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Home My WebLink About06-6014GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 825-6318 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Mortgagors and Real Owners 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendants Ct ; o L` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. x. i V L ACTION: MORTGAGE ?0'1RFCL08UfRF 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 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 AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 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.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 our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a 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-1326. 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 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. The names and addresses of the Defendants are STEPHANIE J. LEBO-TOPPER, 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065 and CHARLES A. TOPPER, 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On April 07, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1904, Page 2526. 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 June 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 ....................................................................................$99,472.34 Interest from 05/01/2006 through 10/31/2006 at 10.2500% .....................$5,210.88 Per Diem interest rate at $28.32 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,973.62 Late Charges from 06/01/2006 to 10/31/2006 .............................................$456.16 Monthly late charge amount at $53.77 Costs of suit and Title Search ......................................................................$900.00 Escrow Advance ..........................................................................................$183.58 Fees ..............................................................................................................$106.00 NSF Charges ..................................................................................................$20.00 Recoverable Balance ......................................................................................$15.00 Monthly Escrow amount $58.77 $111,337.58 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff 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 Sheriffs 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 personam" 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 $111,337.58, together with interest at the rate of $28.32, 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:L- '?:ZUIBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Nancy 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 unswom falsification to authorities. Date: ( 0 / I % Nancy Jimen /reAGE osure Supervisor AMERIQUES O CORPORA N ?xhi6it .f? Cotie-toga Title Insurance Company Commitment Number: 20050 A03;T- SCHEDULE C rROFERTY DESCRIPTION The land referred to in this Connnily enl is rfPscribed as follows: ALL that certain tract of land torrpttler silitate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and desgtl-d as foilows: BEGINNING at a point on the cuiJi 4ttte'df Ike eastern side of Baltimore Avenue in line of land now or formerly of the Methodist Episcopal Church; Ilwiice East along said Church land, 147.00 feet to a point; thence North on a tine parallel to the curb line of the psstp-M %ift of Baltimore Avenue, 44.00 feet, more or less, to a point on line of land now or formerly of Grace R: Slayer; thence West along line of land now or formerly of Grace S. Stayer, 147.00 feet to a point on the nui.l, Jine 'of.lhe eastern side of Baltimore Avenue; thence South along said curb line, 42.4 feet to a point, the placp fir BEGINNING. Parcel 023-32-2336-135A ALTA Commitment Schedule C (2005030343.PFD/2005030343119) i EXhibt ? .oBOX .._ 11111111?9?1?1991III811R Santa Ana, CA 92711-1000 7182 6389 3060 0867 1562 STEPHANIE 7 LEBO-TOPPER ,. ) „m CHARLES A TOPPER SR 206 N BALTIMORE AVE MOUNT HOLLY SPRINGS, PA 17065 "MORTGAGE SERVICES August 07, 2006 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS OF POLICY Loan Number: 0114349368 Properly Address: 206 N BALTIMORE AVE, MOUNT HOLLY SPRINGS PA, 17065 Original Lender: AMC Mortgage Services, Inc. Current LenderlServicer: 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 mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save Your home. This Notice explains how the program works. To see if HEMAP can help you mast MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and above number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397.(Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENYDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO [roswvlwaln-as Also doing business as Delaware AMC Mortgage Services, Inc-, in the states of Texas, Rhode Island, and New Hampshire ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SII CASA DE LA PERDIDA DEL DERECHO A REDIMIR SII 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 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 MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED 'HOW TO CURE YOUR MORTGAGE DEFAULT' EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this noti ce. 