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Home My WebLink About07-1030IIDREN LAW OFFICES P C ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s 3476 Stateview Blvd. :Cumberland Fort Mill, SC 29715 Plaintiff V. Helen Gibble 151 North Bedford Street € NO. Carlisle, PA 17013 Defendant(s) County tut, 1036 (2 - ' LC7?? COMPLAINT IN MORTGAGE FORECLOSURE 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 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 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 claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DENANDA A UN ABOGADO INNEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: US Bank National Association, as Trustee for Bear Stearns ABS 2006-AC2s Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 151 North Bedford Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Carlisle COUNTY: Cumberland DATE EXECUTED: 12/20/05 DATE RECORDED: 12/21/05 BOOK: 1935 PAGE: 1317 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 2/3/07: Principal of debt due $63,744.51 Unpaid Interest at 8.1250 from 7/1/06 to 2/3/07 (the per diem interest accruing on this debt is $14.12 and that sum should be added each day after 2/3/07) 3,043.19 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0 and that sum should be added on the first of each month after 2/3/07) 718.00 Late Charges (monthly late charge of $23.76 should be added in accordance with the terms of the note each month after 2/3/07) 95.04 Corporate Advance 117.30 Attorneys Fees (anticipated and actual to 50 of principal) 3,187.23 TOTAL $71,510.27 7. The attorney's fee 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 in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $71,510.27 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. U/? Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 _ ? utti?e iai AIN tract of land ?°i1a tb'e d Cajun Y ' Neff, the let aad c BorauBh of Caere' d? P1ea thereof arc by Twa° ad in accord=ce with a 1t4t follow, to WW' Rye ebb, dated Wte=ber 811969, as -Ch Pt is South Belford Sued. BEGMG a point of the east side of North South the side of past Nh SMVC g? l2 d North land aow o a 30 mm s bleat, ?•7 of Ray McCaw' (No. 153 b,OL thenco along proper now or mutes East. 91.25 feet to a post a (d utes West' 30 min South 77 dcgrecs soutu 12 slid others, theocc by the $0 jmkia degrees (Iqo. 14q Gg, 61.00 or ' ur 1,,a u w or ,. e+a .40 minutes W secands 14vs a, West, w feet m a 24 ms 20 stake UL ?k t nc hcx?O° b sby m North 5D der cmvcyed; mince N,. T?'asd a? by herein eastern fee to a sp&e; of tine house on the Isad =a corner 2.41 feat to the ? 77 d?B 30 miaut?s? N10 feet a ?e8 30 ? E&st' by 3ald North Beds Street; thence by said sido of BECrINN1NG. 13.75 feet to the placa as 151 N. Bedford Street, Aisle, with a dweling house lmowa BEING imps'?? -. PermsS''' TCGETM with a raUt a in6=59 and CWm" over a 2.20 Boot wide allcyway (ver 1)tW W to the south hffcd for a distance of 30.51 Beet. PO BOX 1225 Charlotte, NC 28201-1225 January 2, 2007 Helen Gibble 151 N. Bedford Street Carlisle PA 17013 111111111111111111111111111111111111 „oo 4047 =100 3602 6433 004801/ 106Act91 RE: America's Servicing Co. Loan Number 1218108881 Mortgagor(s): Helen Gibble Mortgaged Premises: 151 N. Bedford Street Carlisle, PA 17013 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 information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM save be able to help to To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice The name. address and phone number of Consumer Credit are at 1-800-342-2397. (Persons with impaired hearing can This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A HOMEOWNER'S NAME(S): Helen Gibble PROPERTY ADDRESS: 151 N Bedford Street Carlisle, PA 17013 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: 1218108881 America's Servicing Co. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay 0 orec osure on your mortgage or t arty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT T. T". EXPLAINS H CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counse in a encies iste at the en o this nonce, the lender may NOT take action against you for thirty ;3 days after the date of this meeting. The names addresses and telephone numbers of designate d consumer credit counselin agencies for the coup in which the property is locatecT r s forth h en of this Notice, It is only necessary to schedule •ne face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth ater in this once see following pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's-Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT-FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 004801/106 AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will T e- by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES 6NLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have riled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - - The MORTGAGE debt held by the above lender on your property located at: 1-51 N- Bedford Street Carlisle- PA 17013 IS SERIOUSLY I DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 2006 January 2007 P3.440.41 Other charges (explain/itemize): Late Charges $71.28 00 Other Fees (if applicable) Suspense Amount 3,511.69 TOTAL AMOUNT PAST DUE: a