I "'f"O -t - d. 3 ~ ~ -1 ~ iI ~::{ lI) VI ~ ~ c.... C ~ - <:) ~ ~! c l.IJ . , ( - ~ ".,. All that certain lot of ground situate in the South Middletowp. Township, Cumberland County, Pennsylvania, bounded and described as follows: . Beginning at a point on the south side ofSpringVille Road, T-537, at liQ.e ofland now or formerly of Raymond E. Diehl; thence by said Diehl land South 20 degrees 39 minutes East 150.73 feet to a point; thence by land of John P. McCoyet aI., South 75 degrees West 136.05 feet to a point; thence by Lot No. 5 of the hereinafter mentioned Subdivision Plan North 15 degrees West 150 feet to a point on the south side of said Road; thence by the south side of said Road North 75 degrees East 121.21 feet to a point, the place of beginning. Containing 19,297 square feet, more or less. Subject, however, to a 15 foot drainage easement along the western side thereof as shown on said Subdivision Plan. It being Lot No.6 ofthe Final Subdivision Plan for John P. McCoy, et aI., as recorded in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 38, page 9. Parcel #40-28-2098-032 ADDRESS: 205 W. SPRINGVILLE ROAD, BOILING SPRINGS, PA 17007 . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5449 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff (s) From TONY A D. MORRIS (1) You are directed to levy upon the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $153,443.45 L.L. $.50 Interest FROM 11/4/06 TO DATE OF SALE AT 7.8500% Atty's Comm % Atty Paid $120.56 Plaintiff Paid Date: NOVEMBER 8, 2006 Due Prothy $1.00 Other Costs (Seal) ci~!:, By: 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 ..-.tf/J . 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 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW TONY A D. MORRIS (Mortgagor(s) and Record Owner(s)) 205 W. Springville Road Boiling Springs, PAl 7007 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 06-5449 AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 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: 205 W. Springville Road Boiling Springs, P A 17007 l.Name and address ofOwner(s) or Reputed Owner(s): TONY A D. MORRIS 312A Zion Road Mt. Holly Springs, P A 17065 2. Name and address ofDefendant(s) in the judgment: TONY A D. MORRIS 312A Zion Road Mt. Holly Springs, P A 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: iI 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, 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. TENT ANTS/OCCUP ANTS 205 W. Springville Road Boiling Springs, P A 17007 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 3,2006 (1 ~~ r-..:> = c') c..'"' ;A?,: C) -~.::: I OJ .," f.:.~ - 0:::- ) :-:::1 )';> :D -< (.,) \..D -.- 06-5449 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 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange, CA 92868 Plaintiff CIVIL ACTION - LAW vs. TONY A D. MORRIS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 205 W. Springville Road Boiling Springs, PAl 7007 Term No. 06-5449 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: MORRIS, TaNYA D. TaNYA D. MORRIS 312A Zion Road Mt. Holly Springs, P A 17065 Your house at 205 W. Springville Road, Boiling Springs, P A 17007 is scheduled to be sold at Sheriff's Sale on Wednesday, March 07, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$153,443.45 obtained by WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE against you. . NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 .. 06-5449 2. . You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able t6 petition the Court to set aside the sale if the bid price. was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 o s: ~ ~ ~ si \ d) ~ :.? t_ -;, rnr:-~ i::r::, ,,-../ co ." (.., \..0 SHERIFF'S RETURN - REGULAR CASE NO: 2006-05449 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS MORRIS TONYA D SHANNON SHERTZER , Sheriff or Deputy Sheriff of cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MORRIS TONYA D the DEFENDANT , at 1120:00 HOURS, on the 2nd day of October ,2006 at 312A ZION ROAD MT HOLLY SPRINGS, PA 17065 by handing to RICHELLE SHUGHART, DAUGHTER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments --- DEFENDANT IS IN PROCESS OF MOVING FROM 205 W SPRINGVILLE ROAD Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.56 .00 10.00 .00 38.56/ JOllY c v Sworn and Subscibed to .r~~ R. Thomas Kline 10/03/2006 GOLDBECK MCCAFFERTY By: before me this day of A.D. GOLDBECK McCAFFERTY & McKEEVER BY: J08eP-h A. Goldbeck, Jr. Attorney /.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215.627-1322 Attorne for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 AMQ-I086 CF: 09/18/2006 SD: 03/0712007 $153,443.45 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE TONY A D. MORRIS Mortgagor(s) and Record Owner(s) Term No. 06-5449 205 W. Springville Road Boiling Springs, P A 17007 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Y4 ( ) Personal Service by the Sheriffs Office/competent adult (copy ofretum attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). ( ) Pursuant to the Mfidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. ~!.