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 theprot cM is located are set forth at the and 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 a 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. -.X.11- August 07, 2006 Loan Number: 0 1 143 493 68 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 Bring it so to date). NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property located at: 206 N BALTIMORE AVE, MOUNT HOLLY SPRINGS, PA 17065 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 06/01/06 thru 08/01/06 at $954.89 per month Monthly payments plus late charge or other fees: $3242.29 Total Amount to Care Default: 53242.29 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): NIA HOW TO CURE THE DEFAULT --Yon 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 $3242.29 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, certified check or money order madepayable and sent to: 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 if not applicable.) N/A 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 roe 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 care the default within the THIRTY (30) DAY period, you will not be required to pay attorney's foes 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 cared the default within the THIRTY (30) DAY period and foreclosure proceedings have began, you still have the right to cure the defanli and prevent the sale at any time up to one hoar before the Sheriffs Sale. You may do so by paying the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by rraoKlwcrlx-oa performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARNEST 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 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: AMC Mortgage Services PO Box 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 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 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 -- You _ may or X 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 attorney's fees and costs are paid prior to or at die sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: z 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. z TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. s 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) s TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, z 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 ARE ATTACHED Very Truly Yours, AMC Mortgage Services Cc: AMC Mortgage Services Attn: Collections Department Loan Number: 0114349368 Mailed by lit Class Mail and by Certified Mail EFOiO0.1)-. 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, PA 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, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1-800-342-2397 AD ol d ? J 1 Tl _ In the Court of Common Pleas of Cumberland County WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER (Mortgagor(s) and Record Owner(s)) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 No. 06-6014 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 STEPHANIE J. LEBO-TOPPER and CHARLES A. TOPPER by default for want of an Answer. Assess damages as follows: $112,638.82 Debt Interest from 12/09/06 to Date of Sale Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIE OUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FR M ?HE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered t the arty against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least a days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. Gi Attorney for I.D. #16132 AND NOW , Q0,0 , Judgment is entered in favor of WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE and against STEPHANIE J. LEBO-TOPPER and CHARLES A. TOPPER by default for want of an Answer and damages assessed in the sum of $I ,638.82 as per th bove certification. Prothon 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. 06-6014 VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER (Mortgagors and Record Owner(s)) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: \ If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 AMQ-1326 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: November 27, 2006 TO: CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER (Mortgagor(s) and Record Owner(s)) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 TO: CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 06-6014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ?a=fi .Ga?rff?eck 2r GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 AMQ-1326 10 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. TO: STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER (Mortgagor(s) and Record Owner(s)) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s) TO: STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 DATE OF THIS NOTICE: November 27, 2006 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 06-6014 IMPORTANT NOTIC'F YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC S Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 os°l1sal?ff?ec-r GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, STEPHANIE J. LEBO- TOPPER, is about unknown years of age, that Defendant's last known residence is 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or o erwise within the provisions of the Soldiers' and Sailors' iv'1 Relief Action of Congress of 1940 and its Amendments. Date: I VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CHARLES A. TOPPER, is about unknown years of age, that Defendant's last known residence is 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or o wise within the provisions of the Soldiers' and Sailors' ivil Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER (Mortgagor(s) and Record owner(s)) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6014 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of WM SPECIALTY MORTGAGE against STEPHANIE J. LEBO-TOPPER and CHARLES A. TOPPER for f action within (20) days (or sixty (60) days if defendant is the United States of the Complaint, in the sum of $112,638.82. Joseph A. Gi Attorney for I hereby certify that the above names are correct and that the precise creditor is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE Orange, CA 92868 and that the name(s) and last known address(es) of the D, LEBO-TOPPER, 206 N. Baltimore Avenue Mount Holly Springs, PA 1706' Baltimore Avenue Mount Holly Springs, PA 17065; GOLDBECK] BY: Joseph A. Attorney for P MHOUT RECOURSE, and file an Answer in the above ca) from the date of service address of the judgment Parkway West Suite 100 s) is/are STEPHANIE J. kRLES A. TOPPER, 206 N. & McKEEVER ON) if PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Mortgagor(s) and Record Owner(s) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 06-6014 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $112,638.82 Interest from 12/09/06 to Date of Sale at 10.2500% (Costs to be added) GOLDBECK MCCAFF TY & BY: Joseph A. Goldbec Jr. / Attorney for Plaintiff z ? x b ? H w HO-0Qa" oa CO' 0.9 .. v, 10" .4 R v HNC oo aW m", ag o?N z r? ?' W r'L?i b°0 ?