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Home My WebLink About02-2897GOLDREGk #&CAFnRTV BY: JOSEPH A. GO1 DBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF & McKEEVER MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagor(s) and Real Owner(s) 491 State Street West Fairview, PA 17025 Defendant(s) OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term / No. U2 - ai`?7 ce 1. T" CIVIL ,ACTION: MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 end 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 ad 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 orreliefmquestedbydre Plaintiff. You may lose moneymproperty orotherrights importantio you. YOU SHOULD TAKE THIS POPER 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 TO FIND OUT WHERE YOU CAN (,ET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC ' 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A LISTED EN LA CORTE. ° DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER St RVIDO 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. FOR RAZON DE ESA DECISION, ES POSSIBLE QUE LISTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A I!N ABOGADO, FLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632. The name(s) and address(es) of the Defendant(s) is/are AMBER C. HAMMAKER, 119 N. Enola Drive #5, Enola, PA 17025 and LESTER L. HAMMAKER, 119 N. Enola Drive #5, Enola, PA 17025, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On April 07, 2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1607 Page 739. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 3. The premises subject to said mortgage is described as attached. 4. The mortgage is in default because monthly payment of principal and interest upon said mortgage due March 01, 2002, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 5. The following amounts are due on the mortgage: Principal Balance Interest from 02/01/2002 through 06/30/2002 at 9.6250% Per Diem interest rate at $13.61 Attorney's Fee at 5.0% of Principal Balance Late Charges from 03/01/2002 to 06/30/2002 Monthly late charge amount at $22.18 Costs of suit and Title Search Escrow Monthly Escrow amount $35.22 $51,630.62 $2,041.49 $2,581.53 $88.71 $750.00 $0.00 6. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 7. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) 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 "A". The Defendant(s) has/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(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $57,092.35, together with interest at the rate of $13.61, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. DY: JOSEPH A. LrOLDBECK, JR•, hSQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Michael Vestal, 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 IS Pa. C. S. 4904 relating to unswom falsification to authorities. Date: &dA. Michael Vestal Countrywide Home Loans LsulDwriation ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE EAST PENYSBORO TWP, COUNTY OF CCNBERLAYD AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS. TO WIT BEGINNING AT A POINT ON THE NORTH SIDE OF THE STATE ROAD WHICH POINT IS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET (ERRONEOUSLY REFERRED TO IN PRIOR DEED AS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (2555) FEET) WEST OF THE CORNER OF LANDS NOW OR LATE OF JOSEPH L BEST. THENCE NORTHEASTWARDLY ALONG LANDS OF WILLIAM M WORLEY TWENTY-FIVE AND EIGHT-TENTHS (258) FEET TO A POINT IN THE CENTER OF THE PARTITION WALL BETWEEN THE HOUSE HEREIN CONVEYED AND THE ADJOINING HOUSE, THENCE CONTINUING THROUGH THE CENTER OF THE PARTITION WALL IN SLIGHTLY MORE EASTWARDLY DIRECTION FORTY-EIGHT (48) FEET TO AN IRON PIN AT THE END OF SAID PARTITION WALL, THENCE IN A MORE NORHWARDLY DIRECTION ONE HUNDRED FOUR AND FOUR TENTHS (104 4) FEET TO AN IRON PIN AT THE SOUTHERN SIDE OF A FOURTEEN (14) FEET WIDE ALLEY, WHICH IRON PIN IS TWENTY-SIX AND TWO TENTHS (262) FEET WEST OF LANDS NOW OR LATE OF JOSEPH L BEST, THENCE BY SAID ALLEY SOUTH SIXTY-TWO (62) DEGREES EAST TWENTY-SIX AND TWO TENTHS (262) FEET TO AN IRON PIN AT CORNER OF LOT NOW OR LATE OF JOSEPH L BEST, THENCE BY THE SAME SOUTH FIFTY-ONE (51 DEGREES FORTY-FIVE (45) MINUTES WEST EIGHTY NM AND FW&TENTHS (89 5) FEET TO AN IRON PIN, THENCE BY THE SAME SOUTH FORTY-FIVE (45) DEGREES FORTY. FIVE (45) MINUTES WEST NINETY-ONE (91) FEET TO AN MON PIN ON THE NORTH SIDE OF SAID STATE ROAD, THENCE ACROSS SAID STATE ROAD BY LAND NOW OR LATE OF SAID JOSEPH L BEST SOUTH FIFTY- FOUR (54) DEGREES FORTY-FIVE (45) MINUTES WEST TWO HUNDRED FORTY-SEVEN CU7) FEET TO A STAKE ON THE BANK OF THE CONODOGLINET CREEK. THENCE UP SAID CREEK EASTWARDLY BY THE BANK THEREOF TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET TO A POINT AT THE OTHER LAND NOW OR LATE OF KAROL EMIL MALSH. ET UX, THENCE BY THE SAME ACROSS SAID LOT NORTH FIFTY. FOUR (54) DEGREES FORTY-FIVE (45) MINUTES EAST TWO HUNDRED FORTY-SEVEN (247) FEET TO A POINT, THE PLACE OF BEGINNING THERE BEING ERECTED THEREON THE EASTERN HALF OF A DOUBLE TWO STORY FRAME DWELLING, NO 491 STATE ROAD ECounbwMr NONE LOANS SwMConimpondencetw PIC aft 8239 Van N UYS, CA 91409WN Apffl 18, 22" Usterl.HemmakeEXHIB' ° A 491 Stale Street West Fairview, PA 17025-0000 SOW Parma a m: P a Box6A78af Dee91, 7X 7SPW-0694 Certified Mall No. Retum Receipt Requested Regular Meti Account No.: 2419187 Properly Address: 491 Slate Street West FalrYlew, PA 17025-0000 Current SeMcen Couraryeid9 Hang Loess SerAcarg LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains Important legal Information. 8 you true any questlons, Mpteewdad ea at the Consumer Credit Counselling Agency may be able to help answer them. You may also want to contact an attorney M your area. The Iocal tar easocr I*n may be able to help you find a lawyer. LA NOTIRCAC16N EN ADJUNTO ES DE SUMA NIPORTANCIA, PUBS APBCTA SU DERECHO A CONTINUAR VWIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIRCAC16M OSTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS ALL NIIMERO MENCIONADO ARRBA, PUEDE SER ELEGIBLE PARA UN PRitBTAMo PGR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERODA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FI MgA! ASSISTANCE WHICH AN SAVE YOUR HOPE FROM FORECLOSURE AND HELP YOU &ME FUTURE MORT AGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACM, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. Pisces write yaureornaa rxSawmall chacp enawmgmaarca. BCBRPA BI2er4000 LwerLHnamNlp 2419187.6 wl9rwehoH AID Vhr.PaPPg0.1M4lWI4N,MtlIALSY?a4wY,eilblr. 60ern Howe wAw P.O. BOX 0601104 Dallas, TX 76288-0894 Il.,drLL„6fdLHILdLHdLddnrLdLiHdu6ddl $1,38856 AS OF May 18, 2002 241918760001388560138856 A HOME o?Y C= LOANS S98d Cona?andarcl la P.O. eox 8799 Vw fnaw, GA 914OHM APrll 18, 2002 Lester L Hammaker i19NEnola Dr 5 Enola, PA 17025-2521 Send Pa n oos to: P.O. Box 8806914 DVO, 7X 7G266G694 Cer60ed Mall No. Return Recelpt Requesiou Regular Mall Account No.: 2419187 Property Address: 491 State Street West Fairview, PA 17025-0000 Current Servlcer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Th le In o n oft lel notice th at the r mrtasa s on Your h one Is In defe N an d the tender lintands to foreclose Sm ack: Informa tion sho ut the rNMM of th e default Is Pro vided In the ans.hed as The H OMEO VM R'S EMERG ENCY M ORTG AGE ASSIS TANCE PROG RAM MAP) am be able vc w home . This Notics expl ains how the o roara m works To s ae I I EM AP can halm you run t MEE T WITH A C ONSUMER CR EDIT C OUNSELING RACY WITHIN ur DAYS OF T HE D ATE OF THI S NOTIC E Tak e this Notim with You whe n you meet with the Cowyelno Aeen... This NoUm ooMalm Important legal kdo nrabon. I you here any questions, repreeeme8vas at the Consumer Credh Couneelfrrg Agency may be able to help answer them. You may oleo ward to contact an attorney In your area. The local bar assodallon may be able to help you find a lawyer. LA WMFICAC16N EN ADJUNTO ES DE SUMA IAPORTANCIA, PLIES AFECTA SU DER ECHO A CONTINUAR VIVIENDO EN SU CASA. 81 NO COMPRENDE EL CON7ENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N WMEDIATAMEMM LLAMIWDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) $IN CARGOS AL N(NIERO MENCIONADO ARHIBA. PUEDE SER ELEGIBLE PARA UN PR@STAMO FOR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIN SU HI+OTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL SSWANCE WHICH CAN SAME YOUR HOME FROM FORErr OS roe AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROYL91ONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1989 (THE "ACT"), YOU MAY 13E ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED 13Y CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. PNUa wrm YOura nt nwbarw all clwdm and wirespomiarm. SCBRPA ar28r2000 ? LAIILIemmeur 2419187-6 Tar em4 3o-aw ArwwwmPaaaYalmr4wlA,.a„awrrwa«a.e..wrwbr, =1,388.56 ASOF May 18, 20112 ??????ewrvA Nona canna P.O. Box 880894 Dallas, TX 75266-0694 16 WIdr6NLldIudlPlbrnlllhLuIIILIudllrJd{ 241918760001388560138856 Countrywide- HOME LOANS Sena Corles=dw to: P.0.8wt11239 Van MOM, CA 914098139 April 18, 2002 Amber C Hemmaker 491 Slate Street Weal Fairview, PA 17026-0000 SON Paym9a to: P.O. erol6 MM Osra, TX 76PB6.069N CaA61ed NOB No. Retum Receipt Requested Regular Mail Account Nm: 2414157 Property Address: 491 State Street West FeirvieW, PA 17025-0000 Current Servlpen Coumlyn M Hone Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This la an MBolal noti0e that the moriosse on vour home Is In default, and he lender Irdonds to forecloaa, SmI c hdonwaon abols the netura c/ the default Is provided In t Mad tattles. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MMAPI eery he able to help to save tour home This Notice sOnlaUw how the oromam works. IQ see I HEMAPon haLh. you must 11111a WITH A CREDIT COUNSELING AGENCY V Nast DAYS OF THE DATE OF THIS NOTICE. T Ale NOtL_ with you when You moat with no Cohn..,, AOeaaa This Hades contslrw Importers ieW lmonnamen. R you have any questions, rep eunhdhes at the Consumer Credit COunaa ft Agency may be Obis 10 h61p ~OF them. YOU meY 0180 Wee 00 contact an attorney In your area. The 10061 bar aeeobiaiton may be ebb to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES OE SUMA IMPORTANCL% PUBS AFECTA SU DERECHO A CONnNUAR VNIENDO EN SU CA" III NO COMPREN09 EL CONTENIDD DE ESTA NOTIFICAC16N OBTENGA UNA 7RAOMC16M INMEWATAMEWM LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA PUEDE SER ELEGISLE PARA UN PREBTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PEROMA DEL DERECHO A REDIMIR SU HIPOTECA HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE EUG113LE FOR MAM86 AS?IS MCE WHICH CAN SAVE YOU HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGA13E PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1989 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. Pmoowap yarawowenunberw all d"M WA oonsponamoa. 8CBRPA aW2000 ,u,e"rOMa"w 24191876 491aWe9ww AMOYaIMaFIWYaI,aMlNrM1?MANnIrY"hM?„aMW 4eiMlr.. awe looms P.O. Bas 080894 Dail", TX 76288-0694 ILu6LLaLIdLPILdLndLddmLdldadnloldl 51,968.58 AS OF May 18, 2002 241918760001388560138856 MUM Counbywidee HOME LOANS senn[>orreepanaence N: P.O an Van Maya, , CA CA 97/048299 April i8, 2002 Amber C Hemmaker 119 N Enola Or 5 Ends, PA 170254521 Send Payrtanro W. P.O.B=880694 DaURA, 7X 781884694 Certified Mall No. Return Receipt Requested Regular MNI Account No.: 2419187 Property Address: 491 Slate Street West Fairview, PA 17025-0000 Current Serview. Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This W an afhtlal notim Men the mortga is an your home I s In de fyuit a nd the lender o roarkM to kadom Sasdllo hilomrtion ahem the Silligg of dw d@M M to omvlde d In th e athetha d nouss. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANC your ftg=. This Modes amlelne I E PRO mw th GRAM I e twoore HEMA m wo P) may b rks e able m holy to save Ty we r HEMAP can help. you must MEET WITH A CONSU ' ML C REDIT COD . LING AGENCY WITHIN 9a DAYS OFTHE DATE OFTHIB NOTICE Take this Notice with you w hen YO U meet with the Co naehnn Agewy, This Notice Contains Important legal InmrroBon. E you hew any questions, represe b fives at the Consumer Credit Counseling Agenoy may be able to help answer them. You may also went to contact an attorney in your Was. The ktesl bar association may be able to help you find a lawyer. LA NOTIFICAC16N EN ADJUNTO ES DE SUMA BIPORTANCIA, PUES AFECTA SU DERECHO A CONnNUAR VIVIENOO EN SU CASA. SI NO COMPRE:NDE EL CONTENIDO DE ESTA N071FICAC16N OBTENGA UNA TRADUCCIGN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AOENM SIN CARGOS AL N(WERO MENCIONADO ARRBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO FOR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL DUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL AWSTA CE WHICH CAN AVE YOUR HOME FROM ':R r ^ IR AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1948 (THE "ACrj, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: , IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. Reese wile yma=urd rox0mran as chegearyl dmcq WIIFFA A98WW Am vc14.r fidW 2419187.6 art grr.6u..t Aw?"Iea0lW?rl F4W raewlpwpw?,I,gxlewpr Me,wiMpee ecavw MCM*wAdLw lwns r oms P.O. amt 660584 Dallas, TX 75258.0894 ILn61dmLLIlndlnOnrdl„LL,dnlLlyduL,L11 $1,988.58 AS OF May 18, 2002 241918760001388560138856 4ARY,$ggY OF FO,REFCLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on s far ihiriy (30) days from the date of this Notice. During that time you must arrange and adend a Tace toe with one of the consumer credit counseling agencies listed at the end of this Notice. THIS ?AEETING IN CONSUMER CREDIT COUNSELING AGENCIES _ It you meet with one of the consumer credl counseling agencies Meted m the end of this notice, the lender may NOT take adore against you for thirty (30 days attar the time of this n is Dory necessary to sonedme one fabe- o4acemeeung. ArNise yotw lentler lf0!!ffi Caf your intentions. APPLICATION FOR MOSTUAGE ASSISTANCE - Your mortgage is In defeuN for the reasons set forth later in this notice (sae 105DOng pages for specific Information about the nature of your default.) N you have tried and are unable to resolve this problem with the tender, you have the right to apply for financial assistance from the Homeowners Emergency Mortgage Assistance Program. To do so, you must tW out, dp and file a completed Fomeownees Emergency Assialime Program Application with one of the designated consumer credit counseling agencies listed at the and of this Notice. Only consumer credit oounsong agencies have applications orthe pnograrn and they will assist you In submfftog a complete application to the Pemsylvano Housing Finance Agency. Your application MUST be flied or pebbrnarked within thirty (30) day$ of your faro 404ace meeting. YOU V= FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO Sn 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 DEWED. AGENCY ACTION - Available funds for emergency mortgage assistance are vary limited. They will be disbursed by the Agency under the eiigbllay criteria established by the AcL The PannsyNante Housing Finance Agency lies sbdy (60) days to make a decision after it receivea your application. During that time, no foreclosure proceedings will be pursued against you N you have met the time requhemerds set forth above. You will be nodfled directly by the Pennsylvania Housing Finance Agency d as tlacislon on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IN FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (N You have tiled bens rupicy you Can SUN a" for Emergency Marts" AsslstenoW.) NATIM OF THE DEFAULT. •^t••e?l Home one Servicing o. (hereamaher'Countiyiy ) smvtcse your home loan. Your home loan Is In serious default beoauee you have not made your required payments. The total amount now required to reinstate your fame loan as of the data of this letter Is as follows: Monthly Pauments $478.91 $1,439.73 Late Chasing: $22.18 $88.54 aggrGtnenras: Uncollected Late Charges: $71194 Uncolected Costs: $193.85 TOTAL DUE: $1,81111.56 PAYMENT INSTRUCTIONS Please • MgteyoundadflayehlemCovayewsrblaLaaa • Vhibygrben nribgrem)awdakwmaneyadr • WAhtnasaes6aeaemMVcuaeaAftgf Ida a mite lmn 46000, pleats tea emmlae Lf 1adf.) • DWI elrayowdmdcmae Wponlewpm eepmnlenm • Dml m alGish • Dml etadC6h u>yemme NupapmnaeNmepplmtoaelmpgetassana?ymalmmmam,muwemamweev,eeuypombraeyr. A47mmW tms,m. B tau 4ar1 egtme am guegee m e4alarm rmmr twsa.a w.mnwem As w aw nuw.mau HOW 70 CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $1,35&56, plus any additional monthly payments, late charges, foss and other applicable charges Which may fall due during this period. Such payment must be in the form of certified check, cashier's check or Money order, and made payable to Countrywide at P.O. Box 5(10594, Dallas, TX 75266-m94. It your check or other payment Is returned to us for Insufficient funds orfor any other reason, you w51 not have cured your default No edenslon or time to cure well be granted due to a Mumed payment. IF THE YDRTGAOE IS FORECLOBED UPON default the mortgage is foreclosed, the mortgaged property will be sold by the Sheriff to pay ofi the mortgage deb. If the default Is cured before we begin legal proceedings, Countrywide will be entitled to collect the reasonable auomeys fees actually Incurred, up to $50.0D. However, If legal proceedings are started, Countrywide will be entitled to collect the reasonable attorneys lees even 5 they are over $50.00. Any ahorneys teas will be added to the secured debt, which may also Include our reasonable costs. M you Cure the default within the THIRTY (30) DAY period, you will not be required to pay attorneys fees. OTHER LINDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RM3HT TO CURE THE DEFAULT PRIOR TO FORECLOSURE SALE - it you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the foreclosure sale. You may do so by paying the total amount then past due. plus any We or other charges then due, reasonable ntbmeys fees and costs connected With the foreclosure sale and any other cods connected with the foreclosure sale as specified In writing by the lender and by performing any other requirements under the mortgage. Curing your default M the manner set forth in tills notice will restore your mortgage to the memo positron am If you had never dslatrited. EARLIEST POSSMBLE FORECLOSURE SALE DATE . It Is estimated that the earliest data that a foreclosure sale could be held would be apprddmmaly, six (6) months from the date of this letter. A notice of the date of the foreclosure sane will be sent to you before the sale. You may Bnd out at any time exactly what the required payment will be by calling us at the following number. 1-000559-0102 This payment must be In the form Of a cashiers checK certified check or money order and matte payable to us at the address slated above. If the default is cured, the mortgage will be restored to the same position as 11 no default had occurred. However, the default may not be Cured move than three (3) times M any calendar year. HOW TO CDM'ACT THE LENDS - Norms of LaMar. Courrtywlde Nmrb Lama SmvkbV LP AddmlL P. O. Box 10221 Van Nuys, CA 9141"01 Ph" Number f-SM-660.61122 Fax Number: 1-9058775432 Contact Person, Twoma Hwngnft&MS SV54 AdenOon: Lola Counselor EFFECT OF FORECLOSURE LE - You should fealize that a foreclosure sale will end your ownership of the nditgaged property and your tight to renal) In ft. H you continua to We In the property altar the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by Com*ywide at any time. AS&IMPTIDN OF MORTGAGE _ Contact Comhywlde Home Lo m for Information on the possible assurrmabli ty of your lean. YO MAY ALSO HAVE THE RIGHT. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW Pursuant to your home ban documents, and because the home loan is In default Countrywide may, at b option, enter the me of the property. The purpose of this inspection Is to observe the physical condition of ills propand el u ctary Ithat nspection such Property le occupied andlor to determine the Identify of the occupant. The cost of any Inspection will be added to and become pert of the secured debt an provided under the term of the hone loan documents. If you are unable b cure your default on or before May IS, 2002, Countrywide wants you to be aware of various options that may be available to you through Country" to prevent a foreclosure solo of your property. For example: • Repayment Pam It Is possible that you may be eligible for some form of payment assistance thmugh Countrywide. Our basic plan requires that Countrywide reoelve, up front, at least ii of the amount necessary to bring the account curent, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period or time. Other repsyment plena also are avaiable. • Loan .. Mod& n: Alternatively, It Is possible that the regular monthly payments can be lowered through a modification of the ban by reducing the Interest rate and then adding the delinquent payments to the current ban balance. This foreclosure alternative, however, Is limited to certain ban types. • MIS, Your Propedr Alternatively, It you are wiling to sell your home in order to avoid foreclosure, It Is possible sale of your home can be approved through Countrywide even If your home Is worth less than whet Is owed on lt. • Deed-In-Liu: Alternatively, 9 your property Is free from other Ilona or encumbrances, and R the default is due to a serious financial hardship whbh Is beyond your control, you may be eligible to deed your property directly to the Notehoder and avoid the foreclosure sale. N you are Interested In discussing forecosure alternatives with Countrywide, you must Cooled us Immediately. If you request assistance, Countrywide will determine, in its sole discretion, whether Such assistance will be extended to you. In the meantime, Countrywide will pursue all of as rights and remedies under the home loan documents and as permitted by law, unless h agrees otherwise In writing. Please be advised that failure to bring the home loan current or to enter Into a written agreement a6 outlined above will result In 14 acceleration of the debt. Time Is of the essence. Should you have any questions concerning this notice, please contact Countrywde's office Immediately at 1.500.889-0102, extension 9011. ?mesa gMWV0I* Terms Hernandez Loan Counselor 1.800.889-0102, extension 9011 Please be advised met this Communication is from a debt collector. ?l C rv rn =ii r L T t :.J fT C) L?{ (i1 -n J.)l? T. v T ?T S1 n SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HAMMAKER AMBER C but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT HAMMAKER AMBER C ' PER KEVIN HOCKLEY, AMBER LIVES UP NORTH SOMEWHERE, NOT IN CUMBERLAND COUNTY. POST OFFICE SAYS HER MAIL IS STILL BEING DELIVERED TO THIS ADDRESS. Sheriff's Costs: So answe Docketing 18.00 Service 10.35 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 43.35 GOLDBECK MCCAFFERTY MCKEEVER 06/20/2002 Sworn and subscribed to before me this tyq? day of CL?-- 2(?L A.D. Pr t onotary ' SHERIFF'S RETURN - REGULAR CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HAMMAKER LESTER the DEFENDANT , at 1749:00 HOURS, on the 19th day of June , 2002 at 119 N ENOLA DRIVE #5 ENOLA, PA 17025 KEVIN HOCKLEY, ROOMMATE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this day of A. D. Prdthonotary So Answers: R. Thomas Kline 06/20/2002 GOLDBECK MCCAFFERTY MCKEEVER By: P eputy Sheriff GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D.#16132 SUITE 500 - THE BOURSE BLDG. 1 11 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY VS. AMBER C. HAMMAKER LESTER L. HAMMAKER 491 State Street West Fairview, PA 17025 Defendant(s) CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION : SYSTEMS INC. ACTING SOLELY AS : NOMINEE FOR THE BANK OF NEW YORK: AS TRUSTEE FOR CWABS 2000-2 C/O: COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagors and Real Owners) 491 State Street West Fairview, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-2897 Civil Term 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. MOTION FOR 1R. T T T D ERVT E UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, Michael T. McKeever, Esquire, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 491 State Street, West Fairview, PA 17025, hereinafter, the "mortgaged premises". 2. Defendants, AMBER C. HAMMAKER AND LESTER L. HAMMAKER, are the mortgagors and real owners of the mortgaged premises. 3. The last known address of Defendants' is 119 N. Enola Drive #5, Enola, PA 17025 as set forth in Paragraph 2 of the Complaint. 4. The Sheriff has been unable to effect service of the Complaint upon Defendants at their last known address after numerous attempts. 5. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendants. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendants by posting the premises and certified and regular mail to the Defendants' last known address. 7n BY: MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION : SYSTEMS INC. ACTING SOLELY AS : NOMINEE FOR THE BANK OF NEW YORK: AS TRUSTEE FOR CWABS 2000-2 C/0: COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagors and Real Owners) 491 State Street West Fairview, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-2897 Civil Term VERIFICATION It MICHAEL T. MCKEEVER, ESQUIRE, Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. BY: MICHAEL`!'