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Home My WebLink About06-6367GOLDBECK 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 ntw -- 1-.3o 0'.?L'rq WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 VS. LORETTA SYKES-LACEY Mortgagor and Real Owner 810 Kent Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant Term CIVIL ACTION. MWGAGE J:0'AVCLo8urF 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-1387. 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 Defendant is LORETTA SYKES-LACEY, 810 Kent Drive, Mechanicsburg, PA 17055, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On December 18, 2003 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 1849, Page 4065. 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 July 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 ..................................................................................$182,378.08 Interest from 06/01/2006 through 10/31/2006 at 9.2500% .......................$7,169.57 Per Diem interest rate at $46.86 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$9,118.90 Late Charges from 07/01/2006 to 10/31/2006 .............................................$366.24 Monthly late charge amount at $91.56 Costs of suit and Title Search ...................................................................... $900.00 Escrow ....................................................................................................... $5,884.74 Fees ..............................................................................................................$106.00 Corporate Advance ......................................................................................$851.54 $206,775.07 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 is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention 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 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 Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $206,775.07, together with interest at the rate of $46.86, 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:_ V)k V?l A - Q:?? &AX6B-]6CK-W1cCAFFERTY & 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 unworn falsification to authorities. Date: jn,?? ' No -a ancy Jimen oosure Supervisor (TGGAG-F l AMERIQUES C ORPO N E.x.hibitA Date: 12/19/03 Order Number: 000017521 Re: Loretta Sykes-Lacey EXHIBIT 'A' Tkm: 12:13:09 PM 610 KENT DRIVE MECHANICSBUR3, PA 17055 CUMBERLAN) County ALL THAT CERTAINtract or parcel of ground situate in Hampden Wnship, Cumberland County, Pennsylvania, more particully bounded and described as follows, to wit; BEGINNING ata point on the eastern right-f>-way line of Kent Drive at the dividing line between Dz Nos. 62 and 63 of the hereinafter mentioned plan of lode; thence along said dividing line North 69 degrees 11 minutes 20 seconds East 120 feet to apoint; thence along line of Lot No. 62 South 20 defies 48 minlites 40 seconds East 015 feet to line of Lot No.61; thence along the same South 69 degrees 11 minutes 20 secods West 120 feet to the eastern r*-of-way line of Kent Drivel thencealong the same North 20 degrees 48 minutes 40 seconds West 105 feet to ]de of Lot No. 63, the Place of BEGINNING. BEING all of Lot No, 8 no the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at P1m Book 33, Page 10, Cumberland County Record;. Page: 6 of 6 Order Nurrtrx 000017521 RKI849PG408I Ey,hibit (B 1 11 1 AMCP.O. Box 11000 MORTGAGE SERVICES Santa Ana, CA 92711-1000 September 05, 2006 #BWNKZZS LORETTA SYKES- LACEY M I NMI 810 KENT DRIVE MECHANICSBURG, PA 17050-2222 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS OF POLICY Loan Number: 0064609506 Property Address: 810 KENT DRIVE, MECHANICSBURG PA, 17055 Original Lender: AMC Mortgage Services, Inc. Current Lender/Servicer: 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 defaalt, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached hazes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To we if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. N you have any euestions. 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. H you have any questions, representatives at the Consamer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney is your area. The local bar association may be able to help you fad a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA I PORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO 01050A)Ncrfs, 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 SU CASA DE LA PERDIDA DEL DERECHO A REDE IIR 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: Z 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 s 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 mating 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 1N0 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 notice, the lender may NOT take action agaiiust you for tITM+y (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the Dourly in which the property is looted are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in 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 farads 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 you 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 you application. September 05, 2006 Loan Number: 0064609506 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 Mortgap Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it no to date) NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property located at: 810 KENT DRIVE, MECHANICSBURG, PA 17055 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: 07/01/06 thru 09/01/06 at $1525.99 per month Monthly Payments plus late charge or other fees: $5248.51 Total Amount to Caro Default: 55243.51 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): NIA HOW TO CURE THE DEFAULT -You may core the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5248.51 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 made payable and sent to: AMC Mortgage Services 505 City Parkway West, Suite 4100 Orange, CA 92868 You can care 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 CUBE THE DEFAULT--If you do not can 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 morttaied pnwty 17 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 care 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 fees. OTHER LENDER REMEDIES - The lender may also sae 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, yon still hm the right to cure th defauh and prevent the sale at any time up to one hoar before the Sheriffs Sale You may do so by paving 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 