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Home My WebLink About07-2422UDREN 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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee CIVIL DIVISION 51 East Bethpage Road Plainview, NY 11803 :Cumberland County Plaintiff V. Joshua Mitten 2065 Ritner Highway € NO. Carlisle, PA 17013 Defendant(s) 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 TARE 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 Association 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 DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 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 Association 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: Deutsche Bank National Trust Company, as Trustee 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: 2065 Ritner Highway MUNICIPALITY/TOWNSHIP/BOROUGH: West Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 7/14/06 DATE RECORDED: 7/21/06 BOOK: 1959 PAGE: 1488 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 4/13/07: Principal of debt due $213,954.44 Unpaid Interest at 7.875%* from 11/1/06 to 4/13/07 (the per diem interest accruing on this debt is $46.00 and that sum should be added each day after 4/13/07) 7,608.40 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy ate charge of $77.73 should be added in accordance with the terms of the note each month after 4/13/07) 365.47 Recoverable Advance 333.75 Attorneys Fees (anticipated and actual to 50 of principal) 10.697.72 TOTAL $233,564.78 *This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 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 $233,564.78 plus interest, costs and attorneys fees as more fully set forth in the complaint, and for foreclosure and sale of the Mortgaged premises. t/ UV\-, Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 All *a certain tract of land oil m in went Peomsboro Towns* Cun*a and Cotmty, Pun syWania, bounded and damilmd as lifibows: . BEGROWG at a point in the north A&-cf-way Um of a public road, known as the Govemm Ritner Ighway, which bighway is also ]mown m U.S. H>Sbasy No. 11, said point bang &*a t from *c iutteraection of the above named north rigb6of--way line with lute west properly line of the land now or fo®edy of Clamance F. and Edna E. Keller, by the following course and distamtx, namely, nor& surly (60) degrees twatty font (24) minutes east (erroncomly amused in puevioas deed), two hundred and e3abt? (200.8) feet; throes along do said north tight-of-way lino by a Iim curving to dw M whose leog chord bas the Following beating amd distaoee, to wit, north fifty-maven (57) degrees six (6) miemeea east, two handled foal (204) he to an iron pipe; tbemoa alma other property formerly of do said CLremx F. Keller and Edna E. Kollar, bis wik and now or fiermedy of H.H. Snyder the f 3Rvwiog ft m cautses >md disu mms, to wit, north twenty three (23) degrees fifly-ome.(Si) mimeses west four bnmdmd hirty4hrm and esig . tooft (443.8) feet to m iron pipe; somh fifty-eight (38) degrees fifty-five (55) minutes weal, cm hvo&ed seventy (170) feet to an im pipe, south nkwwm (19) doorees W five (55) udsm tes east, four hundred Ecx1y-sic and two taatha (446.2) int to a point, the PLACE OF BEC MING. CONTAINING one and many-one lmmdredths (1.91) scars of land, be the wane more or km HCW .Q SERVICrINC DF785 February 5, 2007 JOSHUA MITTEN 2065 RITNER HWY CARLISLE, PA 17013 HOMEOWNERS NAME(S): JOSHUA MITTEN PROPERTY ADDRESS: 2065 RITNER HWY CARLISLE, PA 17013 LOAN ACCOUNT NUMBER: 0325479590 CURRENT LENDER/SERVICER: HomEq Servicing 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 EMERGENCY 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 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 Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call 717-780-1869) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HomEq Servicing is a debt collector. HomEq is attempting to collect a debt and any information obtained will be used for that purpose. THIS NOTICE CONTINUES ON THE NEXT PAGE EXHIST A HOMEOWNERS 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 PROVISION OF THE HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time you must arrange for and attend a "face-to-face" meeting with one of the consumer counseling agencies listed at the end of this notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer counseling agencies for the county in which your p=e!ly is located are set forth at the end of this notice. It is necessary to schedule only one face-to-face meeting. Advise this lender/servicer immediately only your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later in this notice (see the 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/servicer, 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 completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION Available funds for emergency mortgage assistance are very limited. Funds will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency (The 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 Agency of its decision on your application. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 3 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT The MORTGAGE debt secured by your property located at: 2065 RITNER HWY CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: 1. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Number of Payments Delinquent: 3 b) Delinquent Amount Due: $4,663.65 c) Late Charges: $210.01 d) Recoverable Corporate Advances: $2.00 e) Other Charges and Advances: $0.00 f) Less funds in Suspense: ($0.00) g) Total amount past due as of (due date): $4,875.66 2. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable) HOW TO CURE THE DEFAULT You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER/SERVICER, WHICH IS $$4,875.66 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashiers check, certified check; or money order made uayable to HomEa and sent to: Regular Mail HomEq Servicing P. O. Box 70829 Charlotte, NC 28272 - 0829 Overnight Attn: Cash Central NC 4726 1100 Corporate Center Drive Raleigh, NC 27607-5066 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this notice: (Do not use if not applicable) THIS NOTICE CONTINUES ON THE NEXT PAGE Page 4 IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within THIRTY (30) days of the date of this notice, the lender/servicer intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the opportunity to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS OF THE DATE OF THIS LETTER, HomEq Servicing also intends to instruct its attorneys to start a 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 off the mortgage debt. If the lender/servicer refers your case to its attorneys, but you cure the delinquency before the attorney begins legal proceedings against you, you will still be required to pay the reasonable attorneys fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys fees actually incurred by the servicer even if they are over $50.00. Any attorneys fees will be added to the amount you owe the lender/servicer, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be reauired to Dav attorneys' fees. OTHER LENDER/SERVICER REMEDIES The lender/servicer may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not 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 Sheriff s Sale. You may do so by paving the total amount then past due plus any late charges other charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as Mecified in writing by the lender/servicer 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 if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE It is estimated that the earliest date that such Sheriff s sale of the mortgaged property could be held would be approximately five (5) 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. 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/servicer. HOW TO CONTACT THE LENDER/SERVICER BY TELEPHONE OR MAIL: Name of Lender/Servicer HomEq Servicing Contact Name PA Housing Response Specialist Address 4837 Watt Avenue, North Highlands, CA 95660-5170 Attn: PA Housing Response Team Telephone Number: 1-800-795-5125 FAX Number (916) 339-6940 for use by local counseling agency to notify HomEq that the homeowner met with the agency. EFFECT OF SHERIFF'S SALE You should realize that a Sheriff s sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender/servicer at any time. ASSUMPTION OF MORTGAGE You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 5 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 THE RIGHT TO CURE YOUR DEFAULTS ANY MORE THAN THREE TIMES IN A CALENDAR YEAR;) • TO ASSERT THE NON-EXISTENCE 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/SERVICER; AND/OR • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED TO THIS LETTER If you received a discharge of the account through the Bankruptcy Court and if your account has not been reaffirmed, the acceleration and sale will not result in your being held personally liable for the debt and this letter is not an attempt to collect a personal debt. However, failure to pay the delinquent balance is necessary to avoid foreclosure. You are notified that this default, and any other legal action that may occur as a result thereof, may be reported by HomEq to one or more credit reporting agencies. Please take appropriate action with respect to the important matters discussed herein. Sincerely, HomEq Servicing Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Effective 8/18/2005 at 10:05:07 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 1 (888) 511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1 (800) 342-2397 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. ?-At? Mark J. Udren, ESQ IRE UDREN LAW OFFICES, P.C. w ? 