. MCKEEVER, ESQUIRE GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION : SYSTEMS INC. ACTING SOLELY AS: NOMINEE FOR THE BANK OF NEW YORK: AS TRUSTEE FOR CWABS 2000-2 C/O: COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagors and Real Owners) 491 State Street West Fairview, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-2897 Civil Term MEMORANDUM OF AW IN qfTPPOP- FOR SUBSTITUTED SERVICE UNDER Pa,R.C.E.--43Q_Laj Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendants which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CON U ION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants by posting the premises and certified mail and regular mail to the Defendants' last known address. Respectfully submitted, MICHAEL T. MCKEEVER, ESQUIRE I- -- PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: CWD-1971 Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Case Number: Subject. AMBER C & LESTER L HAMMAKER A.K.A.: FESTER L HAMMAKER JR Property Address: WEST FAIRY EW PA 17025 Last Known Address: 119 N. ENOLA DRIVE 025 #5 ENOLA, P Last Known Number: ( ) - Michael K Gross, being duly sworn according to law, deposes and says: 1. 1 am employed in the capacity of President for Players National Locator. 2. On 0611712002, 1 conducted investigation into the whereabouts of the above named defendant(s). The results of my investigation are as CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER: - - B. EMPLOYMENT SEARCH: good employer for Amber or Lester. Unable to locate a C. INQUIRY OF CREDITORS: Creditors indicated th ft Amber and Lester are using 119 N Enola Drive, #5, Enola, PA 17025 with no valid home number. INQUIRY OF TELEPHONE COMPANY - A. DDIRECTORY irectory assistance had no i sting. INQUIRY OF NEIGHBORS - 9025 We contacted and Lester live at 119 N Enola Drive, Enola,IPA 17025S poke to a neighbor who 717-732-42 stated Amber INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: , 2 a Drive, National l CPA 9 702Address (NCOA) has no change for Amber and Lester As from of 119 June NE 11 MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Amber and Lester listed at 119 N Eno la Drive, #5, Enola, PA 17025. OTHER INQUIRIES al security Administration has no death records on file for Amber A. DEATH RECORDS: As of June 11, 2002 the Soci and Lester L Hammaker and/or a.k.a.'s under their social security numbers. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC. ): None C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office has Amber and Lester listed at 119 N Enola Drive, #5, Enola, PA 17025. OTHER SEARCHES - The social security numbers provided have been verified. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: Amber - February 1971 Lester-1969 AFFIANT Michael K Gross Players National Locator EKristine RY SEAL " cAtt, Notary Publ ic St. Louis o 'Expi es 9212002 113 Old State Road, Suite 104 St. Louis, MO 63021 Fax: (636) 230-0558 Phone: (636) 230-9922 SHERIFF'S RETURN - REGULAR CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HAMMAKER LESTER L the DEFENDANT , at 1749:00 HOURS, on the 19th day of June , 2002 at 119 N ENOLA DRIVE #5 ENOLA, PA 17025 KEVIN HOCKLEY, ROOMMATE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this day of A. D. So Answers : / R. Thomas Kline 06/20/2002 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy Sheriff Prothonotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HAMMAKER AMBER C unable to locate Her in his bailiwick COMPLAINT - MORT_FORE , but was He therefore returns the the within named DEFENDANT , HAMMAKER AMBER C NOT FOUND , as to PER KEVIN HOCKLEY, AMBER LIVES UP NORTH SOMEWHERE, NOT IN CUMBERLAND COUNTY. POST OFFICE SAYS HER MAIL IS STILL BEING DELIVERED TO THIS ADDRESS. Sheriff's Costs: So answers:" Docketing 18.00 Service 10.35! Not Found 5.00 R' Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 . 43.35 GOLDBECK MCCAFFERTY MCKEEVER 06/20/2002 Sworn and subscribed to before me this day of A. D. Prothonotary GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION IN THE COURT OF COMMON PLEAS SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK OF CUMBERLAND COUNTY AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 No. 02-2897 Civil Term Plano, TX 75024-3632 VS. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagors and Real Owners) 491 State Street West Fairview, PA 17025 CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER, Esquire, do hereby certify that true and correct copies of the the foregoing Motion for Substituted Service have been served upon the Defendants this Ah day of July, 2002, by first class mail, postage prepaid. BY: MICHAEL T. MCKEEVER, ESQUIRE C> 2 i _J_'J sO- JUL 2 9 2002 V GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION : IN THE COURT OF COMMON PLEAS SYSTEMS INC. ACTING SOLELY AS: NOMINEE FOR THE BANK OF NEW YORK: OF CUMBERLAND COUNTY AS TRUSTEE FOR CWABS 2000-2 C/0 : COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 No. 02-2897 Civil Term Plano, TX 75024-3632 VS. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagors and Real Owners) 491 State Street West Fairview, PA 17025 ORDER AND NOW, this 1fy day of 2002F upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants by posting a copy of the Complaint upon the premises 491 State Street, West Fairview, PA 17025, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last'kno itaddr`eSss at nola ? r Drive #5, Enola, PA 19025,-- vl % Gw.? tlk h cA A i?uv - S .P.At j H t?.1L papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premise/ y ?,;; 1"W J ,i 1 ?? SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HAMMAKER AMBER C but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT HAMMAKER AMBER C 491 STATE STREET IS VACANT. HER FORWARDING ADDRESS IS PO BOX 32 NEWPORT, PA 17074. Sheriff's Costs: So answer: Docketing S i 18.00 10 35 erv ce . Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland Coun ty .00 38.35 GOLDBECK MCCAFFERTY MCKEEVER 07/22/2002 Sworn and subscribed to before me this day of airo? A.D. Pr t onotary GOLDFECY WC AFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. III S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagor(s) and Real Owner(s) 491 State Street West Fairview, PA 17025 Defendant(s) r? I HEREBY CERTIFY THAT THIS 1S AOTRUE AND CORRECT F THE ORIGINAL FILED COPY OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. O'?- -V)00, ?7 l l u; CIVIL /ACTION: MORTGAGE FORECLOSURE C? c-> C7 f-s r1 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO CO? ECT 1' A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FRO$? S{OU_ `' WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBTr NOTICE You have been sued in coup. If you wish to defend against the claims set forth in die following pages, you most take action within twenty (20) days after die Complaint and notice are served, by entering a written appearance personally or by attorney aed 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 ajudgment maybe entered against you by the Court without further notice for any money claim in the Complaint offor any other claim or relief requested by the Plaintiff. You may lose money or property orother rights important to you. YOU SHOULD TAKE "I I LIS POPER 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlis!a, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A LISTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LISTED RESPONDA DENTRO Of, 20 DIAS DESPOTS DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA ('ORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE LISTED Y CUALQUIER OBIECCION CONTRA LAS QUE)AS EN ESTA DEMANDA. RECUERDE: SI LISPED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SO PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDI R A FA VOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE LISTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A LIN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A I IN AROGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION TRUE COPY FROM RECORD Carlisle, PA 17013 haM se my toreof,, I two o unto k wny w MTa e LEGAL SERVICES INC y ? ?{ ? y WA tt s*of said Court at Cul". Pa.. B Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE ?. , Ail Y Arf URE - copy 1. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEM64M6y,4@G1R fly ffi9utffl31S NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOIE(AW AW(JC41UGCT COPY COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX A) 33 ORWP0-56P632. 2. The name(s) and address(es) of the Defendant(s) is/are AMBER C. HAMMAKER, 119 N. Enola Drive 95, Enola, PA 17025 and LESTER L. HAMMAKER, 119 N. Enola Drive #5, Enola, PA 17025, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On April 07, 2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1607 Page 739. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 3. The premises subject to said mortgage is described as attached. 4. The mortgage is in default because monthly payment of principal and interest upon said mortgage due March 01, 2002, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 5. The following amounts are due on the mortgage: Principal Balance Interest from 02/01/2002 through 06/30/2002 at 9.6250% Per Diem interest rate at $13.61 Attorney's Fee at 5.0% of Principal Balance Late Charges from 03/01/2002 to 06/30/2002 Monthly late charge amount at $22.18 Costs of suit and Title Search Escrow Monthly Escrow amount $35.22 $51,630.62 $2,041.49 $2,581.53 $88.71 $750.00 $0.00 6. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff s Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) 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 "A". The Defendant(s) has/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(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $57,092.35, together with interest at the rate of $13.61, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: k A/ GOLDBECI 1 cC FFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR•, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Michael Vestal, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Date: &jA-vim Michael Vestal Countrywide Home Loans Leal Description ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE EAST PENNSBORO TWP, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS. TO WIT BEGINNING AT A POINT ON THE NORTH SIDE OF THE STATE ROAD WHICH POINT IS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET (ERRONEOUSLY REFERRED TO IN PRIOR DEED AS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (2555) FEET) WEST OF THE CORNER OF LANDS NOW OR LATE OF JOSEPH L BEST. THENCE NORTHEASTW ARDLY ALONG LANDS OF WILLIAM M WORLEY TWENTY-FIVE AND EIGHT-TENTHS (258) FEET TO A POINT IN THE CENTER OF THE PARTITION WALL BETWEEN THE HOUSE HEREIN CONVEYED AND THE ADJOINING HOUSE, THENCE CONTINUING THROUGH THE CENTER OF THE PARTITION WALL IN SLIGHTLY MORE EASTWARDLY DIRECTION FORTY-EIGHT (48) FEET TO AN IRON PIN AT THE END OF SAID PARTITION WALL, THENCE IN A MORE NORHWARDLY DIRECTION ONE HUNDRED FOUR AND FOUR TENTHS (104 4) FEET TO AN IRON PIN AT THE SOUTHERN SIDE OF A FOURTEEN (14) FEET WIDE ALLEY, WHICH IRON PIN IS TWENTY-SIX AND TWO TENTHS (262) FEET WEST OF LANDS NOW OR LATE OF JOSEPH L BEST, THENCE BY SAID ALLEY SOUTH SIXTY-TWO (62) DEGREES EAST TWENTY-SIX AND TWO TENTHS (262) FEET TO AN IRON PIN AT CORNER OF LOT NOW OR LATE OF JOSEPH L BEST, THENCE BY THE SAME SOUTH FIFTY-ONE (51 DEGREES FORTY-FIVE (45) MINUTES WEST EIGHTY _NM_ AND FIVE-TENTHS (89 5) FEET TO AN IRON PIN, THENCE BY THE SAME SOUTH FORTY-FIVE (45) DEGREES FORTY- FIVE (45) MINUTES WEST NINETY-ONE (91) FEET TO AN IRON PIN ON THE NORTH SIDE OF SAID STATE ROAD, THENCE ACROSS SAID STATE ROAD BY LAND NOW OR LATE OF SAID JOSEPH L BEST SOUTH FIFTY- FOUR (54) DEGREES FORTY-FIVE (45) MINUTES WEST TWO HUNDRED FORTY-SEVEN (247) FEET TO A STAKE ON THE BANK OF THE CONODOGUINET CREEK. THENCE UP SAID CREEK EASTWARDLY BY THE BANK THEREOF TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET TO A POINT AT THE OTHER LAND NOW OR LATE OF HAROL EMIL MALSH. ET UX, THENCE BY THE SAME ACROSS SAID LOT NORTH FIFTY. FOUR (54) DEGREES FORTY-FIVE (45) MINUTES EAST TWO HUNDRED FORTY-SEVEN (247) FEET TO A POINT, THE PLACE OF BEGINNING THERE BEING ERECTED THEREON THE EASTERN HALF OF A DOUBLE TWO STORY FRAME DWELLING, NO 491 STATE ROAD Countrywide- NOME LOANS Send correspondence to: PC sox 8239 Van Nuys, CA 914091B2d9 April 18, 2002 f ?ul A Lester L HammakerEoZH 491 State Sheet West Fairview, PA 17025.0000 Send Payments Im P.O. Box 88067 Vedas, TX 75269-0694 Cerlifled Mall No. Return Receipt Requested Regular Mall Account No.: 2418187 Property Address: 491 State Street West Fairview, PA 17025-0000 Current Servicer. Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official nallcg thst the mortaaoe on your home is In QetauI, and the lentler Intends to loreeloae SnecUlc Information about the rtatere of the default is oroVided In the attac ftg pages The HOMEOWNER'SEMERGENCYMORTCA FASSISTAN l Mae be tit to help to MVe S PROGRAM HEMAOt your home. Thhr Notice explain how the omaram war To see 8 HEMAP can halo you must MEET eT CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take thlill totlce with Moll when you meet with the Counseling Aaen s This Notice contains Important legal Information. it you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney In your area. The local bar sesoclation may be able to help you find a lawyer. LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OSTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCKJNADO ARRIBA PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA OE IA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL AcoreTANC WHICH CAN SA YOUR HOME FROM FORECLO¢t RE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. ti Please unite youraabunt numhar on all checks and rorrespondsrxa. L.WILH..Aor 2419187-6 tsl sme alr r A W *%WWi mmgrywe,a..g,ea.stia,nepryrrmvpaaww.¢,a,agw. ace9PA lvca? NOME LOANS P.O. Bolt 880884 Dallas, TX 76266-0694 II.rrLI,Ir r,I,LIInrIIrrlLrr,IInltlu rlrrlLlr,.ILrlr.ld I BCBRPA WM2000 $1,388.56 AS OF May 18, 2002 241918760001388560138856 Countrywide- HOMELOANS Sand Covespondame to: P.O. BOX 8239 Van Mys, CA 91409-6=9 April 18, 2002 Lester L Hammaker 119 N Enola Dr 5 Enola, PA 17025-2521 Send Payments to: P.O. BOX 660694 Dallas, TX 75266,004 CeAffled Mall No. Return Receipt Requested Regular Mail Account No.: 2419187 Property Address: 491 State Street West Fairview, PA 17025-0000 Current Servicer. Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortgage on Your home Is In default, and the tender Intends to foreclose Spaelflc information about the nature of the default is orovkled In the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice exolains how the program works. To see N 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 ounselina Agencw This Notice contains Important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney in your area. The local bar association may be abls to help you find a lawyer. LA NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONITINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENWO DE ESTA NOTIFe=6N OBTENGA UNA TRADUCCIGN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIB/L PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PEROIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. Please wale your accoum number 0 all cmdm and correspondence. BC8RPA Br2612000 I rrtxlflenunaker 2419187-6 401 SIM-beet Alwyba6WIN0.WbnlKbebplbanbrewrw?."w..aw...bwyb,. $1,388.56 AS OF May 18, 2002 aCerPA ®tounbMder noes LOANS P.O. Bm 660894 Dallas, TX 75266-0694 Ii.1,I,lrls„11lrllr, rlinlllrl rllnltlrul ollrl,r rlnl i,ltll 241918760001388560138856 ®Countrywides HOME LOANS Send CorlaspondaMo to. P.O. BOX am9 Van Nuys, CA 91409-8239 April 18, 2002 Amber C Hammaker 491 State Street West Fairview, PA 17025-0000 Send Payments to: P.O. BOX660694 Dallas. TX 752860694 Certifled Mail No. Return Receipt Requested Regular Mail Account No.: 2419187 Property Address: 491 State Street West Fairview, PA 17025-0000 Current Servicer. Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official n otice that the mortga ge on yo ur home Is In default, and the lender Intends to fore close SPecillc IntormaGo n about th e nature of the default Is orovided In the attached Pages The HOMEOMMER'S EM): HCEN CY WORT C r AS SISTANCE PROGRAM (NEMAP) may be able t hel p to save your home. This Notice explains how the program works To see if HEMAP ca n help yo u must ME ET WITH A CONSUMER CREDIT COUNSELING AGENCY WIT HIN 30 DAYS OF THE DATE OF THIS N OTICE Ta ke tills N otice with you when vol meet with the Counseling Agency This Notice contains important legal Irlfomretiom If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTINCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFlCAC16N OSTENGA UNA TRADUCCION INMEDUTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NIlMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRltS7AM0 FOR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACrj, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. PlaesewdN youraccount nunteron all d*GM and CONSWonder ce. 6CBRPA 60281200) AmnxG Hvgneker 2 41 91 87-6 ael5We gnat A avnbsmarnmeNre.a.prn,..a,r..ew+++?srr.e..«s.ore+ww. 9CBWA 1 HOHe LOANS P.O. Box 660894 Dallas, TX 75266.0694 IImhI,Lg6LII,,,11H11,NdIN! Jg,l„IIJ r rdrd„Idl $1,388.56 AS OF May 18, 2002 241918760001388560138856 Countrywide- HOMELOANS Send COnespgndance NO: P.O. Box am Van Nuys, CA 914948,99 April 16, 20M Amber C Hammaker 119 N Enola Dr 5 Enola, PA 17025-2521 Send Paymams M: P. O. Box 980694 Dallas, TX 752660894 Certified Mall No. Return Receipt Requested Regular Mall Account No.: 2419167 Property Address: 491 State Street West Fairview, PA 17025-00011 Current Servicer. Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortgage on Your home Is In default and the lender intends to foreclose Specific Ildormedon about the nature gift n9o,ro is omylded In the attached pages, - The HOMEOWNERS EMERGENCY MORTGAGE AS$ISTANC PROGRAM IHEMAPI may be able to het to save Your home. This Notice explains how the program r To see H HEMAP can held 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, This Notice comams Important legal information. 9 you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to =meet an attorney in your area. The local bar association may be able to help you fund a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTtNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PREBTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PEROIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINAUnet ASSISTANCE WHICH CAN HELP YOU MAKE FUTURE AN SAVE YOUR HOME FROM FORECLOSURE _ -_ Iul_ORTQersE peyaecNTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1903 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTB, AND IF YOU MEET OTHER ELIGIBt4TY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. Please wdle ycurecwurd OUnEer on all checks and correspondence. BQ8RPA 62512000 AmberC Hxgnek4r 2419167-8 4s, SOte strew A N.,proraal4Kap'w mw ee4?y,tl MM,NM prfm?,4,pt u.SrM. sMMMtn aCMRA Cawftwide HOMELOANS P.O. BOX 660694 Dallas, TX 75266-0694 $1,986.56 AS OF May 18.2002 241918760001388560138856 :MPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your 34gage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a'Yace-to-face' eating with one of the consumer credit counseling agencies listed at the end of this Notice. THIS. MEETING MUST CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the and of this notice, the lender may NOT take action against you for thirty (30) days after the date of this one APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is In default for the reasons set forth later in this Notice (sea 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 Homeowners emergency Mortgage Assistance Program. To do so, you must fill out, sign and life a completed Homeowners 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 VIII 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-10-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited They will be disbursed by the Agency under the eligibility criteria esfab8shed by the Act The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Fmance Agency of Its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT - Countrvwlde Home Loans Servicing LP. (hereinafter `Countrvwitle'I services your home loan. Your home loan Is In serious default because you have not made your required payments. The total amount now required to reinstate your home ban as of the date of this letter is as follows: MonthNPayments: $478.91 $1,436.73 Late Chances: $22.18 $66.54 O igrChames: Uncollected Late Charges: $78.94 Uncollected Costs: $193.85 TOTAL DUE: $1,388.56 PAYMENT INSTRUCTIONS Please MakeYOmded( PayaWe m Ceua4wYm Horne LO DM1alamyourd"tDtI1epefvnerlcgpm weteyo WwriumberanyouraAa&ammeyader DOMIndgMenarnespmdence Wdtem aryadd5lonaamoumsyau are lncludyg. (II Donlmodceeh tote)sragemen$50W,pk=BWMcel Wcheck) Payments: Mpayrlmnmwtf be apgedto IM1ebngesl ouhtmdnp Insammm due, ude?gimmkes¢rimay pmhmhedby gw A4d111atnl emamm. 11 yun 4m1 rpedly the pgpmo of additoW amuns WAK wa wY apply Item Na to my atWmdRg paym0ng, BSEmW dNcNntle4lBlaglni?afi0dmm6a tla& WawYmmaA anj fw aNo9 amount as a plMpm mdudaa It yeu mma m wddlkwl pampa paymnt with your hmm man payment, Cgmhyoft w1fM apply your Imma bat paynmrd, tlmn emaddtbnapmdpalpaywnt YourmmmuatbemwmtbemmwacmapplyaNprlncOl"dlon. HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS of the data of this letter, by paying to us the above amount of $1,366.56, plus any etltlffional monthly payments, late charges, fees and other applicable charges which may fall We during this period. Such payment must be in the form of certified check, cashler's check or money order, and made payable to Countywide at P.O. Box 660694, Dallas, TX 75266-0694. it your check or other payment is returned to us for Insult Want funds orfor any other reason, you will not have cured your default No extension of time to cure will be granted due to a returned payment. IF THE MORTGAGE IS FORECLOSED UPON - If the mortgage is foreclosedk the mortgaged property will be sold by the Sheaf to pay of the Mortgage debt If the default is cured before we begin legal proceedings, Countrywide will be entitled to collect the reasonable attorneys fees actually Incurred, up to $60.00. However, If legal proceedings are started, Countrywide will be entitled to collect the reasonable attorneys fees even If they are over $50.00. Any attorneys tees wig be added to the secured del, which may also Include our reasonable costs. 6 you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorneys fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO FORECLORIRE SALE - It you have rot cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the foreclosure sale. You may do so by paying the total amount then past due, plus any late or other charges than due, reasonable attorneys fees and costs connected with the foreclosure sale and any other costs connected with the foreclosure sale as specified In writing by the lender and by performing any other requirements under the mortgage. Curing your default In the manner set forth In this notice will restore your mortgage to the same position as lt you had never defaulted. EARLIEST POSSIBLE FORECLOSURE SALE DATE - It is estimated that the earliest data that a foreclosure sale could be held would be approximatey six (6) Months from the date of this letter. A notice of the date Of the foreclosure sale will be sent to you before the sale. You may find out at any time exactly what the required payment will be by calling us at the following number. 1-600-669-0102. This payment must be in the form of a cashiers check certified check or money order and made payable to us at the address stated above. If the default is cured, the mortgage will be restored to the same position as If no default had occurred. However, the default may not be cured more than three (3) times in any calendar year. HOW_ TO CONTACT THE LEND Name of Lender. Countrywide Nome Loans Servicing LP Address: P. O. Box 10221 Van Nuys, CA 91410-0221 Phone Number: 1.606669-0102 Fax Number: 1405.5774432 Contact Person: Teresa NemandM MS SV-34 Affeaflon: Loan Counselor EFFECT OF FORECLOSURE SALE - You should realize that a foreclosure sale will end your ownership of the mortgaged property and your right to remain in it. lt you cominue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and Omer belongings could be started by Countrywide at any time. ASSUMPTION OF MORTGAGE-Contact Countrywide Home Loans for Information on the possible assumabilly, ot your Ican. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Pursuant to your home ban documents, and because the home loan is In default, Countrywide may, at its option, enter upon and conduct an inspection of the property. The purpose of this Inspection Is to observe the physical condition of the property, to verity that the property Is occupied and/or to determine the Identity of the occupant. The cost of any such Inspection will be added to and become part of the secured debt as provided under the terms of the home loan documents. If you are unable to cure your default on or before May 18, 2002, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It Is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least S4 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modfi catton: Alternatively, it Is possible that the regular monthly payments can be lowered through a modification of the ban by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, Is thrilled to certain ban types. • Salad your Pmoerty Allerna", If you are wl6ing to sell your tome In order to avoid foreclosure, it Is possible that the sale of your home can be approved through Countrywide even If your home Is worth less than what is owed on it, • Deed-In-Lieu: Alternatively, 9 your property is free from other liens or encumbrances, and If the default Is due to a serious financial hardship which Is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are Interested In discussing foreclosure alternatives with Countrywide, you must contact us Immediately. It you request assistance, Countrywide will determine, in its sole dlscratlon, whether such assistance will be extended to you. In the meantime, Countrywide will pursue all of as rights and remedies under the home loan documents and as permitted by law, unless It agrees otherwise In writing. Please be advised that failure to bring the home loan current or to enter into a writen agreement as outlined above will result In the acceleration of the debt Time is of the essence. Should you have any questions concerning this notice, please contact Countrywde's of lee Immediately at 1-800-689-01 OZ extension 9011. 7PJL a gPJC"wi f7 Teresa Hernandez Loan Counselor 1.800.669-0102, extension 9011 Please be advised that this communication is from a debt collector. n i r- - u c:? GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D.#16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM VS. AMBER C. HAMMAKER LESTER L. HAMMAKER 491 State Street West Fairview, PA 17025 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER -?P99 - By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff 0 C, C vo - f I t,".:- t9 i ' GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. AMBER C. HAMMAKER and LESTER L. HAMMAKER Mortgagor(s) 491 State Street West Fairview, PA 17025 Defendant(s) CERTIFICATE OF SERVICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on ghJLoJ he did serve upon Defendant(s) AMBER C. HAMMAKER and LESTER L. HAMMAKER a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated AUGUST 1, 2002 . The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, GOLDB 7_DBECK, McKEEVER B : JO EPH JR. ESQUIRE C-n N ?i?I f?f"T 1-0 N ON 3 zC ",3 i (5 iv Orfi 40 SHERIFF'S RETURN - REGULAR CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HAMMAKER AMBER C the DEFENDANT , at 1910:00 HOURS, on the 19th day of August 2002 at 491 STATE STREET WEST FAIRVIEW, PA 17025 by handing to POSTED PROPERTY AT 491 STATE STREET WEST FAIRVIEW, PA a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Posting 6.00 Surcharge 10.00 .00 44.35 Sworn and Subscribed to before me this as day of Cat 200Z A.D. ?u9 C ? po P-rothnotary K So Answers: R. Thomas Kline 08/20/2002 GOLDBECK MCC ERTY MCKEEVER By: Dep Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HAMMAKER LESTER L the DEFENDANT , at 1910:00 HOURS, on the 19th day of August , 2002 at 491 STATE STREET WEST FAIRVIEW, PA 17025 by handing to POSTED PROPERTY AT 491 STATE STREET WEST FAIRVIEW PA 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 6.00 Service .00 Posting 6.00 Surcharge 10.00 .00 22.00 Sworn and Subscribed to before me this dan day of t ?a? J 0 ao -1-? /A . D . 10004 / ' r thonotary So Answers vY R. Thomas Kline 08/20/2002 GOLDBECK aDepu RTY MC EEVER By: Sheriff In the Court of Common Pleas of Cumberland County MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME, LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagor(s) and Record Owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) PRAECIPE FOR JUDGMENT No. 02-2897 CIVIL TERM 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 AMBER C. HAMMAKER and LESTER L. HAMMAKER by default for want of an Answer. Assess damages as follows: Debt Interest- 02/01/2002 to 09/23/2002 Total (Assessment of Damages attached) $58,421.40 1 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 at 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 Joseph A. Gold c Jr.. Attorney for Pla tff f I I.D. #16132 AND NOW nQ2 ??/yam 1 . , Judgment is entered in favor of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. and against AMBER C. HAMMAKER and LESTER L. HAMMAKER by default for want of an Answer and damages assessed in tt}? sum of $58,421.40 as per the above certification. ; _ ) I 0 C) C r? ?l C ; O r r c •-' T-^ __ .-iii r C-. 1, VJ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagor(s) and Record owner(s)) 491 State Street West Fairview, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff No. 02-2897 CIVIL TERM Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., and against AMBER C. HAMMAKER and LESTER L. HAMMAKER 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 $58,421.40. l Clh , Joseph A. G 1 bec c, Attorney for laintif I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 and that the name(s) and last known address(es) of the Defendant(s) is/are AMBER C. HAMMAKER, 119 N. Enola Drive #5 Enola, PA 19025 and LESTER L. HAMMAKER, 119 N. Enola Drive #5 Enola, PA 19025; _ GOLDBECKAIRTY & McKEEVER BY: Joseph A JG l db c Jr. Attorney for ' tiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $51,630.62 Interest from 02/01/2002 through $3,198.34 09/23/2002 Attorney's Fee at 5.0000% of principal $2,581.53 balance Late Charges Costs of Suit and Title Search Escrow Balance Deficit $155.25 $750.00 $105.66 ($0.00) $58,421.40 BY: Joseph oldbedl?, Jr. Attorney for mtiff WW & McKEEVER AND NOW, this / S + day of C) C46&A, 2002 damages are assessed as above. Pro Prothy o n z o _. m rr --r = - a ko < 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: September 12, 2002 TO: LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDF. HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAM MAKER (Mortgagor(s) and Record Owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) TO: LESTER L. IIANIMAKER 119 N. Enoki Di ivc p5 Enola, PA 19025 IMPORTANT NOTICE In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM 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'[ O'FIF 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, (i0 TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: (hllu C AND COUNTY BAR ASSOCIATION c„L 5?`ra t,Bi ?lo 1 cLIOACIS INC s19??}h li?????oo GO C ScCAFFERI EEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 P m n N -r "L i 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: September 12, 2002 TO AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano. TX 75024-3632 Plaintiff v5. AMBER C. HAM MAKER LESTER L. HAMMAKER (Mortgagor(s) and Record Owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) TO. AMBER C. IIAMMAKER 119 N. Enoln Drive#5 Enola, PA 19025 IMPORTANT NOTICE In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM 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 NO'T'ICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET' LEGAL HELP: k VI B I In ANDOR NI'v BARASSO(IM ION c}i +I 'II .t R%111(i LS IN(' GO C ICCAFFER EEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I 1 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ??. ? "i ;-:i ? mn? -a ? ,?r > ,?i'? `w - r- , „ ; ? ?.?-' ? ;;; :: ,` ` ; - ? ? ,fl -< 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: September 12, 2002 TO LESTER L. HAMMAKER 491 State Street West Fairview, PA 17025 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff %S. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagor(s) and "Record Owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) TO: LESTER L. HAMMAKER 491 State Street West Fairview, PA 17025 IMPORTANT NOTICE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM YOU ARF 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 DA11 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 NOTICE, TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: ('1 i1?1``m NIV\I.``A((Nre)000NTN BARASSOCIATION ,(IAI. SILIRV IIN( t{?ui?yi`I liauisa u GO.r C IcCAFFER EEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-132 n CD ? C. N ^7 fT -v -? m r r ? -G 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: September 12, 2002 TO: AMBER C. HAMMAKER 491 State Street West Fait vie%%. 1'A 17025 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE I IOME LOANS INC. 7105 Corporate ])I ivc PTX I3-35 Plano. TX 75024-3632 PlaintW' S. AMBER C. HAMMAKER LESTER L. IAMMAKER (Mortgagor(s) and Record Owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) TO: AMBER C. HAMMAKER 491 State Street Weet Fairview. PA 17025 IMPORTANT NOTICE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM 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 DATF 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GEI' LEGAL HHT: ( ',A1W RI ANDMUNI V ItAHASSOC IA PION I, It s 1). SI M1( INC GO. C ICCAFFER cCAFFER1'7-*-I1jKE EVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I I S. Independence Mall Fast Philadelphia,PA 19106 215-027-132 T f"?j M1 ?o < 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: September 12, 2002 TO: LESTER L. HAMMAKER PO Box '12 Newport, PA 17074 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAM MAKER (Mortgagor(s) and Record Owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) TO. LESTER L. HAMMAKER PO Box 32 Newport, PA 17074 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM 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 TI IE 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 T11S NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO I'O OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: '?i IIIIH ANU COUN'Ily TAR ASSOCIATION rail? l if ? \ LI; G20' 1-. IN( 11 ,71111 GO, $ C IcCAFFER EEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500-The Bourse Bldg. I I I S. Independence Mall East r7 (? --? ?j ?. t ?J te. ?°I. r l l 1 ? i?t ) y ` - "? 2 rU 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: September 12, 2002 TO: AMBER C. HAMMAKER PO Box 32 Newport, PA 17074 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagor(s) and Record Owner(s)) 491 State Street West Fairview. PA 17025 Defendant(s) TO: AMBER C. IAMMAKER PO Box 32 Newport, PA 17074 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: {I p)111FR}.AND COUNTY BAR ASSOCIASION r",b16-vA'1AN ?. tyVI, ?M RVI('I: INC j, as ?A ),7ii+ ? 41 GO C 1eCAFFER EEVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I I S. Independence Mall East n o n C ev Y' -r l !' aJ --G ?O -G Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff No. 02-2897 CIVIL TERM vs. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagors and Record Owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 63 7? ?. c liq 0 a C7 C7 n r7 i JUL 2 9 200[ GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION : SYSTEMS INC. ACTING SOLELY AS: NOMINEE FOR THE BANK OF NEW YORK: AS TRUSTEE FOR CWABS 2000-2 C/0 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagors and Real Owners) 491 State Street West Fairview, PA 17025 TTORN COPY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-2897 Civil Term ORDER J AND NOW, this ?? day of ^ l t?.L?I.??T' 2002, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants by posting a copy of the Complaint upon the premises 491 State Street, West Fairview, PA 17025, and Plaintiff is directed to serve the Complaint by ; rtified and regular mail to the Defendants' last k?nAo?n address at 119 N. Enola Drive #5, Enola, PA 190/125, (?p-,,,?'.%ww'? E+rtcL- ..l:+w if.Pal• 1..c4.r.-..Q.?e.-L?ct?..d. ?- ?n.c...QJ, ?-.•?? papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE COURT: i?/ry? . a3. 130,,,x., J-. ? GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D.#16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. AMBER C. HAMMAKER and LESTER L. HAMMAKER Mortgagor(s) 491 State Street West Fairview , PA 17025 Defendant(s) CERTIFICATE OF SERVICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-2897 CIVIL TERM JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on gl jod he did serve upon Defendant(s) AMBER C. HAMMAKER and LESTER L. HAMMAKER a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated AUGUST 1, 2002 . The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, GOLDB E 8c McKEEVER B : JOSEPH DBECK, JR. ESQUIRE PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication August 21, 2002 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. August 21, 2002 Sworn to and subscribed before me this 21 st day of August , 2002. Notary Public My commission expires: ?.,. ie r...`.. JOSEPHA GO Notary Public FQH SHIPLEY U. DUHIVIIJ, ATTORNeEY GOLDBECK Carfis)G Boro., Cumberland Caunry suite saB,ttw A Commission Ex 'res Au . 9, 2003 ills. Philad i ; PA 4ba'fills iaclu8n work and accel. 