ano other costs connected with the Sheriff s Sale as specified in writing by the lender and by EFMOKINC,MO, performing any other requirements under the mortgage. Curiag your default in the manner set forth is 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 Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to care 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 a 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 the 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) z 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 Z 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: 0064609506 Mailed by 1st Class Mail and by Certified Mail 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 i? r- :I -Ti \ 4;T` LL 7k -Lei - Aw) 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. LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT No. 06-6367 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 LORETTA SYKES-LACEY by default for want of an Answer. Assess damages as follows: Debt Interest from 12/19/2006 to Date of Sale Total (Assessment of Damages attached) $209,207.47 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and 7 least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 n A / )ldbeck, Jr. Plaintiff AND NOW I)Ec_ /Q jeo(o '-- , Judgment is entered in favor of WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE and against LORETTA SYKES-LACEY by default for want of an Answer and damages assessed in the sum of $209,207.47 as per the above certifi tion. 'I ? Prothonotary __ --/ . 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 vs. No. 06-6367 LORETTA SYKES-LACEY (Mortgagors and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothono By: / 6, J 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-1387 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: December 6, 2006 TO: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 TO: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 06-6367 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 _xv O??f&eck Vr 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, LORETTA SYKES-LACEY, is about unknown years of age, that Defendant's last known residence is 810 Kent Drive, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 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. LORETTA SYKES-LACEY (Mortgagor(s) and Record owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6367 ORDER FOR JUDGMENT Please enter Judgment in favor of WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, and against LORETTA SYKES-LACEY for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $209,207.47. 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 address(es) of the Defendant(s) is/are LORETTA SYKES-LACEY, 810 Kent Drive Mechanicsburg, PA 17055; McCAFFERTY & McKEEVER . Goldbeck, Jr. Plaintiff ASSESSMENT OF DAMAGES i ' TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $182,378.08 Interest from 06/01/2006 through $9,418.85 12/18/2006 Attorney's Fee at 5.0000% of principal $9,118.90 balance Late Charges $549.36 Costs of Suit and Title Search $900.00 Escrow $5,884.74 FEES $106.00 CORPORATE ADVANCE $851.54 $209,207.47 Goldbeck, Jr. Plaintiff & McKEEVER AND NOW, this / 94k-day of ?F-C • , 2006 damages are assessed as above. Pro rothy ? 't, 3 ?. g 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. LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6367 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 12/19/2006 to Date of Sale at 9.2500% (Costs to be added) $209,207.47 ?D CK MCCAFFERTY & McKEEVER Jos . Goldbeck, Jr. ornev r Plaintiff v .r d a> dU v V ?, 7ys ,? y p., 1•1 W ?3 o W y r? oo• v, x C.) U Q ?? w v ,? N Vj N r. •p N W on W ?,' d ?o a ?... C7 Us ? p4 ? d rp w o f-' O c v ai a+ °? 0 0 p U?} d 00 4t o L7 o ? '?, 04 ? o? ? W a r--Zt w T f/1 All that certain tract or parcel of ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, PA 17055 SOLD as the property of LORETTA SYKES-LACEY TAX PARCEL #10-17-1037-062 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6367 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 LORETTA SYKES-LACEY (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 $209,207.47 L.L. $.50 Interest FROM 12/19/06 TO DATE OF SDALE AT 9.2500% Atty's Comm % Atty Paid $122.32 Plaintiff Paid Due Prothy $1.00 Other Costs Date: DECEMBER 19, 2006 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE C s R. Long onotary By: Deputy 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 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. LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 06-6367 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: 810 Kent Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 810 Kent Drive Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: December 18, 2006 GO>IIbB cCAFFERTY & McKEEVER BY: os A,/Goldbeck, Jr., Esq. CJ 4 co .0. 06-6367 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. LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Term No. 06-6367 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: SYKES-LACEY, LORMA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Your house at 810 Kent Drive, Mechanicsburg, PA 17055 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 $209,207.47 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 06-6367 -- 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 06-6367 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.gqv 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 homeretentionagoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of AMQ-1387. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. r-- _ Y? -t? of 03 SHERIFF'S RETURN - REGULAR CASE NO: 2006-06367 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS SYKES-LACEY LORETTA JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE SYKES-LACEY LORETTA DEFENDANT the , at 1637:00 HOURS, on the 15th day of November , 2006 at 810 KENT DRIVE MECHANICSBURG, PA 17055 by handing to MARCELLIOUS HILL HUSBAND 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: Docketing Service Affidavit Surcharge So Answers: 18.00 12.32 osL .00 10.00 R. Thomas Kline 40.32, 00/00/0000 Sworn and Subscibed to By: before me this day of A. D. puts Sheriff was served upon 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-1387 CF: 10/31/2006 SD: 06/13/2007 $209,207.47 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Plaintiff Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 06-6367 Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/cmnpeten4-a"t (copy of return attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE !Mwmok? B . osep A. Goldbeck, Jr. A ey for Plaintiff WM Specialty Mortgage, LLC Without Recourse In the Court of Common Pleas of VS Cumberland County, Pennsylvania Loretta Sykes-Lacey Writ No. 2006-6367 Civil Term Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, states that on March 20, 2007 at 1913 hours, she 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: Loretta Sykes-Lacey, by making known unto Loretta Sykes-Lacey personally, at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2007 at 1253 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 Loretta Sykes-Lacey, located at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Loretta Sykes-Lacey, by regular mail to her last known address of 810 Kent Drive, Mechanicsburg, PA 17050. This letter was mailed under the date of April 3, 2007 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff B YOL?