vnTT uA« RATT FTl TO TAKE THR FOLLOWING ACTION HOW TO CURE THE DEFAULT - - You may cure the default within THIRTY (30 DAYS of the ate o is no ice BY FAYINUTHE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 3,511.69 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable an sent o: America's Servicing Co. PO Box 1820, Newark, NJ 07101-1820 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: IF YOU D NOT CURE THE DEFAULT - - If you do not cure the default within THIRTY 30 DAYS o e date o is Notice, the en er in ends to exercise its rights to accelerate the mortgage de t. This means that the entire outstanding balance o is a will a considered ue imme is e y an you may lose the chance to .pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY 00) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - - The mortgaged property will be sold by the Sheriff to pay o the mortgage debt. telender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actuaIly incurred, up to $50.00. However, if legaf proceedings are started against you you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAt period, you will not be required to pay attorney's tees. OTHER LENDER REMEDIES - - The lender may also sue you personally for the unpaid principal balance an a other sums due under the mortgage. 904801/10§ RIG mortgage. uurii same position as AULT PRIOR TO your default in the manner you had never defaulted. your EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale o the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: America's Servicing Co. Address: 3476 Stateview Boulevard Fort Mill SC 29715 Phone Number: 866-606-9382 Fax Number: 803-396-6063 Contact Person: Clarice Townsend EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortggagge property an your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO 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. SALE -- If you have not cured the default e ings have begun, you still have the right 0 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNCONSUMER CREDIT COUNSELIING AGENCIES PROGRAM CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. Financial Counseling Services of Franklin 2000 Linglestown Road 31 West 3rd Street Harrisburg, PA 17102 Waynesboro, PA 17268 (717) 541-1757 (717) 762-3285 FAX # (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX # (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX # (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gett sburg, PA 17325 (71ff 334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. PO Box 1225 Charlotte, NC 28201-1225 7100 4047 5100 3602 6426 January 2, 2007 Helen Gibble 151 N. Bedford St. Carlisle PA 17013 004902J106Act91 RE: America's Servicing Co. Loan Number 1218108881 Mortgagor(s): Helen Gibble Mortgaged Premises: 151 N. Bedford Street Carlisle, PA 17013 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 information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvan Hnnneina Finance Aeencv toll free at 1-800-342-2397. (Persons with impaired hearing can call This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Helen Gibble PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: 151 N Bedford Street Carlisle, PA 17013 1218108881 America's Servicing Co. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay 0 orec osure on your mortgage or t arty (30) days from the date of this Notice. During that time meeting with one of the consumer credit counseling you must arrange and attend a age agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT T r "HOW TO CURE YOUR MOR' for thirty ?31? days after the date of this your T". EXPLAINS H UR -- If you meet with one of the consumer credit the lender may NOT take action against you -hp name4 adrlrecces and telephone numbers It is only necessary to schedule one face-to-face your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice see o owing pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's-Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT-FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. goaaoz/to@ AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will e disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES 6NLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have riled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - - The MORTGAGE debt held by the above lender on your property located at: 151 N Redford Street - Carlisle- PA 17A1 *1 IS SERIOUSLY I DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 2 06 January 2007 VA 440 41 Other charges (explain/itemize): Late Charges ?