215-827-1322 M who is protesciaml, has good PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication IN THE'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 02-2897 Civil Term August 21, 2002 NOTICE OF ACTION IN MORTGAGE FORECLOSURE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 / C ieposes that he is not interested in c o OUNTRYWIDE HOME LOANS, INC, PLAINTIFF vs. AMBER C. HAMMAKER AND LESTER L. HAMMAKER, MORTGAGORS AND REAL OWNERS E tter of the af d t D FENDANTS oresai no ice or TO: AMBER C. HAMMAKER AND LESTER L. HAMMAKER, Mortgagors and Real and that all allegations in the Owners, Defendants, whose last known addresses are 4g1 State Street West Fair. , view, PA 17025 and 119 N. Enola Drive #5, Enola, PA 19025 'ment as to time, place and character THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED To OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU ire true. WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. You are hereby notified that Plaintiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., ACTING SOLELY AS NOMINEE FORTHE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 c/o COUNTRYWIDE HOME LOANS INC., has filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to NO. 02-2897 Civil Term wherein Plaintiff k , see s to foreclose on the mortgage secured on your property located, 491 State Street, West Fairview, PA 17025, whereupon your property would besold by the Sheriff of Cum- August 21 2002 berland County. , NOTICE YOU ttAVf BEEN SUED-"4-C URTT: ffroe-wisk4o defend against the claims set forth in the notice above, you must take action within twenty (20) days after this 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 for against you. You are warned that if you fail to do so the case ma roceed 21 st ubscribed before me this y p without you and a judgement may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief AU ust g , 2002, 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, 00 TO OR TELEPHONE THE OFFE SE FOR H BELOW TO FI D OUT WH RE YOU CAN GET LEGAL HE P Notary Public . CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 1 expires: LEGAL SERVICES INC. 8 Irvine Row Carlisle, PA 17013 717-243-9400 JOSEPH A. GOLDBECK JR. , ATTORNEY FOR PLAINTIFF GOLDBECK McCAFFERTY & McKEEVER P C , . Y Pd, Notary Puuiic , . . Suite 500, The Bourse Building berlafld Couilty 111 S. Independence Mall East rP,S AU 9 2 3 Philadelphia, PA 19106 . , ?-??-1 215-627-1322 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, 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, AUGUST 23, 2002 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 Rog & M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 23 day of AUGUST 2002 L06 E. SNYDER, Notary N* Wiwi moo, cumwaw CW* v C&Tx* alon Exoirea March 5.2005 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action Law No. 02-2597 Civil Term MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 c/o COUNTRYWIDE HOME LOANS INC.. PLAINTIFF VS. AMBER C. HAMMAKER AND LESTER L. HAMMAKER, MORTGAGORS AND REAL OWNERS, DEFENDANTS NOTICE OF ACTION IN MORTGAGE FORECLOSURE TO: AMBER C. HAMMAKER AND LESTER L. HAMMAKER, Mort- gagors and Real Owners. Defen- dants, whose last known ad- dresses are 491 State Street, West Fairview, PA 17025 and 119 N. Enola Drive #5, Enola. PA 19025 THIS FIRM IS A DEBT COLLEC- TOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OB- TAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECT- ING THE DEBT. You are hereby notified that Plain- tiff. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 c/o COUNTRYWIDE HOME LOANS INC., has filed a Mortgage Foreclo- sure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of Cumber- land County, Pennsylvania, docket- ed to NO. 02-2597 Civil Term, where- in Plaintiff seeks to foreclose on the mortgage secured on your property located. 491 State Street, West Fairview. PA 17025, whereupon your property would be sold by the Sheriff of Cumberland County. NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the notice above, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your de- fenses or objections to the claims set for 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 claimed in the Complaint or for any other claim or relief re- quested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PA- PER 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 CUMBERLAND LAW JOURNAL LEGAL SERVICES INC. S Irvine Row Carlisle. PA 17013 (717) 243-9400 JOSEPH A. GOLDBECK. JR., ESQUIRE GOLDBECK McCAFFERTY & MCKEEVER. P.C. Attorneys for Plaintiff Suite 500 The Bourse Building 111 S. Independence Mall East Philadelphia. PA 19106 (215) 627-1322 Aug. 23 SHERIFF'S RETURN - REGULAR CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HAMMAKER AMBER C the DEFENDANT , at 1910:00 HOURS, on the 19th day of August , 2002 at 491 STATE STREET WEST FAIRVIEW, PA 17025 by handing to POSTED PROPERTY AT 491 STATE STREET WEST FAIRVIEW, PA a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Posting 6.00 Surcharge 10.00 .00 44.35 Sworn and Subscribed to before me this day of A. D. So Answers: r R. Thomas Kline 08/20/2002 GOLDBECK MCC ERTY MCKEEVER By: Dep t Sheriff Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2002-02897 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HAMMAKER AMBER C ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HAMMAKER LESTER L the DEFENDANT , at 1910:00 HOURS, on the 19th day of August , 2002 at 491 STATE STREET WEST FAIRVIEW, PA 17025 by handing to POSTED PROPERTY AT 491 STATE STREET WEST FAIRVIEW, PA 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 6.00 Service .00 Posting 6.00 Surcharge 10.00 .00 22.00 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 08/20/2002 GOLDBECK MCCA FERTY MC EVER By: Depu Sheriff Prothonotary PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 G'O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drivc PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. AMBER C. HAMMAKER No. 02-2897 CIVIL TERM LESTER L. HAMMAKER Mortgagor(s) and Record Owner(s) 491 State Street West Fairview, PA 17025 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 02/01/2002 to 09/23/2002 at 9.6250% (Costs to be added) $58,421.40 BY: Joseph 4.rGoldbecr, Jr. Attorney for Maintiff & McKEEVER r K n vi w c o o?c???c cr?o ?` W 1 D 70 o -' c_ -? Cp d W 41 ?O w? a? U F ? Q Na NO o-'7' o ? z? x F Wzo ?xo ?wo `i'xoU HQ¢v' wiz U v?iZFGO O Q ?zwo ?aF3 W p¢c4 w? h ? O F¢w OUw ?zo z O N ?Wapp ? a ' 3 WUW 'x 0 w o „ iC W d b ;g a; W F y CID G7 w ? U N b C7 d d 7 h ?> v i4 ? N Ya O V ¢ .M. s. C7 ? P. W ? b tC ? ? g S A N C7 --- ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE EAST PENNSBORO TWP, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT' BEGINNING AT A POINT ON THE NORTH SIDE OF THE STATE ROAD WHICH POINT IS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET (ERRONEOUSLY REFERRED TO IN PRIOR DEED AS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (2555) FEET) WEST OF THE CORNER OF LANDS NOW OR LATE OF JOSEPH L BEST. THENCE NORTHEASTWARDLY ALONG LANDS OF WILLIAM M WORLEY TWENTY-FIVE AND EIGHT-TENTHS (258) FEET TO A POINT IN THE CENTER OF THE PARTITION WALL BETWEEN THE HOUSE HEREIN CONVEYED AND THE ADJOINING HOUSE, THENCE CONTINUING THROUGH THE CENTER OF THE PARTITION WALL IN SLIGHTLY MORE EASTWARDLY DIRECTION FORTY-EIGHT (48) FEET TO AN IRON PIN AT THE END OF SAID PARTITION WALL, THENCE IN A MORE NORHWARDLY DIRECTION ONE HUNDRED FOUR AND FOUR TENTHS (104 4) FEET TO AN IRON PIN AT THE SOUTHERN SIDE OF A FOURTEEN (14) FEET WIDE ALLEY, WHICH IRON PIN IS TWENTY"-SIX AND TWO TENTHS (262) FEET WEST OF LANDS NOW OR LATE OF JOSEPH L BEST, THENCE BY SAID ALLEY SOUTH SIXTY-TWO (62) DEGREES EAST TWENTY-SIX AND TWO TENTHS (261) FEET TO AN IRON PIN AT CORNER OF LOT NOW OR LATE OF JOSEPH L BEST, THENCE BY THE SAME SOUTH FIFTY-ONE (51 DEGREES FORTY-FIVE (45) MINUTES WEST EIGHTY-NINE AND FIVE-TENTHS (89 5) FEET TO AN IRON PIN, THENCE BY THE SAME SOUTH FORTY-FNE (45) DEGREES FORTY- FIVE (45) MINUTES WEST NINETY-ONE (91) FEET TO AN IRON PIN ON THE NORTH SIDE OF SAID STATE ROAD, THENCE ACROSS SAID STATE ROAD BY LAND NOW OR LATE OF SAID JOSEPH L BEST SOUTH FIFTY- FOUR (54) DEGREES FORTY-FIVE (45) MINUTES WEST TWO HUNDRED FORTY-SEVEN (247) FEET TO A STAKE ON THE BANK OF THE CONODOGUTNET CREEK. THENCE UP SAID CREEK EASTWARDLY BY THE BANK THEREOF TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET TO A POINT AT THE OTHER LAND NOW OR LATE OF HAROL EMIL MALSH. ET UX, THENCE BY THE SAME ACROSS SAID LOT NORTH FIFTY- FOUR (54) DEGREES FORTY-FIVE (45) MINUTES EAST TWO HUNDRED FORTY-SEVEN (247) FEET TO A POINT, THE PLACE OF BEGINNING THERE BEING ERECTED THEREON THE EASTERN HALF OF A DOUBLE TWO STORY FRAME DWELLING, NO 491 STATE ROAD TAX PARCEL # 45-16-1050-028 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2897 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC Plaintiff (s) From AMBER C. HAMMAKER AND LESTER L. HAMMAKER, 491 STATE STREET, WEST FAIRVIEW, PA 17025 (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 $58,421.40 L.L. $.50 Interest FROM 2/1/02 TO 9/23/02 AT 9.6250% Arty's Comm % Due Prothy $1.00 Arty Paid $236.05 Other Costs Plaintiff Paid Date: OCTOBER 1, 2002 CURTIS R. LONG Prothonota (Seal) ? BY:Q"7'a P. Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Jospeh A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 AMBER C. HAMMAKER vs. LESTER L. HAMMAKER Mortgagor(s) and Record Owner(s) 491 State Street West Fairview, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 02-2897 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY 1, Joseph A. Goldbeck, Jr., 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. Joseph A. G Attorney for C? CD S.. O l+ ? yl ? 1- Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 1 I 1 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagor(s) and Record owner(s)) 491 State Street West Fairview, PA 17025 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 02-2897 CIVIL TERM MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., 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: 491 State Street West Fairview, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 2. Name and address of Defendant(s) in the judgment: AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. (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. 1 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: September 20, 2002 GOLDBECK CAFFvRTY & P BY: Joseph A oldbe Jr., Esq. Attorney for P aintiff rte] ;? 'G l;ci 7 -+ a ?D 02-2897 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagor(s) and Record Owner(s) Term No. 02-2897 CIVIL TERM 491 State Street West Fairview, PA 17025 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: HAMMAKER, AMBER C. AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 Your house at 491 State Street, West Fairview, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $58,421.40 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 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: 02-2897 CIVIL TERM 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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. 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 thirty (30) days from the date of the Sheriff s 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 C) O C rv ; v C -0tl' 21- -G l CJ . rJ 02-2897 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#l 6132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagor(s) and Record Owner(s) Term No. 02-2897 CIVIL TERM 491 State Street West Fairview, PA 17025 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: 11 AM MAKER, I ESTER L. LESTER L. HAMMAKER 119 N. Enola Drive #5 Fnola, PA 19025 Your house at 491 State Street, West Fairview, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $58,421.40 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 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: 02-2897 CIVIL TERM 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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. 