\ !)<Oln ~~ eel 0 11~, l'\ :; C;; llU ci:: ~ i~j 0>9. 0 1 . ~ ~. (.) ~ij"!;~-~ ~ ~I ~ l'1 :E tj li,I'~ ~ ~ fr ~" p 0 U. I ~ \...}. <(:; 0 ~ ~. ::","f ,,," ~ ......._ 0- "'Q,).~~ NO 0( "'4IM' 0 0 ~ .1 il ,~ lj '5 l u :J:" ~ 11 Q.OI ~i lIi~ Elb Qo~a: Sit :B 1\10 II ~.I ~~ ~$ IL <!:. eb CL~ Cf) !z-g~ <!-2 ::>CD ()= ()>~ 001 _c:~ Cf)"t:!;; I- .9:- ~ < .... I- ~ !~. z . WIO / I- ~ f II" ~ ,.~ t, ~ ~ 18 ! ~ lid i! 0000 6 ~ " Cf) .~ i I a ~----!T-- !-I ~ - M 'lil 8~ -fj- g ~ ~8.illl ~ ~~ 1 8o~!_ Cf)~)( ai oX oooO[ ~~s~ 1! 000 III o oua..u (' . ~ l- i w.... lJ) w.... o III:Q. i ~:$ ~~8~!~ ~~\I)~9~ ~9~:E::a8 ~O::l~:C; C) (/)t... Q. ~ I z i ,...: ! ! I I r- , ,--- -l I I ell ~ ! D: c: o .. c CD E i ~ r;- III > 'C 0.. ! '_. : ~;,.:r_~:~::;( . ~ ~ ; ~ ~ ~;;;J u ',' t~_~'~',,:: \,' :: I~ .-.: '....;.. I~ <:'l c: . 0.. C ;f i CD .. o I ~ W S ~ ~ !U -I I.. ...J.2~ SJ lXl C:. 10 ::>w . r-- '" 1i 0-_01 <0 c: ... ~ i~ ~ I f I:: :J l!? ;,::._____ _ _____.____ -- - - - - --- --.--- - 15-- ~ W WI ~ """ ~ ~~CDIO<( III ro~~a.. ~ ~~~N~ ~ ~of6S:J w:J=trl~ 0<( e (ij cj 'E :J CD . ltI a..m:I:o..:I: , I ., _~:~,:):> I !) I~ b~ ~'t 5'" zi 'a ~a: N- o N M ..,f lci <ri cO ~ G) Cl \'G e:, ~ ~O) I ~ .;1 ~ ~ ~ . i~:8 2; ;: '~i '~:E ~ '...fori];-:.. 1. ~ q: .... ~ ~ ::J vi fl .. UNITEDSTIJTES ... POST4L SERVICE.. Date Produced: 12/04/2006 GOLDBECK MCCAFFERTY & MCKEEVER The following is the delivery information for Certified item number 7111 4342363000033818. Our records indicate that this item was delivered on 11/24/2006 at 12:58 p.m. in MOUNT HOLLY SPRINGS, PA, 17065. The scanned image of the recipient information is provided below. Signature of Recipient: Delivery Sedon ~~ "':""'1' ~ r(\ *"'" ~ Address of Recipient: -\~~ "~\.<rN'7' 31Z- ?; A")t il4t. ? 7()1;5 Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representative. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 4340453 16625576 AMQ- /<1r6 GOLDBECK McCAFFERTY & McKEEVER BY: JosMhA. Goldbeck, Jr. Attorney'.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-825-6320 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN TIIE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE TONY A D. MORRIS Mortgagor(s) and Record Owner(s) Term No. 06-5449 205 W. Springville Road Boiling Springs, P A 17007 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 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: 205 W. Springville Road Boiling Springs, P A 17007 l.Name and address ofOwner(s) or Reputed Owner(s): TONY A D. MORRIS 312A Zion Road Mt. Holly Springs, P A 17065 2. Name and address ofDefendant(s) in the judgment: TONY A D. MORRIS 312A Zion Road Mt. Holly Springs, P A 17065 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 ... , . t P A 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 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. TENT ANTS/OCCUPANTS 205 W. Springville Road Boiling Springs, P A 17007 (attach separate sheet ifmore 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 r-~ c'::::r (':.:;J --' :J:' ~ I OJ -rj :J,<: (-:1 ~ .-, :L.-n rrl p" -0 Pj ,~, " :~i~ ~fl ~)r~ '-"-;yo ~ N r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which WM Specialty Mtg 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 8th day of No v, A.D., 2006, out ofthe Court of Common Pleas of said County as of Civil Term, 2006 Number 5449, at the suit ofWM Specialty Mtg LLC against Tonva D Morris is duly recorded in Deed Book No. 279, Page 1208. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ;<3 day of ~.L~ , A.D. ;:;Lo 07 ~(J. 4h ~ ) - Recorder of Deeds FIIcoIdIr 01 DeedI. Cumbe/IInd CoIIltr. CIIIsII. PA My ~ EJpm the FlnIt MolIdayol JIn. 2010 ') WM Specialty Mortgage LLC, without recourse VS Tonya D. Morris In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-5449 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on December 13,2006 at 1730 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Tonya D. Morris, by making known unto Richelle Shughart adult daughter of Tony D. Morris, at 312 Zion Road, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 19,2007 at 1035 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Tonya D. Morris located at 205 West Springville Road, Boiling Springs, 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 ofthe pendency ofthe action to the within named defendant, to wit: Tonya D. Morris, by regular mail to her last known address of 312A Zion Road, Mt. Holly Springs, P A 17065. This letter was mailed under the date of January 16,2007 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 Joseph Goldbeck, on behalf ofWM Specialty Mortgage LLC, Without Recourse. It being the highest bid and best price received for the same, WM Specialty Mortgage LLC, Without Recourse, of 505 City Parkway West, Suite 100, Orange, CA 92868, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $ 912.58 Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge $30.00 17.90 15.00 15.00 30.00 10.00 .50 1.00 9.68 2.10 15.00 20.00 .. Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 355.00 310.07 16,83 25.00 39.50 $ 912.58 ,/ 2/a-tJ67 ~ ~~~~ R. Thomas Kline, Sheriff 7 ~ ~v- !Jo .L~ ')'0 \ . Ck. j' 71L '( O~ /t({)to3 J f' . 