&rgeant Real Estate s 6 ? d ? ? Z 4 ?? ?{ ? j C coo a ape ' V o$ ? ri a o U u. m c? ti N co Sul a $ N z Coc o O Z km m m?nQ ? c oQ ? N ,c o G is U ?,y a. M oa v?? o OHO W`w DppD o? 06 v ?. m U ? r m N u o }? Q ??aW JM v?lf OC w mca Q?to .: ch Q.' co m m a 0 c E v N Q A d 1`- 5? o- a c 0 a m 0 c r p M m E 0 v I 'S a o? r? N O a 0 N ro u e^- ? M N T Z ? O os- d wl- t+7 a 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 RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 vs. LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 Term No. 06-6367 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: 810 Kent Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement . Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 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 810 Kent Drive Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: May 15, 2007 9V)(d)WdkU G DB CK cCAFFERTY & McKEEVER BY. o ph A. Goldbeck, Jr., Esq. Attorney for Plaintiff ir? r--? CV5 Wit::.: WM Specialty Mortgage, LLC Without Recourse In the Court of Common Pleas of VS Cumberland County, Pennsylvania Loretta Sykes-Lacey Writ No. 2006-6367 Civil Term Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, states that on March 20, 2007 at 1913 hours, she 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: Loretta Sykes-Lacey, by making known unto Loretta Sykes-Lacey personally, at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2007 at 1253 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 Loretta Sykes-Lacey, located at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Loretta Sykes-Lacey, by regular mail to her last known address of 810 Kent Drive, Mechanicsburg, PA 17050. This letter was mailed under the date of April 3, 2007 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Goldbeck. Sheriffs Costs: Docketing 30.00 Poundage 15.64 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 26.88 Levy 15.00 Surcharge 20.00 Law Journal 355.00 Patriot News 287.39 Share of Bills 16.17 $797.58 ? f/b7107 So Answers: _ ?0001a?? .t44? R. Thomas Kline, Sheriff BY Real Estate ergeant PA`' J g ??y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6367 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 LORETTA SYKES-LACEY (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 $209,207.47 L.L. $.50 Interest FROM 12/19/06 TO DATE OF SDALE AT 9.2500% Atty's Comm % Due Prothy $1.00 Atty Paid $122.32 Plaintiff Paid Other Costs Date: DECEMBER 19, 2006 (Seal) - ?'?-?Kxqd Curti R. Long, onotary 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 # 04 On January 8, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 810 Kent Drive, Mechanicsburg, Hampden Township, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: January 8, 2007 By: _ Real Estate Sergeant E 0 .E d I Z 330 4001 i, • I Goldbeck McCafferty & McKeever - BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 06-6367 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: Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 4. Name and address of the last recorded holder of every mortgage of record: f 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 810 Kent Drive Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: December 18, 2006 Got!Bse ftA,/Goldbeck, cCAFFERTY & McKEEVER BY: Jr., Esq. h 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 Attornev for Plaintiff 06-6367 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s Term No. 06-6367 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: SYKES-LACEY, LORETTA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Your house at 810 Kent Drive, Mechanicsburg, PA 17055 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 $209,207.47 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 06-6367 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 fmd 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 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 -- 06-6367 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 homeretentionngoldbecklaw.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-1387. Para int6rmacion en espanol pueae communicarse con Loretta al 215-62j-631+4. All that certain tract or parcel of ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, PA 17055 SOLD as the property of LORETTA SYKES-LACEY TAX PARCEL # 10-17-103 7-062 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#4 Sworn to and subscribed before me this 18th day of May 2007 A.D. Notarial Seal Terry L. Russell, Notary Public H 'sburg, Dauphin Ccunty ON spy Co i ion Expires June 6, 2010 nsvlvania Association of Notaries NOTARY CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 11' MINII"AW 11 F lip 1? 1& feoll?lalUil lktwig" ?l PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 20, 27 & May 4, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. tor SWORN TO AND SUBSCRIBED before me this 4 day of May. 2007 NOTARIAL SEAL LOSS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 RRAL EgTATE MLR NO. 4 Writ No. 2006-6367 Civil WM Specialty Mortgage LLC. Without Recourse VS. Loretta Sykes-Lacey Atty.: Joseph A. Goldbeck All that certain tract or parcel of ground situate in Hampden Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: Beginning at a point on the east- ern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter. mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 46 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 min- utes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, Page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive, Mechanicsburg, PA 17055. SOLD as the property of LORETTA SYKES-LACEY. TAX PARCEL #10-17-1037-062. 