/ I. ZZ5 00 Other pFees (if applicable) Suspense Amount 3,511.69 TOTAL AMOUNT PAST DUE: n vnTT uA« FAiT 1Pn TO TAKR THF. FOLLOWING ACTION HOW TO CURE THE DEFAULT - - You may cure the default within THIRTY (30) DAYS of the date o is notice E TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 3,511.69 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable an sen o: America's Servicing Co. PO Box 1820, Newark, NJ 07101-1820 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: - - If you do not ds to exercise its to accelerate the AYS This may means that the entire outs an ing a_ance o is a win 1 ne lose the chance to pay the mortga a in monthly installments. due is not made within THIRTY ?30) DAYS, the lender also legal action to foreclose upon your mortgaged property. If full payment of the total amount past intends to instruct its attorneys to start IF THE MORTGAGE IS FORECLOSED UPON - - The mortgaged property will be sold by the Sheriff to pay o the mortgage debt. telender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAt period, you will not be required to pay attorney's-re-es. OTHER LENDER REMEDIES - - The lender may also sue you personally for the unpaid principal balance an a other sums due under the mortgage. g048O2/tog AULT mortgage. Curing your default in the manner same position as if you had never defaulted. your EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale o the mortgage property could e held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: America's Servicing Co. Address: 3476 Stateview Boulevard Fort Mill SC 29715 Phone Number: 866-606.5'382 Fax Number: 803-396-6063 Contact Person: Clarice Townsend EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mort agge property an your right to occupy it. If you continue to live in the property after the Sheriff's ate, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO 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 G!URE 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. -- If you have not cured the default have begun, you still have the right 0 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWrCONSUMER CREDIT COUNSELING AGENCIES PROGRAM CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. Financial Counseling Services of Franklin 2000 Linglestown Road 31 West 3rd Street Harrisburg, PA 17102 Waynesboro, PA 17268 (717) 541-1757 (717) 762-3285 FAX# (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX # (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gett burg, PA 17325 (717334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Lzill\ Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. ct D ^6 w r ? ? 1 'y my t...._ (? L, f f7JJ 2 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s :Cumberland County Plaintiff V. NO. 07-1030-Civil Term Helen Gibble Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: April 10, 2007 BY: ark J. Udrel,,-Ssquire ttorney for Plaintiff UDREN LAW OFFICES, P.C. V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized`to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Helen Gibble Loan #1218108881 MJU 407020101 '? -- - Z' Name : Steven Patrick Title: Vice President Loan Documentation Company: ?? ?? -? ?,?- ? ..? =? -re ?? r, , t? '' ` ?", ? . ; ??,, .# . ? _ ?? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s :Cumberland County 3476 Stateview Blvd. Fort Mill, SC 29715 :MORTGAGE FORECLOSURE Plaintiff V. 6 Helen Gibble :NO. 07-1030-Civil Term 151 North Bedford Street Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Helen Gibble for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $71,510.27 Interest Per Complaint 931.92 From 2/4/07 to 4/10/07 Late charges per Complaint 47.52 From 2/4/07 to 4/10/07 TOTAL $72,489.71 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached J?ereto. UDREN LAW OFFICES, P.C. Mark NjT. dren, ES132RE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICA D DATE: PR PROTHY SHERIFF'S RETURN - REGULAR CASE NO: 2007-01030 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS GIBBLE HELEN MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GIBBLE HELEN the DEFENDANT , at 2040:00 HOURS, on the at 151 NORTH BEDFORD STREET CARLISLE, PA 17013 HELEN GIBBLE 6th day of March 2007 by handing to 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: So Answers: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 32.80 03/07/2007 UDREN LAW OFFI S Sworn and Subscibed to By: before me this day Deput S eriff of A.D. UDREN LAMP OFFICES, P.C. BY: Mark J. Udren, Require ATTY I.D. NO. 04302 WOODCREST.CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadinga@udron.com US Bank National Association, as Trustee for Bear Stearns ABS 2006-AC2s Plaintiff V. Helen Gibble Defendant (s) TO: Helen Gibble 151 North Bedford Street Carlisle, PA 17013 DATE of Notice: March 29, 2007 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-1030-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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVIC10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEB COLLECTIONICES AC, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECT R IS IS EMPT TO LLECT A DEBT. ANY INFORMATION OBTAINED WILL Bib. II THAT URPO k J. uarerr, ;squire Wo rest Corporate Center 111 oodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 n Zc' UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 US Bank National Association, as Trustee for Bear Stearns ABS 2006-AC2s 3476 Stateview Blvd. Fort Mill, SC 29715 Plaintiff v. Helen Gibble 151 North Bedford Street Carlisle, PA 17013 Defendant(s) STATE OF COUNTY OF SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-1030-Civil Term AFFIDAVIT OF NON-MILITARY SERVICE Helen Gibble Over 18 As captioned Unknown Sworn to and subscribed befo e me this day o f20 1Notary i above ame : Steven Patric Title. Vice President Loan Documentation Company: 0 FICIAL SEAL Notary Public state of south Carolina M Commissslonn RANDY Ps ®Nt 1, ES016 0 -lz "Er9. V 3-. r ? N i ? - REN LAW OFFICES P C ATTORNEY FOR PLAINTIFF . Up BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s €:Cumberland County Plaintiff v. :MORTGAGE FORECLOSURE Helen Gibble :NO. 07-1030-Civil Term De f endant (s) TO: Helen Gibble 151 North Bedford Street Carlisle, PA 17013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, notified that a Judgment has been entered against you proceeding as indicated below. Prothonotary you are hereby in the above x Judgment by Default Money Ju( Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Helen Gibble ':NO. 07-1030-Civil Term Defendant (s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. LAW OFFICES, P.C. lark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF " ? ? ? ; ? rt ??? ? a ` ? S ? ? ? ?? ? . J '"As ?? ?