1 O 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 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee :CIVIL DIVISION 51 East Bethpage Road :Cumberland County Plainview, NY 11803 Plaintiff :MORTGAGE FORECLOSURE V. s Joshua Mitten :NO. 07-2422 CIVIL TERM 126 Meals Drive 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) Joshua Mitten 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 Interest Per Complaint From 4/14/07 to 6/16/07 Late charges per Complaint From 4/14/07 to 6/16/07 $233,564.78 2,944.00 233.19 TOTAL $236,741.97 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 hereto. LAW OFFIe2E'Sti P. C. k J. Nd3p(!n, ESQUIRE orney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE;` I?.t?Q_ ?, a.CSO? PRO PRO UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Enquire ATTY I.D. NO. 06302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY SILL, NJ 08003 856-669-5600 r eadi a¦auerea c Deutsche Bank National Trust Company, as Trustee Plaintiff V. Joshua Mitten Defendant(s) TO: Joshua Mitten 126 Meals Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-2422 Civil Term DATE of Notice: June 5, 2007 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 Association 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 TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O 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 SERVICIO, 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 Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRA ICES ACT, THIS LAW FIRM IS DREW= TO BE A DEBT COLLECTOR AND THIS IS AN A T TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL IRE USED FOR THAT PURP SE. M--. C-- ..aa, vwyaw?,.-... W rest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 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 Dleadinas@udren.com Deutsche Bank National Trust Co., as Trustee Plaintiff V. Joshua Mitten Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-2422 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN 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 Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age. Residence: Employment: Sworn to and subscribed before me this 16th day f June, 2007. No ry ub ic, Joshua Mitten Over 18 As captioned Unknown Name:U `/MARK J. UDREN, ESQ. Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. Zo% ILI - w x _y l"r 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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee CIVIL DIVISION Plaintiff ;Cumberland County V. =MORTGAGE FORECLOSURE Joshua Mitten Defendant(s) NO. 07-2422 CIVIL TERM To: Joshua Mitten 126 Meals Drive Carlisle, PA 17013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment- has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin ` ?/P 67 Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment 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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee :CIVIL DIVISION Plaintiff :Cumberland County V. ;MORTGAGE FORECLOSURE Joshua Mitten ENO. 07-2422 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $236,741.97 Interest From 6/17/07 7,912.00 to Date of Sale 12/5/07 ongoing Per Diem of 46.00 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. rk J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF rim u? r?rn- x ? C C ? ti? h C C' i ' ? CJ • iE « r ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-2422 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., AS TRUSTEE, Plaintiff (s) From JOSHUA MITTEN (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 $236,741.97 L.L. $.50 Interest FROM 6/17/07 TO DATE OF SALE 12/5/07 - ONGOING PER DIEM OF $46.00 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $7,912.00 Atty's Comm % Atty Paid $151.80 Plaintiff Paid Date: JUNE 18, 2007 (Seal) Due Prothy $2.00 Other Costs / &' h - Curtis . Long, Pr notary 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 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 Deutsche Bank National Trust =COURT OF COMMON PLEAS Co., as Trustee :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Joshua Mitten '_NO. 07-2422 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. UDREN LAW OFFICES, P.C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF C > CD co } f 6.f 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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee ;CIVIL DIVISION Plaintiff :Cumberland County V. 'MORTGAGE FORECLOSURE Joshua Mitten :NO. 07-2422 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Joshua Mitten 126 Meals Drive Carlisle, PA 17013 Your house (real estate) at 2065 Ritner Highway, (West Pennsboro Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $236,741.97, 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.) 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 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 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 Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ?.?+ r°.? ?J ?. t ? .?., ?,. "S S _ «.._ _? i'f .. (....i '.... T" ,J.? ?..?' "`` 6. L 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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Joshua Mitten :NO. 07-2422 CIVIL TERM Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee, 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: 2065 Ritner Highway, (West Pennsboro Township) Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Joshua Mitten 126 Meals Drive 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 Deutsche Bank National 51 East Bethpage Road Trust Co., as Trustee Plainview, NY 11803 Mortgage Electronic P.O. Box 2026, Flint, MI 48501-2026 Registration Systems, Inc. 