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 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs, CIVIL ACTION - LA W TONY A D. MORRIS (Mortgagor(s) and Record Owner(s)) 205 W, Springville Road Boiling Springs, P A 17007 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 06-5449 AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 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: 205 W. Springville Road Boiling Springs, P A ] 7007 ] .Name and address of Owner(s) or Reputed Owner(s): TONY A D. MORRIS 3] 2A Zion Road Mt. Holly Springs, P A ] 7065 2. Name and address ofDefendant(s) in the judgment: TONY A D. MORRIS 312A Zion Road Mt. Holly Springs, P A 17065 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 170] 3 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA ]7]05-2675 4. Name and address of the last recorded holder of every mortgage of record: .1 # 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. TENT ANTS/OCCUP ANTS 205 W. SpringviIle Road Boiling Springs, P A 17007 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 3, 2006 06-5449 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange, CA 92868 Plaintiff . CIVIL ACTION - LAW vs. TONY A D. MORRIS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 205 W. Springville Road Boiling Springs, P A 17007 Term No. 06-5449 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: MORRIS, TONY AD. TONY A D. MORRIS 312A Zion Road Mt. Holly Springs, P A 17065 Your house at 205 W. Springville Road, Boiling Springs, P A 17007 is scheduled to be sold at Sheriff's Sale on Wednesday, March 07, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$153,443.45 obtained by WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE against you. . NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 06-5449 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price. was grossly inadequate compared to the value of your property. . 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff: you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the 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 A venue Carlisle, P A 17013 All that certain lot of ground situate in the South Middletown Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point on the south side of Spring-ville Road, T-537, at liJ).e ofland now o~ formerly of Raymond E. Diehl; thence by said Diehl land South 20 degrees 39 minutes East 150.73 feet to a point; thence by land of John P. McCoy et aI., South 75 degrees West 136.05 feet to a point; thence by Lot No. 5 of the hereinafter mentioned Subdivision Plan North 15 degrees West 150 feet to a point on the south side of said Road; thence by the south side of said Road North 75 degrees East 121.21 feet to a point, the place of beginning. Containing] 9,297 square feet, more or less. Subject, however, to a 15 foot drainage easement along the western side thereof as shown on said Subdivision Plan. . It being Lot No.6 of the Final Subdivision Plan for John P. McCoy, et al., as recorded in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 38, page 9. Parcel #40-28-2098-032 ADDRESS: 205 W. SPRINGYILLE ROAD, BOILING SPRINGS, PA 17007 . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5449 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff (s) From TONY A D. MORRIS (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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $153,443.45 1.1. $.50 Interest FROM 11/4/06 TO DATE OF SALE AT 7.8500% Atty's Comm % Atty Paid $120.56 Plaintiff Paid Date: NOVEMBER 8, 2006 Due Prothy $1.00 Other Costs (Seal) (lUh~ cur6s R. Long, Pr not By: 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 ~ Real Estate Sale # 45 On November 09,2006 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, P A Known and numbered as 205 West Springville Road, Boiling Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 09,2006 BYjt eLl ( .S~t~ Real Estate Sergeant S \ :b '\J b- hON qUOI i"~.l~_~;,~:~' 'ci ,\ :U\.:IJrc,) - ,- -' _.:, >."" , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever smce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #45 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: January 26, February 2 and February 9,2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 45 Writ No. 2006-5449 Civil WM Specialty Mortgage LLC without Recourse vs. Tonya D. Morris Atty.: Joseph Goldbeck All that certain lot of ground situ- ate in the South Middletown Town- ship, Cumberland County. Pennsyl- vania. bounded and described as follows: Beg1nn1ng at a point on the south side of Springville Road. T-537. at line of land now or formerly of Raymond E. Diehl; thence by said Diehl land South 20 degrees 39 minutes East 150.73 feet to a point; thence by land of John P. McCoy et al., South 75 degrees West 136.05 feet to a point; thence by Lot~CI-"-_5_ SWORN TO AND SUBSCRIBED before me this 9 day of February, 2007 NOT AR,AL SEAL lO!S E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 ~.JIIV",,\,___~'::~.-aNI