4 • PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6367 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 12/19/2006 to Date of Sale at 9.2500% $209,207.47 (Costs to be added) UWW ?A=wLkjho GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff a QI O ?o H°O za O U F 4 x o .. o F r ? V1 ?] a u p ° W Q ?U ¢ O 0Aa ? o ? W a 0 R' Gl O H ro d? O y U N 0 M b N0 _o N C/] O, M a? 490 v a?_ O N ?o 0 Gn CX3 Ti '? V1 ..:D ?jj ? C :G j?•. t r - - o Cb CLA All that certain tract or parcel of ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, PA 17055 SOLD as the property of LORETTA SYKES-LACEY TAX PARCEL #10-17-1037-062 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Clara Loretta Sykes-Lacey aka Loretta Sykes-Lacey Dehtnrk) WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE BK. NO. 1:07-bk-01713 RNO CHAPTER 13 V. Clara Loretta Sykes-Lacey and Charles J. DeHart, III Esq. Trustee ORDER Upon Consideration of the Certification of Default filed by the Moving Party in accordance with the Stipulation of the parties approved on October 05, 2007 it is ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1978 (The Code) 11 U.S.C. Section 362, is modified to allow WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriff's Sale regarding the premises 810 Kent Drive Mechanicsburg,PA 17055 and a possessory action if necessary. The stay provided by Bankruptcy Rule 4001(a) (3) has been waived. Dated: March 27, 2008 the Cot M 6" io-WI f Tho dA t a tnvi 04 *wow de. Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 06-6367 I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Uffvw I- WI Michael T. McKeever Attorney for plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE C ra PA a Go6beck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6367 AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 810 Kent Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: WM SPECIALTY MORTGAGE LLC 505 CITY PARKWAY WEST SUITE 100 ORANGE, CA 92868 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 f y DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 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 810 Kent Drive Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: April 3, 2008 j? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff N A ??- j??? CA ? ? !•rr% ? ? C"' ??? ? ? i1 ?? ?' { " w ,? ? ?.r.1 "'r, v 06-6367 GOLDBECK McCAFFERTY & McKEEVER IN THE COURT OF COMMON PLEAS of Cumberland County BY: Michael T. McKeever Attorney I.D.#56129 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 CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(: Term No. 06-6367 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: SYKES-LACEY, LORMA AWA CLARA LO=A SYKES-LACEY LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Your house at 810 Kent Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $209,207.47 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: t 06-6367 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. 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. 4. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 06-6367 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: or 717-243-9400. 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website /consumers/homeowners/real.Wx. http://www.Rhfa.org 5). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 1-866413-2311 or via email at homeretentionna ?oldbecklaw.com. Call Seth 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-1387. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6367 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 LORETTA SYKES-LACEY a/k/a CLARA LORETTA SYKES-LACEY (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 $209,207.47 L.L. Interest from 12/19/06 to Date of Sale at 9.2500% Atty's Comm % Atty Paid $941.40 Plaintiff Paid Date: 4/04/08 Due Prothy $2.00 Other Costs 1111714.4,1 - rothonot (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 GOLDBECK WCAFFERTY & WKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO CORRECT CAPTION Term No. 06-6367 Kindly correct the docket to reflect the correct caption of LORETTA SYKES-LACEY AWA CLARA LORETTA SYKES-LACEY. Respectfully submitted, By: IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GOLDBECK, McCAFFERTY & McKEEVER ? Michael T. McKeever, Esquire Attorney for Plaintiff GOLDBECK, WCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Mellon Independence Center SUITE 5000 701 Market Street PHILADELPHIA, PA 19106-1532 (215) 627-1322 FAX (215) 627-7734 Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 April 3, 2008 RE: PRAECIPE TO CORRECT CAPTION Dear Sir or Madam: Kindly file of record the enclosed Praecipe to Correct Caption. We do not need a time-stamped copy for our file. Thank you for your attention in this matter. Very truly yours, isi MICHAEL T. MCKEEVER MTMIJJ S zc w t.3 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 06-6367 Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: 'sec S?,,trs Q"? SCZ) Personal Service by the Sheriffs Office/ ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, 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 Sheriff s 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 Sheriff s Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, 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. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff AMQ-1387 CF: 10/31/2006 SD: 09/03/2008 $209,207.47 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE O O Woo m i ? ; I r M I I O I ? 4J `g I a O in } vQ S N o O O W 4 d U W g 11000 0 ui 0 U U lit r U') jw 246 5 r?i?3co0 am n: S? v q ? a 5 imSp?Wj I I i !0=5=?? Ic'I jM I to ?ti X00 m is d a O? D a? V' N ? C U e U ? h CL Q V y 4 O V U, Y O i`r GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL, ACTION - LAW VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 Term No. 06-6367 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 810 Kent Drive Mechanicsburg, PA 17055 I .Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 WM SPECIALTY MORTGAGE LLC 505 CITY PARKWAY WEST SUITE 100 ORANGE, CA 92868 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 810 Kent Drive Mechanicsburg, PA 17055 (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: July 30, 2008 .,`,--,cam r s?- GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff ? :> r? =-e?t ??. -r -rt - - ??' ? ':1 `-:: L ?'1 C? 6 xJ ?:=? WM Specialty Mortgage LLC, without recourse In the Court of Common Pleas of VS Cumberland County, Pennsylvania Loretta Sykes-Lacey a/k/a Clara Loretta Sykes- Writ No. 2006-6367 Civil Term Lacey Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2008 at 0845 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: Loretta Sykes- Lacey a/k/a Clara Loretta Sykes-Lacey, by making known unto Loretta Lacey personally, at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copies of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 12, 2008 at 1008 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 Loretta Sykes-Lacey a/k/a Clara Loretta Sykes-Lacey located at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Loretta Sy kes- Lacey a/k/a Clara Loretta Sykes-Lacey by regular mail to her last known address of 810 Kent Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of July 2, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Michael McKeever. Sheriffs Costs: Docketing 30.00 Poundage 16.21 Posting Handbills 15.00 Advertising 15.00 Prothonotary 2.00 Mileage 24.00 Levy 15.00 Surcharge 20.00 Law Journal 355.00 Patriot News 316.64 Share of Bills 17.64 ? ?n g $ 826.49 ? Q?? - So Answers: R. Thomas Kline, Sheriff BY r4 G1, Real Estate Sergeant ;,TO &sxgL' 2 1493 Ir Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 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 LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 06-6367 AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 810 Kent Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: WM SPECIALTY MORTGAGE LLC 505 CITY PARKWAY WEST SUITE 100 ORANGE. CA 92868 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box_ 2675 Harrisburg, PA 17105-2675 r DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 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 810 Kent Drive Mechanicsburg, PA 17055 (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: April 3, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff f 06-6367 GOLDBECK McCAFFERTY & MCKEEVER BY. Michael T. McKeever Attorney I.D.#56129 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. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) Term No. 06-6367 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: SYKES-LACEY, LOREITA AWA CLARA LORETTA SYKES-LACEY LORETTA SYKES-LACEY AIKIA CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Your house at 810 Kent Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FI, Courthouse to enforce the court judgment of $209,207.47 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 06-6367 L' 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. 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. 4. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 '117-243-9400 f 06-6367 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: or 717-243-9400. 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website btip://www.pbLa.or-g/consumers/homeowners/real.Mx. 5). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 1-866413-2311 or via email at homeretentionO-goldbecklaw.com. Call Seth 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-1387. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain tract or parcel of ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, PA 17055 SOLD as the property of LORETTA SYKES-LACEY TAX PARCEL #10-17-1037-062 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6367 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 LORETTA SYKES-LACEY a/k/a CLARA LORETTA SYKES-LACEY (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 $209,207.47 L.L. Interest from 12/19/06 to Date of Sale at 9.2500% Atty's Comm % Due Prothy $2.00 Atty Paid $941.40 Other Costs Plaintiff Paid Date: 4/04/08 Prothonotary (Seal) By: REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Deputy Supreme Court ID No. 56129 Real Estate Sale #16 On May 2, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 810 Kent Drive, Mechanicsburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 2, 2008 By: ?UC Real Es a Sergeant L 011 V 01 ddtl 8001 10 ??1?3S X61 C ?1 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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: July 18, July 25, and August 1, 2008 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. Coyne, SWORN TO AND SUBSCRIBED before me this 1 day of August, 2008 , Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My COmmisslOn Expires Apr 28, 2010 RRAL !R'!AIM #Aii NO. 1+6 Writ No. 2006-6367 Civil WM Specialty Mortgage LLC, without recourse vs. Loretta Sykes-Lacey a/ k/ a Clara Loretta Sykes-Lacey Atty.: Michael McKeever All that certain tract or parcel of ground situate in Hampden Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: Beginning at a point on the east- ern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deim- ler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive, Mechanicsburg, PA 17055. SOLD as the property of LORETTA SYKES-LACEY. TAX PARCEL # 10-17-1037-062. ?he Patriot-News Co. 812 Market St. Harrisburg, PA 17101 iquiries 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE ?hePatriot News Now you know CARLISLE PA 17013 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 This ad ran on the date(s) shown below: 07/23/08 l?ik Sworn to an scribed before me tt\ii C -- Notary Public df A upt, 2008 A. D. 07/30/08 08106/08 TH OF PENNSYWANIA NoW Seal &Wft L lQWw, Nohry pW* Ca l"M E)4*W Nov. 2e 2Df I Member, PennsyNW14 Assodeftn or Nouut" Il" game amb-1616 is '; rMMt Nallaiillif tavNTi'm wu is so m LLCM Vs LoroiM Sykes4imm t awa Clem AV*nray ilfNaasl MelCwm LEGAL DE PTK)N All that cow tract or pucel of V%W awate in Bamgden Toww*, CmubedAnd Cmty, Fenosylnma, mm,px*Wxiy bounded and 'desaitied as follows to Wit Begmmng at a point on the aortas rigbt-0f--way line of Kent Drive at the dividing bran bdween Lots Nos. 62 and 63, of the bwem fter memiomed plea of lots; %m m, said dividing line north 69 dWm 11 minutm 20 seconds #W 120 fat pp a point; tbeue along line ofb No. 62 somb,20 domes 48 mimrtes 40 seconds east 105 feet to line of Lot no. 61; thence along to same south 69 degrees 11 40 place of beginning. Being.all of Lot No. 62 on Ore Final No No.2, Part of Seca 2, Dwok Mom mw*d at Plan Book 33, page 10, Cumberland County Records. Il 1TS consist of "a mWential dwelling. BEING PREMISES: 810 Kent DrivAkdankslug. PA17055 SOLD as the paopeny of LORETTA SYKES- LACEY TAX PARCEL. #10-17-1037-062 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.F' 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6367 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 12/19/2006 to Date of Sale per diem at $46.86 $209,207.47 (Costs to be added) GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff (ri cy, G 00 00 00) in; all* Imo o b ? ? a N C:21 ri-I R to rj d H H ? O p Oa W ?" ? W O U O °c- W Q 1 ° O D I f