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 Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North 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 2065 Ritner Highway (West Pennsboro Township) 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: June 16, 2007 'kl J. Udren, ESQ. torney for Plaintiff JL CASE NO: 2007-02422 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF ENNSYLVANIA: COUNTY OF CUMBER AND DEUTSCHE BANK NA IONAL TRUST VS MITTEN JOSHUA Cumberland Coun says, the withi MITTEN JOSHUA Sheriff or Deputy Sheriff of ,Pennsylvania, who being duly sworn according to law, COMPLAINT - MORT FORE was served upon the DEFENDANT I at 1719:00 HOURS, on the 15th day of May , 2007 at 126 MEALS DRIVE CARLISLE, PA 1713 by handing to a true and attekted copy of COMPLAINT - MORT FORE and at the sarr Additional Com 2065 RITNER HI together with time directing His attention to the contents thereof. nts Y APPEARS TO BE VACANT. Sheriff's Cost Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 00 32.80 Sworn and Subs ibed to before me this day of , So Answers: R. Thomas Kline 05/16/2007 UDREN LAW OFFICE By. put Sheriff A.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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee :CIVIL DIVISION 51 East Bethpage Road :Cumberland County Plainview, NY 11803 Plaintiff V. Joshua Mitten 126 Meals Drive :NO. 07-2422 CIVIL TERM Carlisle, PA 17013 Defendant(s) 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. Y w _ This Affidavit is made subject to th p na tie o 18 Pa S. Section 4904 relating to unsworn falsification to au ho it'es. Dated: November 8, 2007 LAW OFFICES, P. C. BY :\J Mark J. Udren, Esquire 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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Joshua Mitten :NO. 07-2422 CIVIL TERM Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee, 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: 2065 Ritner Highway, (West Pennsboro Township) Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Joshua Mitten 126 Meals Drive 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 of record: Name Deutsche Bank National Trust Co., as Trustee the last recorded holder of every mortgage Address 51 East Bethpage Road Plainview, NY 11803 Mortgage Electronic P.O. Box 2026, Flint, MI 48501-2026 Registration Systems, Inc. HSBC Bank USA, NA as Trustee 2476 Stateview Boulevard for Home Equity Loan Trust Fort Mill, SC 29715 Series ACE 2005-HE5 c/o Francis S. Hallinan, Esquire One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 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 Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North 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 2065 Ritner Highway (West Pennsboro Township) 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 P C.S. sec. 4904 relating to unsworn falsification to authorikes/-\ OFIkICES, /P . C . DATED: November 8, 2007 Dark J. Udren, Esquire Attorney for Plaintiff 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 Deutsche Bank National Trust Co., as Trustee Plaintiff V. Joshua Mitten Defendant(s) ATTORNEY FOR PLAINTIFF € COURT OF COMMON PLEAS CIVIL DIVISION € Cumberland County NO. 07-2422 CIVIL TERM TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Joshua Mitten PROPERTY: 2065 Ritner Highway (West Pennsboro Township) Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 5. 2007, at 10:00 am, at the Commissioners Hearing Room, 2"d 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 that 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 (D -ja Li Vl and Cc fig o O > ` • Q c c .a ? o•- a u,) cgqt2 c!!??EMo EV 0 d) =y 4) ED= i EE C6 LL_ t mron= ?r EE 0 Q Vl m Q? V C C C? ?O?WOC n ?L m tnU_ = c Ea W c£ E yp? O A CA,. m m c vo?m-o m m i^ .0-- Cy • LL IX ?%1? o d lE ? O Ol T p= T c m G' 'D d m W._ E d o a-n o , p08 (CC C) . oG?cO.E=o0 m mho 4G ?r? N x? y C0 0 m U C N•- N? V ?E .ern ?m? p Q v ca ?l O O? ? o-mac o E N C l6 woE?0% m g m ?; is O U m N W Eotm&v OCmT O G (D ,_ .- ...?.... - CDC O O- tow C • E 05 d? U? N A w N C y O ?l $ Qli ONM'?O•'.O?- o ° C= tii N d C D ?? U? 4 t Q .., ... ay m= c ac O 4 Q? 4 C -. 2 C OC CL CL L L y -0 rn o -Y y _ _ p) ?(D - o C, C, U) a °oVEc El D m 4) ca 0 m lOL 2U m c ° - • S- a . o? E E a 2 & 2 •E ` p r : crrma,E? 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O EC W m m O a m (? Z O E s N 00 W p V o O 2 =m m Z° y ?' C) W W a v 0U) (° LL U) E w a) CD o C6 0 p0 - y ? ? Ew a V _ U) w Z w W ,m 1° i Nc7 y c y N u.pF- LL U) Z m (D to o < moa i Q? L J Z N Z N 0 a0 N J_ QWG= L QW Z)Q? QW aci< ?Qaa o 0 a ( A J L Y N Y N m N m E ZVO? W O? ° m cm°> ma ` ) cmc•- a) v Z> a, W cc (nU 2 m m 00,= :5 u Z co v,?_ U) c 5 m U) o n p d i-- a 1: 3: F= LE (L t ? N U y CD A N O a C E ¢Z C `gym O O N N E 'E r_ LO LO O? n aci m m c o o U 2 CD _ C m E ?p U) c d Z Q y c J 1 N cr) IT r ° N M 4T Ln (D r- 00 0) r e- {- J d IL wr ° m Y .a d a O L) d tl1 E L O U. rn U- ti ti 00 M O Li co a EXHIBIT A Deutsche Bank National Trust Co., as Trustee In the Court of Common Pleas of VS Cumberland County, Pennsylvania Joshua Mitten Writ No. 2007-2422 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 28, 2007 at 1700 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: Joshua Mitten, by making known unto Miriam Mitten, mother of Joshua Mitten, at 126 Meals Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2007 at 10 15 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joshua Mitten located at 2065 Ritner Highway, 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: Joshua Mitten by regular mail to his last known address of 126 Meals Drive, Carlisle, PA 17013. This letter was mailed under the date of October 12, 2007 and never returned to the Sheriffs Office. So Anslyeo 4 ?K?440 R. Thomas Kline, Sheriff B Real Estate ergeant "HIBIT B C ^ ^? c? . ' v 'ri ? ? y .? Z ? ? ? ? N ~"1 :: j C ? - .?, -?; .? ? !