_J? ^ ?. '°r? ?,y -. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Helen Gibble :NO. 07-1030-Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 US Bank National Association, as Trustee for Bear Stearns ABS 2006- AC2s, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 151 North Bedford Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Helen Gibble 151 North Bedford Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address US Bank National Association, 3476 Stateview Blvd. as Trustee for Bear Stearns Fort Mill, SC 29715 ABS 2006-AC2s Mortgage Electronic P.O. Box 2026 Registration Systems, Inc. Flint, MI 48501-2026 5. Name and address of the property: Name None Address 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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: Name Address Tenants/Occupants 151 North Bedford Street Carlisle, PA 17013 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. sec. 4904 relating to unsworn falsification to authorities. DATED: April 10, 2007 every other person who has any record lien on UDREN LAW OFFICES, P.C. Mark J. Udren, ESQ. Attorney for Plaintiff w ? C C-D UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s :Cumberland County Plaintiff V. ;MORTGAGE FORECLOSURE Helen Gibble NO. 07-1030-Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Helen Gibble 151 North Bedford Street Carlisle, PA 17013 Your house (real estate) at 151 North Bedford Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $72,489.71, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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 on page two on how to obtain an attorney.) ? s w= YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. LAWYER REFERRAL SERVICE Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ?? CJI .{ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s ':Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Helen Gibble :NO. 07-1030-Civil Term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $72,489.71_ Interest From 4/11/07 2,089.76 to Date of Sale 9/5/07 Ongoing Per Diem of 14.12 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, IFF TZ-) cz? -o c- 4,A ?, V.1 9.J c? o 7 J r ?` t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1030 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, Plaintiff (s) From HELEN GIBBLE (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 $72,489.71 L.L. $.50 Interest FROM 4/11/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $14.12 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $2,089.76 Atty's Comm % Atty Paid $128.80 Plaintiff Paid Date: APRIL 12, 2007 Due Prothy $2.00 Other Costs C is R. Long, o tary (Seal) By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 SHERIFF'S RETURN - REGULAR CASE NO: 2007-01030 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS GIBBLE HELEN MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GIBBLE HELEN the DEFENDANT , at 2040:00 HOURS, on the 6th day of March , 2007 at 151 NORTH BEDFORD STREET CARLISLE, PA 17013 by handing to HELEN GIBBLE 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 4.80 Affidavit .00 Surcharge 10.00 .00 3)afoZ ? 32.80 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/07/2007 UDREN LAW OFFI S By: Deput S eriff A. D. 4MR10 LAW OFFICES, P. C. BY: Nark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 US Bank National Association, as Trustee for Bear Stearns ABS 2006-AC2s 3476 Stateview Blvd. Fort Mill, SC 29715 Plaintiff V. Helen Gibble 151 North Bedford 'Street Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-1030-Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known,as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to t e penalties ofA8 Pa.C.S. Section 4904 relating to unsworn falsification t authoritAe Dated: August 30, 2007 \_-Tg6REN L14if OFV3;tE4, P. C. BY: Mark J. Udr , Es uire Attorn for Plai iff 1W w UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 US Bank National Association, as Trustee for Bear Steams ABS 2006- AC2s Plaintiff V. Helen Gibble Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-1030-Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Helen Gibble PROPERTY: 151 North Bedford Street, Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 5. 2007, at 10:00 A.M., in the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A U. a N? o0 $ 0 g o a i A As ?pD =U a a? -V ? a tit ° I ®90 Z. fn pit S Cc' r`? \ \ "a 3Jtll Hs3?v g2 ;0,p ?io.ez?an z 013 0 a cn w CL. ?[3 13 ? Z O N Q N r Q Ul p4. Z o m Q $ Q to r = n F=' 2 CC 0 V V.