1 f 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 thirty (30) days from the date of the Sheriff s 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 ° c ? o v e Z T -G t? Le¢el Description --- - - - -° ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE EAST PENNSBORO TWP, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AN]) DESCRIBED AS FOLLOWS, TO WIT BEGINNING AT A POINT ON THE NORTH SIDE OF THE STATE ROAD WHICH POINT IS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET (ERRONEOUSLY REFERRED TO IN PRIOR DEED AS TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (2555) FEET) WEST OF THE CORNER OF LANDS NOW OR LATE OF JOSEPH L BEST. THENCE NORTHEASTWARDLY ALONG LANDS OF WILLIAM M WORLEY TWENTY-FIVE AND EIGHT-TENTHS (258) FEET TO A POINT IN THE CENTER OF THE PARTITION WALL BETWEEN THE HOUSE HEREIN CONVEYED AND THE ADJOINING HOUSE, THENCE CONTINUING THROUGH THE CENTER OF THE PARTITION WALL IN SLIGHTLY MORE EASTWARDLY DIRECTION FORTY-EIGHT (48) FEET TO AN [RON PIN AT THE END OF SAID PARTITION WALL, THENCE IN A MORE NORHWARDLY DIRECTION ONE HUNDRED FOUR AND FOUR TENTHS (1044) FEET TO AN IRON PIN AT THE SOUTHERN SIDE OF A FOURTEEN (14) FEET WIDE ALLEY, WHICH IRON PIN IS TWENTY-SIX AND TWO TENTHS (262) FEET WEST OF LANDS NOW OR LATE OF JOSEPH L BEST, THENCE BY SAID ALLEY SOUTH SIXTY-TWO (62) DEGREES EAST TWENTY-SIX AND TWO TENTHS (261) FEET TO AN IRON PIN AT CORNER OF LOT NOW OR LATE OF JOSEPH L BEST, THENCE BY THE SAME SOUTH FIFTY-ONE (51 DEGREES FORTY-FIVE (45) MINUTES WEST EIGHTY-NINE AND FIVE-TENTHS (89 5) FEET TO AN IRON PIN, THENCE BY THE SAME SOUTH FORTY-FR'E (45) DEGREES FORTY- FIVE (45) MINUTES WEST NINETY-ONE (91) FEET TO AN IRON PIN ON THE NORTH SIDE OF SAID STATE ROAD, THENCE ACROSS SAID STATE ROAD BY LAND NOW OR LATE OF SAID JOSEPH L BEST SOUTH FIFTY- FOUR (54) DEGREES FORTY'-FIVE (45) MINUTES WEST TWO HUNDRED FORTY-SEVEN (247) FEET TO A STAKE ON THE BANK OF THE CONODOGLINET CREEK. THENCE UP SAID CREEK EASTWARDLY BY THE BANK THEREOF TWENTY-SIX AND FIFTY-FIVE ONE-HUNDREDTHS (26 55) FEET TO A POINT AT THE OTHER LAND NOW OR LATE OF HAROL EMIL MALSH. ET UX, THENCE BY THE SAME ACROSS SAID LOT NORTH FIFTY- FOUR (54) DEGREES FORTY-FIVE (45) MINUTES EAST TWO HUNDRED FORTY-SEVEN (247) FEET TO A POINT, THE PLACE OF BEGINNING THERE BEING ERECTED THEREON THE EASTERN HALF OF A DOUBLE TWO STORY FRAME DWELLING, NO 491 STATE ROAD DOCKET # 02-2897 CIVIL TERM TAX PARCEL # 45-16-1050-028 PROPERTY ADDRESS: 491 State Street, West Fairview, PA 17025 IMPROVEMENTS: A residential dwelling. SOLD AS THE PROPERTY OF: AMBER C. HAMMAKER and LESTER L. HAMMAKER GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagors and Record Owners 491 State Street West Fairview, PA 17025 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-2897 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: MPr ?cf i4rm Personal Service by the Sheriffs Office/competent adult (copy of return attached).. F-s i Ew ( ) 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. ?C) Premises was posted by Sheriffs Office/oosips6evowAWt (copy of return attached). f l m t ?, . fpm m A le- ( ) 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. Respectfully submitted, / U - - L A , r, J C oseph A oldbeck, Jr. ?orney for Plaintiff 7160 3901 9844 0951 1781 TO: HAMMAKER, LESTER L. LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER September 20, 2002 REFERENCE: HAMMAKER, AMBER C. / CWD-1971 03/05/03 - Cumberland RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees ft-? d US Postal Service POSTMARK:v'A DATE Receipt for v Certified Mail ,k t t , No Insurance Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 38'11, Domest,, return receipt by tear- ing left to right across pert. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece sf space permits. Otherwise affix to back of nlaill t 2, If you do not want the receipt postmarker7 stick the article # label to the right of the return address date receipt and retain the receipt 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt and the mailpiece rid ;Brie the edge of the receipt to the gummed edge Of a1 hesive- i h s °A ill hold the receipt in place to present to your mailcenter or past office service window. ,SEE ILLUSTRATION! \? PI?/I 1A N...I.I..I..III......INI...I (Corm 38W) VII?n? ! 9!1 !11 - ?qoo Y- Flrm NIaIN O? . 123 M.M S5 .11251 I V fl6 Clly, ?m 12315 II 11....1.1..1..111......1111...1 os.ie o. oee Legal Seymenl Marketing Manager w", Puxlal Solulione, Inc. 1 ?9tl 5oulll Mlsslon PD. Sidle 110 Fulltlr ook, CP 92028-4112 4. Enter fees for the services rFquesec 1 "" e;>l 'cafe spaces on the front of this receipt. 5 Save this receipt and present it if you ",1n1- as ,, rv. 7160 3901 9844 0951 1774 To: HAMMAKER, AMBER C. AMBER C. -HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER September 20, 2002 REFERENCE: HAMMAKER, AMBER C. / CWD-1971 03/05/03 - Cumberland PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees i US Postal Service POSTMARKE I Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across perf. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE ILLUSTRATION) IFG1tt1 ' a 291 041 709 ,a •..J.LIWII....IYJ ot9rl nJ94r r?e EroaY, CA Z 9aoaB •I ix IJextle = O= g W, #1264 12946 b.. Y.J........JNI..I oevin D. oa, Legal S,gmenl Marketing Manager Inc. Walz Post S" 1588 Soutll Mi eelon RC. Suite 110 Fe liorook, CA 82028.4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5. Save this receipt and present it if you make an inquiry. 0 3 Oc J J t0 N O m m N ? W N °Z Q? ?Q m m J a o m ? D Z 3 D O D z m n 0 0 'o W `G m K ? W F ? m 0 w O = a W m3m???^ m Scl oo? 0 0 O O x O j m mm3oom mwSgyc om;oQm ?n3'Sao sm '8= 3"vocm m9'3 S o m 3 o S s, 3mnS j "j, v °_oo33v- m8, ?iim o y ? : , 3 ? c ao $? m o N - J m n ? o m? m e'?'m3?mm .3 F: °a a.vpn N_ J Q j n ° V ?3Sm.0? p0-'mv Sx (nom-p C C n a w a°m 3 -m 3 3 c 3 w 3 p ? o?c ?c? Gov ?mmmom ?mmnvm n _-mom . '4D > Z W b?rna Y ?o m o a ? ?. = CO a m I o M a z b?ma .2_. cNi? d ? ?a? U3? a rn i\ n -A %* -,a ** %,n ?? y r.r a M c 4 c o W I 3CaC N 0 r :v 00,011 G CAS r.? -.a N •? aN w eESOT=D' 2.-8 vP ?y D or] D •s - - ? m o m ? - z r m0 w N s ? A? o w'z 3 r m A X a ? O n O c n C n 0 0 ,. r Dy ?a? n W aN m 0Q 36- M. (l) D d a°° a M 3 y ry W d (0 y °0 7 m o Hal N ? M ??? ? 0 x W p m m m x Octn v.? m m D m a ? N m O n m w m ??? m _ m m ? ? p m m J m p J n d d o D J A ?2 p A °' n o ,Q s m ? N < u m ? C E ? m n co ??? m? nU, ?<o pn o H vy c w m n m n m n m ? m a 0 ° N D y o mn ?O?n' n n n 3 = 0 (D T? o m 0 3 11 O N - C m '-Q -Q O? 2 m ? -r A m m AMENDED RETURN Mortgage Electronic Registration In The Court of Common Pleas of Systems, Inc., acting soley as nominee Cumberland County, Pennsylvania For the Bank of New York as trustee Writ No. 2002-2897 Civil Term For CWABS 2000-2 c/o Countrywide Home Loans, Inc. VS Amber C. Hammaker and Lester L. Hammaker Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on October 29, 2002 at 1:26 o'clock PM, 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: Amber C. Hammaker, by posting the premises located at 491 State Street, West Fairview, Cumberland County, Pennsylvania, pursuant to a court order with a said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 25, 2002 at 6:14 o'clock PM, 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: Lester L. Hammaker, by making known unto Lester Hammaker personally, at 119 N. Enola Drive, #5, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 7, 2003 at 6:46 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Amber C. Hammaker and Lester L. Hammaker located at 491 State St., West Fairview, 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 one of the within named defendants, to wit: Amber C. Hammaker by regular mail to her last known address of 491 State Street, West Fairview, PA 17025. This letter was mailed under the date of January 13, 2003 and was returned to the Sheriffs Office as "Not Deliverable as Addressed. Unable to Forward" on January 23, 2003. 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 one of the within named defendants, to wit: Lester L. Hammaker by regular mail to his last known address of 119 North Enola Drive, #5, Enola, PA 17025. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me This day of 2003, A.D. Prothonotary So Answers: I'e '?a~ R. Thomas Kline, Sheriff B ? Real Estate eputy Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagors and Record Owners 491 State Street West Fairview, PA 17025 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-2897 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., 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: 491 State Street West Fairview, PA 17025 1.Name and address of Owners or Reputed Owners: AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 2. Name and address of Defendants in the judgment: AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 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. (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 unswom falsification to authorities. DATED: February 19, 2003 A E K CAFFERTY & McKEEVER BY: seph A. oldbeck, Jr., Esq. At rney for Plaintiff C. C'. -Y C11 ? -? r? _.ri COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State 4o hereby certify that the Sheriff's Deed in which Bank of New York tr for CWABS 20000=2 is the grantee the same having I been sold to said grantee on the 5th day of March A.D., 2003, under and by virtue of a writ Execution issued on the Ist day of October, A.D., 2002, out of the Court of Common Pleas 6f said County as of Civil Term, 2002 Number 2897, at the suit of Mortgagee Electronic Registrati?ystems Inc nominee for Bank of New ork tr for Cwabs 2000-2 against Amber C Hammaker & Leste L is duly recorded in Sheriff's Deed Book No. 256, Page 2127. IN TESTIMONY WHEREOF, I hake hereunto set my hand and seal of said office this 2 day of A.D. 2003 Recorder of Deeds Sao vdJim2m AMENDED RETURN Mortgage Electronic Registration In The Court of Common Pl$as of Systems, Inc., acting soley as nominee Cumberland County, Pennsylvania For the Bank of New York as trustee Writ No. 2002-2897 Civil T4rm For CWABS 2000-2 c/o Countrywide Home Loans, Inc. VS Amber C. Hammaker and Lester L. Hammaker Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on October 29, 2002 at 1:26 o'clock PM, he served a trace copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Amber C. Hammaker, by posting the premises locate at 491 State Street, West Fairview, Cumberland County, Pennsylvania, pursuant to a urt order with a said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to la , states that on October 25, 2002 at 6:14 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the withi named defendant, to wit: Lester L. Hammaker, by making known unto Lester H aker personally, at 119 N. Enola Drive, #5, Enola, Cumberland County, Penns lvania, its contents and at the same time handing to him personally the said true and correct copy of the same. I Valerie Weary, Deputy Sheriff, who being duly sworn according tb law, states that on January 7, 2003 at 6:46 o'clock P.M., she posted a true copy of th? within Real Estate Writ, Notice, Poster and Description, in the above entitled action, pon the property of Amber C. Hammaker and Lester L. Hammaker located at 491 State St., West Fairview, 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 llowing manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Amber C. Hammaker by regular mail to her last known address of 491 State Street, West Fairview, PA 17025. This letter was m iled under the date of January 13, 2003 and was returned to the Sheriffs Office as "Not eliverable as Addressed. Unable to Forward" on January 23, 2003. 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 llowing manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Lester L. Hammaker by regular mail to his last known address of 119 North Enola Drive, #5, Enola, PA 17025. This letter was mailed der the date of January 13, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed th within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 5, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for The Bank ofNew York as Trustee for CWABS 2000-2 c/o Countrywide Home Loans, Inc. It being the highest''bid and best price received for the same, The Bank of New York as Trustee for CWABS 2000-2 c/o Countrywide Home Loans, Inc. of 7105 Corporate Drive, PTX B-35, Pl o, TX 75024- 3632, being the buyer in this execution, paid to Sheriff R. Thomas Kline he sum of $1,081.18. Sheriffs Costs: Docketing $30.00 Poundage 21.19 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 31.05 Certified Mail 1.96 Levy 15.00 Surcharge 30.00 Posting 6.00 Law Journal 418.85 Patriot News 365.92 Share of Bills 25.21 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 1081.18 Sworn and subscribed to before me So An we This S?r' day of R. Thomas Kline, Sheriff 2003, A.D. rothonotary BY Real Esta Deputy Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ivivtc i UA(it ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 vs. AMBER C. HAMMAKER LESTER L. HAMMAKER (Mortgagor(s) and Record Owner(s)) 491 State Street West Fairview, PA 17025 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 02-2897 CIVIL TERM MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe Ifor the writ of execution was filed the following information concerning the real property located at: 491 State Street West Fairview, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 2. Name and address of Defendant(s) in the judgment: AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTON - LAW ACTION OF MORTGAGE FORECLOSURE LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 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 may be affected by the sale. (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 p information and belief. I understand that false statements herein are made subject to the penalties relating to unsworn falsification to authorities. DATED: September 20, 2002 GOLDBECK CAFF RTY & 1 BY: Joseph A oldbe , Jr., Esq. Attorney for P aintiff in the property which onal knowledge or 18 Pa. C.S. Section 4904 VER 02-2897 CIVIL TERM GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#I 6132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagor(s) and Record Owner(s) 491 State Street West Fairview, PA 17025 Defendant(s IN THE COURT OF COON PLEAS of Cumberland 6unty I I CIVIL ACTION - LAW ACTION OF MORTOAGE FORECLOSU Term No. 02-2897 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT T COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HAMMAKER, AMBER C. AMBER C. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 Your house at 491 State Street, West Fairview, PA 17025 is scheduled to be sold at S? eriffs Sale on Wednesday, March 05, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courth use to enforce the court judgment of $58,421.40 obtained by MORTGAGE ELECTRONIC REGIST TION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS RUSTEE FOR CWABS 2000-2 CIO COUNTRYWIDE HOME LOANS INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 02-2897 CIVIL TERM 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK SAS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., the back payments, to charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 2 1 5-627 1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or pen judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the ore chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OT ER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidden You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was gros$ly 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 tl?e 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 ow er 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 S eriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evi t you. 6. You may be entitled to a share of the money which was paid for your house. A sch dule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days fro 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTEi FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVE A BELOW TO LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 02-2897 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. AMBER C. HAMMAKER LESTER L. HAMMAKER Mortgagor(s) and Record Owner(s) IN THE COURT OF COIVI?MON PLEAS of Cumberland C Runty CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURIE 491 State Street West Fairview, PA 17025 Defendant(s Term No. 02-2897 CIVIL ` ERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT T COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HAMMAKER, LESTER L. LESTER L. HAMMAKER 119 N. Enola Drive #5 Enola, PA 19025 TO BE Your house at 491 State Street, West Fairview, PA 17025 is scheduled to be sold at eriffs Sale on Wednesday, March 05, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courth use to enforce the court judgment of $58,421.40 obtained by MORTGAGE ELECTRONIC REGIS TION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS RUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC. 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: 02-2897 CIVIL TERM 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC., the back payments] late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike of open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale f r good cause. 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 biddFr. You may find out the price bid price by calling the Sheriff of 717-240-6390. Ii 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 irk 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. Yoti 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 toevict you. 6. You may be entitled to a share of the money which was paid for your house. A s ?hedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days fr m the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution isiwrong) 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 NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LIS ED 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-2897 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. ACTING SOLELY AS NOMINEE FOR THE BANK OF NEW YORK AS TRUSTEE FOR CWABS 2000-2 C/O COUNTRYWIDE HOME LOANS INC Plaintiff (s) From AMBER C. HAMMAKER AND LESTER L. HAMMAKER, 491 STATE STREET, WEST FAIRVIEW, PA 17025 (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 '1he 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 s been added as a garnishee and is enjoined as above stated. Amount Due $58,421.40 L.L. $.50 Interest FROM 2/1/02 TO 9/23/02 AT 9.6250% Atty's Comm % Due Prothy $1.00 Atty Paid $236.05 Other Costs Plaintiff Paid Date: OCTOBER 1, 2002 CURTIS R. LONG (Seal) Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 3 On October 24, 2002 the sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as 491 State Street, West Fairview, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 24, 2002 By: s ? [ is t 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 Asst. 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 28th day(s) of January and the 4th and 11th day(s) of February 2003. 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. '?. ................a. .......... .....? PUBLICATION ..........................: COPY Sworn to and sub ribe b ore me this 14t of wary 2003 A.D. ? S A L E #3 Notanal Seal ? REAL ESTATE SALE No. 3 Terry L. Russell, Notary' Writ No. 2002-2897 City Of Harrisburq, Dauphin County p OTARY PUBLIC Civil Term My Commission Expires June 6, 2006 Mortgage Electronic Member, Pennsylvania Association Of Notaries My commission expires June 6, 2006 Registration Systems, Inc., acting solely as Nominee for The Bank of CUMBERLAND COUNTY SHERIFFS OFFICE New York as Trustee for CWABS 2002-2 CUMBERLAND COUNTY COURTHOUSE c% Countrywide Home CARLISLE, PA. 17013 LOWdl, Ina AmbwC.Hammelaerand Statement of Advertising Costs Lester L. Hammaker Atty: Joseph A. Goldbeck, Jr. To THE PATRIOT-NEWS CO., Dr. DESCRIPTION ALL THAT CERTAIN tract of land situate in the For publishing the notice or publication attached East Pennsboro Twp., County of Cumberland and hereto on the above stated dates $ 364.17 State of Pennsylvania more particularly bounded Probating same Notary Fee(s) $ 1.75 and described as follows, to wit: 365.92 BEGINNING at a point on the north side of the Total $ State Road which point is twenty-six and fifty- five one-hundredths (26.55) feet (erroneously referred to in prior deed as twenty-five and fifty- Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By ................................ five one-hundredths (25.55) feet) west of the corner of lands now or late of Joseph L. Best, thence northeastwardly along lands of William M. Worley twenty(five and eight-tenths (25.8) feet to a point in the center of the partition wall between the house herein conveyed and the adjoining house, thence, continuing through the center of the partition wall in slightly more eastwardly direction forty-eight (48) feet to an iron pin at the end of said partition wall, thence in a more northwardly direction one hundred four and four-tenths (104.4) feet to an iron pin at the southern side of a fourteen (14) feet wide alley, which iron pin is twenty-six and two-tenths (26.2) feet west of lands now or late of Joseph L. Best, thence by said alley south sixty-two (62) degrees east twenty-six and two tenths (26.2) feet to an iron pin at corner of lot now or late of Joseph L. Best, thence by the same south fifty- one (51) degrees forty-five (45) minutes west eighty-nine and five-tents (89.5) feet to an iron Pin, thence by the same south forty-five (45) degrees forty-five (45) minutes west ninety-one (91) feet to an iron pin on the north side of said State Road, thence across said State Road by land now or late of said Joseph L. Best south fifty-four (54) degrees forty-five (45) minutes west two hundred forty-seven (247) feet to a stake on the bank of the Conodoguinet Creek, thence up said creek eastwardly by the bank thereof twenty-six and fifty-five one-hundredths (26.55) feet to a point at the other land now or late of Harol Emil Malsh, et ux, thence by the same across said lot north fifty-four (54) degrees forty-five (45) minutes east two hurWred forty-seven (247) feet to a point, the place of BEGINNING there being erected thereon the eastern half of a double two- story frame dwelling, No. 491 State Road. DOCKET #02-2897 Civil Tenn. TAX PARCEL #45-16-1050-028. PROPERTY ADDRESS: 491 State Street, West Fairview, PA 17025 IMPROVEMENTS: A residential dwelling. SOLD AS THE PROPERTY OF. Amber C. Hammaker and Lester L. Hammaker. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L 1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND . Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal o 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 of the County and was established January 2, 1952, and designated by the local colurts as the of and State aforesaid, periodical for the publication of all legal notices, and has, since January issued weekly in the said County, and that the printed notice or publication attached ficial legal regularly exactly the same as was printed in the regular editions 2n attx2,ached been hereto is Journal on the following dates, and issues of the said Cumberland Law viz: JANUARY 31, FEBRUARY 7, 14, 2003 Affiant further deposes that he is authorized to verify this statement b Law Journal, a legal periodical of general circulation, and that he stn by the Cumberland in the subject matter of the aforesaid notice or advertisement, and that all allegations interested in th statements as to time, place and character of publication are true. e foregoing REAL ESTATE BALE NO. 3 Writ No. 20 20 2897 Civil Mortgage Electronic Registration Systems, Inc. acting soley as Nominee for The Bank of New York as trustee for CWABS 2000-2, c/o Countrywide Home Loans, Inc. vs. Amber C. Hammaker and Lester L. Hammaker Atty.: Joseph A. Goldbeck, Jr. Legal Description ALL THAT CERTAIN tract of land land situate in the East Pennsboro Of County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of the state road wh point twenty -six ich and fifty-five one- hundred Ills (26 (26 55) feet (erroneously referred to in prior deed as twenty- six and fifty-five one-hundredths (25 sa Editor IV I)-',',N TO AND SUBSCRIBED before me this -14-day of FEBRUARY 2per 55) feet) West of the corner of lands now or late of Joseph L. Best, thence northeastwardly along lands of Will- iam M. Worley twenty-five and eight- tenths (25 8) feet to a point in the center of the partition wall between the house herein conveyed and the adjoining house, thence continuing through the center of the partition wall in slightly more eastwardly di- rection forty-eight (48) feet to an iron pin at the end of said partition wall, thence in a more norhwardly direc- tion one hundred four and four tenths (104 4) feet to an iron pin at the southern side of a fourteen (14) feet wide alley, which iron pin is twenty-six and two tenths (26 2) feet west of lands now or late of Joseph L Best, thence by said alley South sixty-two (62) degrees East twenty- six and two tenths (26 2) feet to an iron pin at corner of lot now or late of Joseph L Best, thence by the same South fifty-one (51 degrees forty-five (45) minutes West eighty-nine and five-tenths (89 5) feet to an iron pin, thence by the same South forty-five (45) degrees forty-five (45) minutes West ninety-one (91) feet to an iron pin on the North side of said state road, thence across said state road by land now or late of said Joseph L Best south fifty-four (54) degrees forty-five (45) minutes West two hundred forty-seven (247) feet to a stake on the bank of the Conodogui- net Creek. Thence up said creek eastwardly by the bank thereof twenty-six and i3fty-five one-hun- dredths (26 55) feet to a point at the other land now or late of Harol Emil Malsh, et ux, thence by the same across said lot North fifty-four (54) degrees forty-five (45) minutes East two hundred forty-seven (247) feet to a point, the place of begin- ning there being erected thereon the eastern half of a double two story frame dwelling, No 491 State Road. DOCKET #02-2897 CIVIL TERM. TAX PARCEL #45-16-1050-028. PROPERTY ADDRESS: 491 State Street, West Fairview, PA 17025. IMPROVEMENTS: A residential dwelling. SOLD AS THE PROPERTY OF: AMBER C. HAMMAKER and LESTER L. HAMMAKER.