rC) 1U ^.3 W W ? n H U O W U n, O + N W W U cn W a 3 p a? N Ixl U R$ U U N vMi ? ? U N Y ? a Vl All that certain tract or parcel of ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, PA 17055 SOLD as the property of LORETTA SYKES-LACEY TAX PARCEL #10-17-1037-062 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CLARA LORETTA SYKES-LACEY a/k/a LORETTA SYKES-LACEY, Debtor CHAPTER 13 CASE NO: 1-08-bk-02345-MDF WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Moving Party V. CLARA LORETTA SYKES-LACEY a/k/a LORETTA SYKES-LACEY, CHARLES J. DEHART, III., ESQUIRE, TRUSTEE, Respondents RE: DOCKET ENTRY NO: 28 MOTION FOR RELIEF FROM STAY 1 I U.S.C. Section 362 and 1301 ORDER Upon consideration of Movant's Motion for Relief from the Automatic Stay, it is ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under I 1 U.S.C. Sections 362 and 1301 of the Bankruptcy Reform Act of 1978 (The Code) I I U.S.C. 1 I U.S.C. Sections 362 and 1301 (if applicable), are modified to allow WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriffs Sale regarding the premises 810 Kent Drive Mechanicsburg, PA 17055 and a possessory action if necessary. The stay provided by Bankruptcy Rule 4001(a)(3) has been waived. Movant may, at its option, provide and enter into a potential forbearance agreement, loan modification, refinance agreement or other loan workout/ loss mitigation agreement. The moving 1 Case 1:08-bk-02345-MDF Doc 40 Filed 11/18/08 Entered 11/18/0813:58:10 Desc party may contact the debtor(s) via telephone or written correspondence to offer such an agreement. Dated: November 18, 2008 2 Case 1:08-bk-02345-MDF Doc O Filed 11/18/08 Entered 11/18/08 13:58:10 Desc f .. Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6367 AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 810 Kent Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Bok 2675 Harrisburg, PA 1710512675 WM SPECIALTY MORTGAGE LLC 505 CITY PARKWAY WEST SUITE 100 ORANGE, CA 92868 64 s DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 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 810 Kent Drive Mechanicsburg, PA 17055 (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 24, 2008 QM a --? Q) _ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff m cil !".3 CP. 'IJ Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 06-6367 I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. UOAU :1 yy Michael T. McKeever Attorney for plaintiff n ? m .? 1 cj, =G -1 W 06-6367 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WM SPECIALTY MORTGAGE LI C, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. LORETTA SYKES-LACEY A/K/A'CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(o) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s Term No. 06-6367 THIS LAW FIRM IS A DEB COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS N TICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY I FORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. TO: SYKES-LACEY, LORETTA A/K/A C ARA LORETTA SYKES-LACEY LORETTA SYKES-LACE A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Your house at 810 Kent Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2009, at 10:0 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $209,207.7 obtained by WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE against you. CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 06-6367 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. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. 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). 1. If the Sheriffs Sale is not stopp d, 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 i the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call th 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 f the money which was paid for your house. A schedule of distribution of the money bid for your h use 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 schedul unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within t (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. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER T 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 06-6367 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 lmay 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretentionkgoldbecklaw.com. Call Seth 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-1387. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6367 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 LORETTA SYKES-LACEY a/k/a CLARA LORETTA SYKES-LACEY (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 evied 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 state . Amount Due $209,207.47 Interest from 12/19/06 to Date of Sale Atty's Comm % Atty Paid $1,791.89 Plaintiff Paid Date: 11/25/08 (Seal) REQUESTING PARTY: L.L. $.50 diem at $46.86 Due Prothy $2.00 Other Costs to be added Curtis R. Long, rothonota By: Deputy Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFER Y & MCKEEVER SUITE 5000-MELLON IN EPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 191 6-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 AMQ-1387 CF: 10/31/2006 SD: 03/04/2009 $209,207.47 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 06-6367 n o o .o i CERTIFICATE OF SERVICE: PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) ._. ` C) t ' J xy Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service one N Defendants of the Notice of Sheriff Sale was made by: co ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, 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 Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, 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. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff I. C2 c o ooQ i . -- _. .'.. - tA' a - - - ----- ? oU i o o .7 I Zn o I I I 14 f i 20 z ? a e c , I c a ? o??o 000n 0 co i a z° g N w W n U ? U O w a ? G m ? O a W:2 ??m a ? c i ?T-CD X d N 0 F- 0. 2U)H LU 0 O l ' 0 0 ao ?9aio m a a = 0 ( ) I p i I I CL A 4• i V$WJN ? i ? i O W? i I I ? mQ11?? T I I J ? T T ? {iA I I1? i 5y 0=01 i? CV IM ?i sip ? 9?dr I ? I v i g a O a m N 2 v ? N l0 i~ N r E LL M zt o UNUED AMPOSTAL.1 Date Produced: 12/08/2008 GOLDBECK MCCAFFERTY & MCKEEVER The following is the delivery information for Certified MailTIftem number 7111 4342 3630 0046 6784. Our records indicate that this item was delivered on 1210512008 at 03:24 p.m. in MECHANICSBURG, PA, 17050. The scanned image of the recipient information is provided below. DMNry •?allow nn Signature of Recipient: YK S " Ac6V Address of Recipient: MY t 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 representitve. Sincerely, United States Postal Service v The customer reference number shown below is not validated or endorsed by the United M States Postal Service:-it is solely for customer use. Customer Reference Number: 4340453 16625576 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever . 'Attomey I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff . WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 Term No. 06-6367 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 810 Kent Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE WM SPECIALTY MORTGAGE LLC 505 CITY PARKWAY WEST SUITE 100 ORANGE, CA 92868 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 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 810 Kent Drive Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: February 2, 2009 `CK {?ef?L5G?/ L /G ?GC.t/?Gl GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff n ^? L?r`' HIM C7?`- ' CJ N GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor and Record Owner 810 Kent Drive Mechanicsburg, PA 17055 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 06-6367 MOTION TO POSTPONE SHERIFF'S SALE Plaintiff, by and through its attorneys, in support of its Motion to Postpone Sheriffs Sale represents as follows: 1. Plaintiff is the holder of first mortgage upon the premises, 810 Kent Drive Mechanicsburg, PA 17055, hereinafter the "mortgaged premises." 2. Defendant is the mortgagor and record owner of the mortgaged premises. 3. A Sheriffs Sale of the mortgaged premises was scheduled for March 4, 2009, and was postponed pursuant to PaR.C.P. 3129.1 until April 1, 2009. 4. The Sale for April 1, 2009 was postponed until May 6, 2009 5. A Sheriff's Sale of the mortgage premises is scheduled for May 6, 2009 and will need to be postponed to June 10, 2009 due to the Fannie Mae Moratorium. 6. There is no prejudice to any party. WHEREFORE, Plaintiff requests that the Court enter Plaintiffs proposed order, which will postpone the sale until Thursday, June 10, 2009. Respectfully submitted, GOLDBECK MCCAFFERTY & MCKEEVER I 1? 7 By: A Michael T. McKeever, Esquire GOLDBECK McCAFFERTY & McKEEVER Michael McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 Attorney I.D. #56129 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor and Record Owner 810 Kent Drive Mechanicsburg, PA 17055 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 06-6367 MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 3129.3(b) allows a judgment creditor to postpone a sheriffs sale up to two times within a one hundred thirty day period without new notice. The postponement must be announced to all assembled bidders. As outlined in the attached motion, the Sheriff s Sale has already been postponed as allowed by Pa.R.C.P. 3129.3(b). Plaintiff seeks Court approval under, inter alia, Pa.R.C.P. 126, to postpone the sale again. This postponement will be announced to all assembled bidders. CONCLUSION For all the reasons discussed above and in the attached Motion, the Court should enter the attached Order postponing the Sheriffs Sale. Respectfully submitted, GOLDBECK CAFFERTY & McKEEVER By: '? I N ? I-. ffi cupf"A "/ Michae T. cKeever, Esquire GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff VS. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor and Record Owner 810 Kent Drive Mechanicsburg, PA 17055 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 06-6367 CERTIFICATE OF SERVICE Michael T. McKeever, Esquire, attorney for Plaintiff, hereby certifies that a copy of Plaintiffs Motion to Postpone Sheriffs Sale was mailed by first class mail, postage prepaid, to Defendant(s) on May 4, 2009. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Respectfully submitted, GOLDBECK MCCAFFERTY & MCKEEVER y' Michael T. McKeever, Esquire GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor and Record Owner 810 Kent Drive Mechanicsburg, PA 17055 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 06-6367 VERIFICATION Michael T. McKeever, Esquire, hereby states that he is the attorney for Plaintiff herein, and that all of the facts set forth within the attached Motion to Postpone Sheriffs Sale are true and correct to the best of his knowledge, information and belief. The undersigned understands that the foregoing statements are made subject to the penalties of 18 P.S. Section 4904. Na WXV Michael T. McKeever, Esquire RED- OF THE RR;1 7, 2009 MAY -5 PM 12: G 1 ?} .. , rs• r MAY 0 5 T"I i WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor and Record Owner 810 Kent Drive Mechanicsburg, PA 17055 Defendant ORDER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 06-6367 AND NOW, this S 1? day of A4 2 1 , 2009 upon consideration of Plaintiffs Motion to Postpone Sheriffs Sale and any response thereto, it is ORDERED and DECREED: That ±he Motion is granted and the Sheriffs Sale in the above-captioned matter is hereby postponed until Wednesday, June 10, 2009, and month-to-month thereafter, without need for further advertising ?t• U BY THE COURT: J. Q, s3?? L I.1 { WV 9- AVW 6002 ?1? ` WM Specialty Mortgage LLC, Without In The Court of Common Pleas of Recourse Cumberland County, Pennsylvania VS Writ No. 2006-6367 Civil Term Loretta Sykes-Lacey a/k/a Clara Loretta Sykes-Lacey Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2008 at 1810 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: Loretta Sykes- Lacey a/k/a Clara Loretta Sykes-Lacey, by making known unto Loretta Sykes-Lacey personally, at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2009 at 1928 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 Loretta Sykes-Lacey a/k/a Clara Loretta Sykes-Lacey located at 810 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Loretta Sykes- Lacey a/k/a Clara Loretta Sykes-Lacey by regular mail to her last known address of 810 Kent Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of January 9, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 67.32 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 23.40 Levy 15.00 Surcharge 20.00 Postpone sale 40.00 Law Journal 355.00 Patriot News 334.58 Share of bills 15.52 933.32 ? c.??q?n 9 ?. So Anse I-IM.-Mb 01 oeolgf4o't., R. Thomas Kline, Sheriff BY OP-0 11 ^ Real Estate Coordinat cr? ,.,, r 3 . 6.? 1? 