- p e'?i pC U S m m o ?i 0.53 C4j U), - N coAo eo ?uj N4CGn`Nd N v za 0?4w x O ?- N= m oN ocQQw?_v a o0O.Xto r 5 Z pG Z a wc?? Nw0coQ a 73 Z V V ? ti L z 0 o E O 0. m a c 0 a 0 c S 0 v R oQ co r1 m ? LL r= a ? e~o ll LL 3. N CL. r N ? ` r ? Y EXH?giT A ' S] 7 Vi O r N O Q N G a? 11? . US Bank National Association, as In the Court of Common Pleas of Trustee for Bear Stearns ABS 2006-AC2s Cumberland County, Pennsylvania VS Writ No. 2007-1030 Civil Term Helen Gibble Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 2007 at 1440 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Helen Gibble, by making known unto Helen Gibble personally, at 151 North Bedford Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Megan Marlow, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2007 at 1605 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Helen Gibble located at 151 North Bedford Street, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Helen Gibble, by regular mail to her last known address of 151 North Bedford Street, Carlisle, PA 17013. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff BY Real Estate 'ergeant EXHIBIT B try N N COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Bear Stearns ABS 2006-AC2 Tr is the grantee the same having been sold to said grantee on the 5th day of Sept A.D., 2007, under and by virtue of a writ Execution issued on the 12th day of April, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 1030, at the suit of Bear Stearns ABS 2006-AC2s Tr against Helen Gibble is duly recorded as Instrument Number 200737259. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a'? day of A.D. aL'o 0 Aeoower of Duda. wr&ww Courtly, CwW Pa Recor r of Deeds * Ccm?dWW 609a the Fk* Monday of Jm. 2010 US Bank National Association, as In the Court of Common Pleas of Trustee for Bear Steams ABS, 2006-AC2s Cumberland County, Pennsylvania VS Writ No. 2007-1030 Civil Term Helen Gibble Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 2007 at 1440 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Helen Gibble, by making known unto Helen Gibble personally, at 151 North Bedford Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Megan Marlow, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2007 at 1605 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Helen Gibble located at 151 North Bedford Street, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Helen Gibble, by regular mail to her last known address of 151 North Bedford Street, Carlisle, PA 17013. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 5, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren on behalf of US Bank National Association, as Trustee, for Bear Stearns ABS 2006-AC2. It being the highest bid and best price received for the same, US Bank National Association, as Trustee, for Bear Stearns ABS 2006-AC2 of 3476 Stateview Blvd., Fort Mill, SC 29715, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,033.38. Sheriff s Costs: Docketing $30.00 Poundage 20.26 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 9.60 Levy 15.00 t Surcharge 20.00 Law Journal 401.00 Patriot News 366.83 Share of Bills 15.69 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $1,033.38 So Answers: 0 R. Thomas Kline, Sheriff 7 BYJk4 Real Estate ergeant ?.S C.12 Loco 7 i9 93 ?? L .lk UD BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Helen Gibble NO. 07-1030-Civil Term Defendant(s) tREN LAW OFFICES P C ATTORNEY FOR PLAINTIFF AFFIDAVIT PURSUANT TO RULE 3129.1 US Bank National Association, as Trustee for Bear Stearns ABS 2006- AC2s, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 151 North Bedford Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Helen Gibble 151 North Bedford Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address US Bank National Association, 3476 Stateview Blvd. as Trustee for Bear Stearns Fort Mill, SC 29715 ABS 2006-AC2s Mortgage Electronic P.O. Box 2026 Registration Systems, Inc. Flint, MI 48501-2026 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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: Name Address Tenants/Occupants 151 North Bedford Street Carlisle, PA 17013 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. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: April 10, 2007 Mark J. Udren, ESQ. Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com US Bank National Association, :COURT OF COMMON PLEAS as Trustee for Bear Stearns :CIVIL DIVISION ABS 2006-AC2s ':Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Helen Gibble :NO. 07-1030-Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Helen Gibble 151 North Bedford Street Carlisle, PA 17013 Your house (real estate) at 151 North Bedford Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA, to enforce the court judgment of $72,489.71, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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 on page two on how to obtain an attorney.) I , #L y 1 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE 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 by calling 856-669-5400. 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 856-669-5400. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE 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. LAWYER REFERRAL SERVICE Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Asscoiation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 . #0 ALL THAT CERTAIN tract of lend with the improvements thereon erected, situate in the 1$t Ward of the Borough of Carlisle, Cumbe=rland County, Penneylva da, bounded and desmibed in accordsaae with a survey and Plan thereof made by Thomas A. Neff, Registered Surveyor, dated September 8, 1969, as followa, to wit: BEGRM MG at a point on;the east side of Norih Bedford Street, which point is South 12 drgrmt; 30 minutes West, 89.70 feet from the south side of East Nrnth Su i; thence along property now or formerly of Ray McCarter (No. 153 North Bedford Strmt), and others, South 77 degrees 30 minutes East, 91.25 feet to a post at line of land now or for=miy of Wiliam Shook; thence by the same:, South 12 degrees 30 minutes West, i b avu feet w a stake at lice of laud uuw or fomwly ef Edwin U. Rankin (No. 34q Nw tl,, I*Udford Qtrett); t1v=** by the cam*, North 77 dpgrrAft 30 miuut= West, 61.00 feet to a spilre; thence by the name, Nora 50 degrees 24 =inutes 20 seconds West, 2.41 feet to the southacstena corner of the house on the land hercin conveyed; thence by said house, North 77 degrees 30 minutes West, 28.10 feet to a spy on the eastern side of North Bedford Street; thence: by said street, North 12 degrees 30 minatca East, 13.75 feet to the pWx of BEtrINMG. BEING improvcd with .a dwelling house known as 151 N. liaaard Street, Carlisle, Fexinsylvatzie. TOUR with a right Of ingress and egress over a 2.20 foot wide: alleyway over property to the south hem for a distance of 30.51 feet. BEING KNOWN AS: 1151 NOLEH PBEDF A 1OD STREET CARLIS, 013 PROPERTY ID NO.: 02-21-0318-193 FROM TITLE TO SAID PREMISES IS VESTED IN HELEN EAND W FE DATEDE 1D2 / 2 0/ 0 5 MARLINCORDED gp,RBOUR AND FRANCES C. Bp,RBOUR, HUSBAND 12/21/05 IN DEED BOOK 272 PAGE 2273. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-1030 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, Plaintiff (s) From HELEN GIBBLE (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 $72,489.71 L.L. $.50 Interest FROM 4/11/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $14.12 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $2,089.76 Atty's Comm % Due Prothy $2.00 Atty Paid $128.80 Other Costs Plaintiff Paid Date: APRIL 12, 2007 (Seal) ??4?L Curt' R. Long, on tary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 24 On May 2, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA Known and numbered as 151 North Bedford Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 2, 2007 By: Real Estate sergeant LI c cscV LGt3? I ....,. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1st day(s) of August 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #24 ...... ejl-.4 Sworn to and subscribed before me this 20th day of August 2007 A.D. COMMONWEAI_7 -E o.4,,!6 Notar.'_-' Seal Terry L Russe,i, aiHoUy Public C' Of Harrisburg; Dauphin County mmission Expires June 6, 201 U e . ?ennstYlvAnia AssoGictinn of Nn{gri;'..s NOTARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 20, July 27, and August 3, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lis e- arie Coyne ditor SWORN TO AND SUBSCRIBED before me this day of August, 2007 Notary _ NOTARIAL SEAL DEBORAH A COLONS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission ExpWo Apr 28, 2010 MMOMMEW RZAL ZOTATZ SALE NO. 24 . Writ No. 2007-1030 Civil US Bank National Association, as Trustee for Bear Stearns ABS 2006-AC2s vs. Helen Gibble Atty.: Mark Udren DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the 1st Ward of the Borough of Carlisle, Cumberland County. Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by Thomas A. Neff, Registered Surveyor, dated September 8, 1969, as follows, to wit: BEGINNING at a point on the east side of North Bedford Street, which point is South 12 degrees 30 minutes West, 89.70 feet from the south side of East North Street; thence along property now or formerly of Ray Mc- Carter (No. 153 North Bedford Street), and others, South 77 degrees 30 min- utes East, 91.25 feet to a post at line of land now or formerly of William Shook; thence by the same, South 12 degrees 30 minutes West, 15.100 feet to a stake at line of land now or formerly of Edwin M. Rankin (No. 149 North Bedford Street); thence by the same, North 77 degrees 30 minutes West, 61.00 feet to a spike; thence by the same, North 50 degrees 24 minutes 20 seconds West, 2.41 feet to the southwestern corner of the house on the land herein conveyed; thence by said house, North 77 degrees 30 minutes West, 28.10 feet to a spike on the eastern side of North Bedford Street; thence by said street, North 12 degrees 30 minutes East, 13.75 feet to the place of BEGINNING. BEING improved with a dwell- ing house known as 151 N. Bedford Street, Carlisle, Pennsylvania. TOGETHER with a right of ingress and egress over a 2.20 foot wide alley- way over property to the south hereof for a distance of 30.51 feet. BEING KNOWN AS: 151 NORTH BEDFORD STREET CARLISLE, PA 17013. PROPERTY ID NO.: 02-21-0318- 193. TITLE TO SAID PREMISES IS VESTED IN Helen Gibble by deed from Marlin L Barbour and Frances C. Barbour, husband and wife dated 12/20/05 recorded 12/21/05 in Deed Book 272 Page 2273. S