° x W O Q O L1r O F ? V ?e o? W b ?.•, x oa cv a ? W ? W o ? U x W ? ? 03 i 10 r19 (Z- G a y C*I ,oa xi C? ? The land referred to in this Commitment is described as follows: All that certain tract of land together situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point on the curb line of the eastern side of Baltimore Avenue in line of land now or formerly of the Methodist Episcopal Church; thence east along said Church land, 147.00 feet to a point; thence north on a line parallel to the curb line of the eastern side of Baltimore Avenue, 44.00 feet, more or less, to a point on the line of land now or formerly of Grace S. Stayer; thence west along line of land now or formerly of Grace S. Stayer, 147.00 feet to a point on the curb line of the eastern side of Baltimore Avenue; thence south along said curb line, 42.4 feet to a point, the place of beginning. Parcel #23-32-2336-135A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6014 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 STEPHANIE J. LEBO-TOPPER AND CHARLES A. TOPPER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $112,638.82 L.L. $.50 Interest FROM 12/9/06 TO DATE OF SALE AT 10.2500% Atty's Comm % Due Prothy $1.00 Atty Paid $131.28 Other Costs Plaintiff Paid Date: DECEMBER 12, 2006 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 1 C As R. L r onota By: Deputy Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 w Goidbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER (Mortgagor(s) and Record Owner(s)) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 06-6014 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: 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE BOROUGH OF MOUNT HOLLY SPRINGS 200 Harman Street Mt. Holly Springs, Pa 17065 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the be of my rsonal knowledge or information and belief. I understand that false statements herein are made subject to th penalti s of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: December 8, 2006 GOLDBECK McCAI BY: Joseph A. Goldb Attorney for Plaintiff -4t '" rj S j ' r 7 1 r? L-= 4. MS r - 3f? 06-6014 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Mortgagor(s) and Record Owner(s) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s Term No. 06-6014 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: LEBO-TOPPER, STEPHANIE J. STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Your house at 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courtjudgment of $112,638.82 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: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to 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 our office at 215-825-6329 or 1-866413-2311 and 06-6014 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 06-6014 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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 our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a 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-1326. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. -TI C--) Fill 06-6014 GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Mortgagor(s) and Record Owner(s) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s Term No. 06-6014 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: TOPPER, SR., CHARLES A. CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Your house at 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $112,638.82 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: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to 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 our office at 215-825-6329 or 1-866-413-2311 and 06-6014 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 06-6014 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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 our toll free number at 1-866-413-2311 or via email at homeretention(&Poldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1326. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ? r? ? =- ? Ca"? ? :? -s-? T ? ? ` ?` ' ? rti? fi` ` `? _ ?? ' c:°? '? ? --{ CASE NO: 2006-06014 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS TOPPER STEPHANIE J LEBO ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE TOPPER STEPHANIE J LEBO DEFENDANT the at 1305:00 HOURS, on the 6th day of November , 2006 at 206 N BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 CHARLES A TOPPER by handing to ADULT IN CHARGE 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 5.28 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 33.2811/07/2006 ?r?17 /off /? GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: ? - 7 before me this day Deputy Sheriff was served upon of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-06014 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS TOPPER STEPHANIE J LEBO ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TOPPER CHARLES A the DEFENDANT , at 1305:00 HOURS, on the 6th day of November-, 2006 at 206 N BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 CHARLES A TOPPER 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline 16.00t/ 11/07/2006 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: before me this day Deputy Sheriff of A. D. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 AMQ-1326 CF: 10/16/2006 SD: 06/13/2007 $112,638.82 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Mortgagor(s) and Record Owner(s) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Plaintiff Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 06-60 Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that s Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/c (copy of return at ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return rec ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defend (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of 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 ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attache( ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receil Mail attached). ;e on the ed). attached). s) of record iowledgment s) for Certified Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties prodded by 18 P.S. Section 4904. IN THE COURT OF COMMON PLEAS of Cumberland CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Ali A. Goldb ck, Jr. for Plaintiff WM Specialty Mortgage, LLC without In the Court of Common Pleas of recourse Cumberland County, Penn ylvania VS Writ No. 2006-6014 ?(o Stephanie J. Lebo-Topper and Charles A. Topper Vc- I Kenneth Gossert, who being duly sworn according to law, states that on March 15, 2007 at 1739 hours, he served a true copy of the within Real Estate rit, Notice and Description, in the above entitled action, upon the within named defendants to it: Stephanie J. Lebo-Topper and Charles A. Topper, by making known unto Stephanie Lebo-T pper personally and as wife of Charles A. Topper, at 206 North Baltimore Avenue, Mt. Holly S rings, Cumberland County, Pennsylvania its contents and at the same time handing to her personal y the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1435 hours, he posted a true copy of the within Real Estate Writ, No tice, Poster and Description, in the above entitled action, upon the property of Stephanie J. Lebo -Topper and Charles A. Topper, at 206 North Baltimore Ave, Mt. Holly Springs, Cumberlan County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, sta above Real Estate Writ, Notice, Poster and Description in the following mane mailed a notice of the pendency of the action to the within named defendants, Lebo-Topper and Charles A. Topper, by regular mail to their last known adds Baltimore Avenue, Mt. Holly Springs, PA 17065. These letters were mailed 1 3, 2007 and never returned to the Sheriffs Office. rs: R. Thomas Kline, Sheriff he served the The Sheriff wit: Stephanie J. s of 206 North ier the date of April BY Re4Esta4teputy8kill D IM 0 W ? ' m L - r m CID r0 ?d y W ao m _ 0 0 ?o O N . rn n3 M Rtg X v- 90 v z ;7 m fn w 3 D O T m C7 r 5. A m Q 3 g F 0 w m O 0 co, VI ?I y m D N 3 ._? j A a " UNITFO C) r J 1 0 q 9k v AD T O O cn K W N i ?M? o oo m N ...i N¦.` Q tD N N O ID O 0 WI. c?cl..co or -ar3 &0DCAco0) cnrn?omn Nr rnO0 a n co N y DSTT D ' ? N O M D Z m 3 1 R . 0cD pka w00 o 5m m m y o 0 =o ????? x = °,D -0 w N `? G7 N °og Cl. tu ? w 2 =h R I i $ ?? y Z C, fl/ ? O 3 cn0 co 1 to ?D 00 0 O O c y ( ? M c 0 0 O c°'n O r- ???? CD M -0 X A CD M CA) 0 r- -0 3 8: ;D D Z ° m cn 3 C16_ 0 0 p M 0 m ZZ ccn v v st Q > & c 0 off p @ w m C -10 g Ef 3 $ ?Z c? m2 " 44 a FrTr?.?i__. GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT IN THE COURT OF CC RECOURSE 505 City Parkway West of Cumberland Suite 100 Orange, CA 92868 Plaintiff CIVIL ACTIONN vs. ACTION OF MORTGAGI STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Term Mortgagor(s) and Record Owner(s) No. 06-6( 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff in the above ac Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was information concerning the real property located at: 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 PLEAS - LAW FORECLOSURE 14 by its attorney, the following CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the pr perty to be sold: BOROUGH OF MOUNT HOLLY SPRINGS 200 Harman Street Mt. Holly Springs, Pa 17065 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support nforcement 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 prope 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 terest 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 may be affected by the sale. TENANTS/OCCUPANTS 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 (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 persc information and belief. I understand that false statements herein are made subject to the penalties of relating to unsworn falsification to authorities. DATED: May 16, 2007 in the property which nal knowledge or 8 Pa. C.S. Section 4904 UCLDJECK McCAFFERTY & r BY. eph A. Goldbeck, Jr., Esq. Attorney for Plaintiff co _„'j Ul : / COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which WM Specialty Mtg LLC is the grantee the same having been sold to said grantee on the 13th day of June A.D., 2007, under and by virtue of a writ Execution issued on the 12th day of Dec, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 6014, at the suit of WM Specialty Mtg LLC against Stephanie J Lebo-Topper & Charles A is duly recorded in Deed Book No. 281, Page 494. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 1? ?- day of A.D. ,-o o -? (3. M?-c;L Recorder of Deeds %WRW of Duda, CwbwW CN*. CHIN, PA My Comfifea w E)Ome to RM Monday of Jan. 2MO WM Specialty Mortgage, LLC without In the Court of Common Pleas of recourse Cumberland County, Pennsylvania VS Writ No. 2006-6014 Stephanie J. Lebo-Topper and Charles A. Topper Kenneth Gossert, who being duly sworn according to law, states that on March 15, 2007 at 1739 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: Stephanie J. Lebo-Topper and Charles A. Topper, by making known unto Stephanie Lebo-Topper personally and as wife of Charles A. Topper, at 206 North Baltimore Avenue, 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. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1435 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Stephanie J. Lebo-Topper and Charles A. Topper, at 206 North Baltimore Ave, Mt. Holly 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 of the pendency of the action to the within named defendants, to wit: Stephanie J. Lebo-Topper and Charles A. Topper, by regular mail to their last known address of 206 North Baltimore Avenue, Mt. Holly Springs, PA 17065. These letters were mailed under the date of April 3, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 13, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $35,000.00 to Attorney Joseph Goldbeck on behalf of WM Specialty Mortgage LLC, without recourse. It being the highest bid and best price received for the same, WM Specialty Mortgage LLC of 505 City Parkway West, Suite 100, Orange, CA 92868, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $9,930.37. Sheriff s Costs: Docketing $30.00 Poundage 700.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 11.52 Levy 15.00 Surcharge 30.00 Law Journal 355.00 Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed 255.86 16.17 25.00 39.50 $1,567.55 f _ ? lam' U? ?g s-- 9 So Answers: R. Thomas Kline, Sheriff BY I Real Estate ergeant Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER (Mortgagor(s) and Record Owner(s)) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 06-6014 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: 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE BOROUGH OF MOUNT HOLLY SPRINGS 200 Harman Street !1 Mt. Holly Springs, Pa 17065 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the be of my ersonal knowledge or information and belief. I understand that false statements herein are made subject to th penalti s of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 8, 2006 GOLDBECK MCCAI BY: Joseph A. Goldb Attorney for Plaintiff 06-6014 GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Mortgagor(s) and Record Owner(s) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 06-6014 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: LEBO-TOPPER, STEPHANIE J. STEPHANIE J. LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Your house at 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $112,638.82 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: IN THE COURT OF COMMON PLEAS 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 our office at 215-825-6329 or 1-866-413-2311 and 06-6.014 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 06-6014 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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 our toll free number at 1-866-413-2311 or via email at homeretention(d?goldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1326. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 06-6014 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. STEPHANIE J. LEBO-TOPPER CHARLES A. TOPPER Mortgagor(s) and Record Owner(s) 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Defendant(s) Term No. 06-6014 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: TOPPER, SR., CHARLES A. CHARLES A. TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 Your house at 206 N. Baltimore Avenue, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $112,638.82 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: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to 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 our office at 215-825-6329 or 1-866-413-2311 and 06-6014 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 06-6014 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.hudgov 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 our toll free number at 1-866-413-2311 or via email at homeretentiongyoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1326. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. The land referred to in this Commitment is described as follows: All that certain tract of land together situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point on the curb line of the eastern side of Baltimore Avenue in line of land now or formerly of the Methodist Episcopal Church; thence east along said Church land, 147.00 feet to a point; thence north on a line parallel to the curb line of the eastern side of Baltimore Avenue, 44.00 feet, more or less, to a point on the line of land now or formerly of Grace S. Stayer; thence west along line of land now or formerly of Grace S. Stayer, 147.00 feet to a point on the curb line of the eastern side of Baltimore Avenue; thence south along said curb line, 42.4 feet to a point, the place of beginning. Parcel #23-32-2336-135A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-6014 Civil COUNTY OF CUMBERLAND) 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 STEPHANIE J. LEBO-TOPPER AND CHARLES A. TOPPER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $112,638.82 L.L. $.50 Interest FROM 12/9/06 TO DATE OF SALE AT 10.2500% Atty's Comm % Due Prothy $1.00 Atty Paid $131.28 Other Costs Plaintiff Paid Date: DECEMBER 12, 2006 Cu 's R. L ? onot (Seal) 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 # 32 On February 15, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Mt. Holly Springs Borough, Cumberland County, PA Known and numbered as 206 North Baltimore Ave., Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 15, 2007 By: Real Estat Sergeant 8 Z _8 d S 1 1130 9G0l ova SCHEDULE OF DISTRIBUTION SALE NO. 32 Date Filed: July 13, 2007 Writ No. 