8 ::. " \ . to ? OD .? c)? G 94 9 /Cw..1a4Y.3Z' Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY (Mortgagor(s) and Record Owner(s)) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-6367 AFFIDAVIT PURSUANT TO RULE 3129 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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: 810 Kent Drive Mechanicsburg, PA 17055 I.Name and address of Owner(s) or Reputed Owner(s): LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 A/K/A CLARA LORETTA SYKES-LACEY 2. Name and address of Defendant(s) in the judgment: LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 A/K/A CLARA LORETTA SYKES-LACEY 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 WM SPECIALTY MORTGAGE LLC 505 CITY PARKWAY WEST SUITE 100 ORANGE, CA 92868 1I r DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 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 8l0 Kent Drive iVlechanicsburg, PA 17055 (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 24, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 06-6367 GOLDBECK WCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 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. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY Mortgagor(s) and Record Owner(s) 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s Term No. 06-6367 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: SYKES-LACEY, LORETTA A/K/A CLARA LORETTA SYKES-LACEY LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Your house at 810 Kent Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $209,207.47 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 06-6367 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. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is tiled. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: am://www.philadell2hiafed.org/foreclosure/ 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 06-6367 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website htip://www.phfa.orp,/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 Seth 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-1387. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain tract or parcel of ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of-way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, PA 17055 SOLD as the property of LORETTA SYKES-LACEY TAX PARCEL. #10-17-1037-062 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) ` COUNTY OF CUMBERLAND) NO 06-6367 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 LORETTA SYKES-LACEY a/k/a CLARA LORETTA SYKES-LACEY (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 $209,207.47 L.L. $.50 Interest from 12/19/06 to Date of Sale per diem at $46.86 Atty's Comm % Due Prothy $2.00 Atty Paid $1,791.89 Plaintiff Paid Date: 11/25/08 (Seal) REQUESTING PARTY: Other Costs to be added C is R. Long, ro onotar By: Deputy Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY &.MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale #69 On December 15, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 810 Kent Drive, Mechanicsburg more fully described on Exhibit "A" filed with this writ and by this reference le incorporated herein. Date: December 15; 2008 By: em Real Estate Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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 30, February 6, and February 13, 2009 Affrant 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. Li a Marie Coyne, Edi r SWORN TO AND SUBSCRIBED before me this day of February 13, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY MY Commission Expires Apr 28, 2010 FiAL ? 4" NO. N1 Writ No. 2006-6367 Civil WM Specialty Mortgage LLC, without recourse vs. Loretta Sykes-Lacey a/k/a Clara Loretta Sykes-Lacey Atty.: Michael McKeever All that certain tract or parcel of ground situate in Hampden Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: Beginning at a point on the east- ern right-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 d ees 11 minutes 20 seconds west 1 Am* to the oaeWa rW-4 wW fie of Sent Drive, >9rewca ; WWlire wme ?ffi 20 de?owae ? r,o seoaie?ls west 105 fist to *n of Lot Mo. 63, dw plaw of adwss6atiatNo. *a I& ftwi Plan No. 2, Part of Section 2, Deim- ler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive, Mechanicsburg, PA 17055. SOLD as the property of LORETTA SYKES-LACEY. TAX PARCEL #10-17-1037-062. Thp Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ZhePatriot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since-, That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 REAL ESTATE SALE NO. 69 Writ No. 2006-6367 Civil Term WM SPeclalty Mortgage LLC, without recourse VS Loretta Sykes-Lacey alWa Clara Loretta Sykes-Lacey Attomey Michael McKeever LEGAL DESCRIPTION All that certain tract or parcel of ground situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the eastern tight-of-way line of Kent Drive at the dividing line between Lots Nos. 62 and 63 of the hereinafter mentioned plan of lots; thence along said dividing line north 69 degrees 11 minutes 20 seconds east 120 feet to a point; thence along line of Lot No. 62 south 20 degrees 48 minutes 40 seconds east 105 feet to line of Lot no. 61; thence along the same south 69 degrees 11 minutes 20 seconds west 120 feet to the eastern right-of--way line of Kent Drive; thence along the same north 20 degrees 48 minutes 40 seconds west 105 feet to line of Lot No. 63, the place of beginning. Being all of Lot No. 62 on the Final Plan No. 2, Part of Section 2, Deimler Manor, recorded at Plan Book 33, page 10, Cumberland County Records. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 810 Kent Drive Mechanicsburg, Ph 17055 SOLD as the property of LORETTA SYKES- LACEY TAX PARCEL #10-17-1037-062 This ad ran on the date(s) shown below: 01/21/09 01128/09 02104109 . .. . .. . .. .: Sworn to and sscr' d before me this 25 day of February, 2009 A.D. i l c Notary Public :,0MM0NVVEc.'.! --' F 'c 1-'(? SYLVAN;; Shertie L K! Netary Public Cay Of Harns " Dx.;phin County My Convriespoi r :),rFx- Nov. 26, 2011 Member. Pennsvw- ', s rlatlon of Nota;w- 1 . w GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff IMF ,- P",Ti `;I!OAF?Y 2010 MAR 29 PM 3: 53 CUM r, `":; ?? ? il?t4 t y P E 3, SyUP',, WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: No. 06-6367 Kindly vacate the judgment upon payment of your costs only. MI EL T. MCKEE ER, QUIRE r? a34/. v7 IN THE COURT OF COMMON PLEAS of Cumberland County W?. .-,ft. GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 OF FlC f? i ''! i r ' NOTAN 2010 MAR 29 PM 3: 54 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. LORETTA SYKES-LACEY A/K/A CLARA LORETTA SYKES-LACEY 810 Kent Drive Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County No. 06-6367 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. JM' el T. McKeever, Es/ ire Attorney for Plaintiff