2006-6014 Civil Term WM Specialty Mortgage LLC without recourse VS Stephanie J. Lebo-Topper and Charles A. Topper 206 N. Baltimore Ave. Mt. Holly Springs, PA 17065 Sale Date: June 13, 2007 Buyer: WM Specialty Mortgage, LLC without recourse Bid Price: $35,000.00 Real Debt: $112,638.82 Interest: 5,883.18 Attorney Writ Costs: 131.28 Total: DISTRIBUTION: $118,653.28 Receipts: Cash on account (02/13/2007): $ 1,500.00 Cash on account (06/13/2007): 3,500.00 Cash on account (06/28/2007): 6,430.37 Total Receipts: $11,430.37 Disbursements: Sheriffs Costs Legal Search Cumberland County Tax Claim Bureau Mabel Satteson, Tax Collector Mt. Holly Springs Borough Total Disbursements: Balance for distribution: So Answers: R. Thomas Kline Sheriff $1,567.55 200.00 3,212.98 1,636.84 4,813.00 ($11,430.37) 0.00 SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale No. 32, held June 13, 2007 EFFECTIVE DATE: June 18, 2007 PREMISES: 206 North Baltimore Avenue, Mount Holly Springs, Pennsylvania (the "Premises"), tax parcel No. 23-32-2336-135A RECITAL: Being the same premises which Ross S. Richwine, Jr. and Terry L. Richwine, husband and wife, by their Deed dated May 30, 2003 and recorded June 4, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 257, Page 1977, granted and conveyed unto Charles A. Topper, Sr. and Stephanie J. Lebo-Topper, husband and wife.. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All real Estate taxes on the Premises assessed but not billed, including, but not limited to, those Real Estate taxes accruing on and after July 1, 2007. 20. Mortgage in the amount of $100,000.00 from Charles A. Topper and Stephanie J. Lebo- Topper to Ameriquest Mortgage Company dated April 7, 2005 and recorded April 22, 2005 in Mortgage Book 1904, Page 2526, assigned January 11, 2007 in Misc. Book 733, Page 2180 to W. M. Specialty Mortgage, LLC. -2- 21. Judgment against Stephanie J. Lebo-Topper and Charles A. Topper in favor of W. M. Specialty Mortgage, LLC in the amount of $112,638.82 entered December 12, 2006 to No. 2006-6014. 22. Judgment against Charles A. Topper, Sr. and Stephanie J. Lebo-Topper in favor of Borough of Mount Holly Springs in the amount of $2,914.31 entered November 30, 2005 to No. 2005-6146. 23. Judgment against Charles A. Topper, Sr. and Stephanie J. Lebo-Topper in favor of Borough of Mount Holly Springs in the amount of $3,878.10 entered December 27, 2006 to No. 2006-7288. 24. Taxes due to the Tax Claim Bureau in the amount of $3,192.85. 25. Rights granted MetEd in Misc. Book 344, Page 553 and in Misc. Book 88, Page 545. 26. Subject to the rights of others in and to the portion of the Premises adjoining or within Baltimore Avenue, also known as Baltimore Street. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -3- REAL ESTATE SALE NO. 32 Writ No. 2006-6014 Civil WM Specialty Mortgage LLC without recourse vs. Stephanie J. Lebo-Topper and Charles A. Topper Atty.: Joseph Goldbeck The land referred to in this Com- mitment is described as follows: All that certain tract of land to- gether situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point on the curb line of the eastern side of Baltimore Avenue in line of land now or for- merly of the Methodist Episcopal Church; thence east along said Church land, 147.00 feet to a point; thence north on a line parallel to the curb line of the eastern side of Baltimore Avenue, 44.00 feet, more or less, to a point on the line of land now or formerly of Grace S. Stayer: thence west along line of land now or formerly of Grace S. Stayer, 147.00 feet to a point on the curb line of the eastern side of Baltimore Avenue: thence south along said curb line, 42.4 feet to a point, the place of beginning. Parcel #23-32-2336-135A. EXHIBIT A Assignment of Bid NO. 06-6014 - LEBO-TOPPER 206 N. Baltimore Avenue Mount Holly Springs, PA 17065 I, Joseph A. Goldbeck, Jr., Esquire, as attorney for the successful bidder, hereby assign my bid at the Sheriff Sale dated June 13, 2007 to: WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 GOLDBECK MCCAFFERTY & MCKEEVER Date: June 14, 2007 JOSEPH A. GOLDBECK, JR. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pemisylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of g,-neral circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that Tie Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#32 Sworn to and subscribed before me this 18th day of Mav 2007 A.D. Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County MY mission Expires June E, 2010 Memb ennsvivania Association of Notaries r N ARY PUBLIC ` CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 20, 27 & May 4, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and charac -?r of publication are true. Coyne, r SWORN TO AND SUBSCRIBED before me this __A __day of May, 2007 SEAL Lnlc E. CYDER, Notary Public C % Gu Oberland CouWy :v Y , ... -:es March J REAL EilTATE *ALE NO. 32 Writ No. 2006-6014 Civil VIM Specialty Mortgage LLC without recourse vs. Stephanie J. Lebo-Topper and Charles A. Topper Atty.: Joseph Goldbeck The land referred to in this Com- mitment is described as follows: All that certain tract of land to- gether situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point on the curb line of the eastern side of Baltimore Avenue in line of land now or for- merly of the Methodist Episcopal Church; thence east along said Church land, 147.00 feet to a point; thence north on a line parallel to the curb line of the eastern side of Baltimore Avenue, 44.00 feet, more or less, to a point on the line of land now or formerly of Grace S. Stayer; thence west along line of land now or formerly of Grace S. Stayer, 147.00 feet to a point on the curb line of the eastern side of Baltimore Avenue; thence south along said curb line, 42.4 feet to a point, the place of beginning. Parcel #23-32-2336-135A.