`? -- ._ ? _-. =? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Deutsche Bank National Tr Co Tr is the grantee the same having been sold to said grantee on the 5th day of Dec A.D., 2007, under and by virtue of a writ Execution issued on the 18 day of June, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 2422, at the suit of Deutsche Bank National Trust Co Tr against Joshua Mitten is duly recorded as Instrument Number 200746882. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this .20 day of A.D. a?ff ®7 Recorder of Deeds Recorder of Duds, Cumbe(WW County. Cad*. PA My Coe 1Won Eou ft Fast Monday Of Jan. 2010 Deutsche Bank National Trust Co., as Trustee In the Court of Common Pleas of VS Cumberland County, Pennsylvania Joshua Mitten Writ No. 2007-2422 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 28, 2007 at 1700 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: Joshua Mitten, by making known unto Miriam Mitten, mother of Joshua Mitten, at 126 Meals Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2007 at 10 15 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joshua Mitten located at 2065 Ritner Highway, 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: Joshua Mitten by regular mail to his last known address of 126 Meals Drive, Carlisle, PA 17013. This letter was mailed under the date of October 12, 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 December 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 Deutsche Bank National Trust Company as Trustee under Pooling and Servicing Agreement dated as of December 1, 2006 Securitized Asset Backed Receivables LLC Trust 2006- WM4 Mortgage Pass-Through Certificates, Series 2006-WM4. It being the highest bid and best price received for the same, Deutsche Bank National Trust Company as Trustee under Pooling and Servicing Agreement dated as of December 1, 2006 Securitized Asset Backed Receivables LLC Trust 2006-WM4 Mortgage Pass-Through Certificates, Series 2006-WM4, of 51 East Bethpage Road, Plainview, NY 11803, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,039.15. Sheriff s Costs: Docketing $30.00 Poundage 20.38 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 Surcharge 20.00 Law Journal 407.00 Patriot News 367.25 Share of Bills 14.92 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $1,039.15 ? /al ?i f o So Answers: r R. Thomas Kline, Sheriff loo, IJ, B Real Estate ergeant CIPX as a43?o 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 Deutsche Bank National Trust =COURT OF COMMON PLEAS Co., as Trustee 'CIVIL DIVISION Plaintiff ::Cumberland County V. ;MORTGAGE FORECLOSURE Joshua Mitten :NO. 07-2422 CIVIL TERM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee, 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: 2065 Ritner.Highway, (West Pennsboro Township) Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Joshua Mitten 126 Meals Drive 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 Deutsche Bank National Trust Co., as Trustee 51 East Bethpage Road Plainview, NY 11803 Mortgage Electronic Registration Systems, Inc. P.O. Box 2026, 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 Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any in terest in the property which may be affected by the sale: Name ACd s s Tenants/Occupants 2065 Ritner Highway (West Pennsboro Township) Carlisle, PA 170.13 I verify that the statements made in this affidavit are true and correct to the best of my pe rsonal knowledge or information and belief. I understand that f alse statements herein are made subject to the penalties of 18 Pa..C.S. sec. 4904 relating to unsworn falsification to aut horities. UDREN LAW OFFICES, P.Q. DATED: June 16, 2007 J. Udren, ESQ._ torney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL,` NJ 08003-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee €CIVIL DIVISION Plaintiff ":Cumberland County V. :MORTGAGE FORECLOSURE Joshua Mitten NO. 07-2422 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Joshua.Mitten 126 Meals Drive Carlisle, PA 17013 Your house (real estate) at 2065 Ritner Highway, (West Pennsboro Township) Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $236,741.97, 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 MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. Thesale 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.) 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 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`sc"hedule 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 Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 .Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 Ali that cataia tract of land sitneme in wet Plow Township, Cmnberkmd County, Penm4vanie, bounded and d=crUwd as f Mown BEGBWWiG at a point in the meth rigt-of-way lid of a pub is road, imam w the Govemor Rimer Ioway. which big mmy is also Immm as U.S. mom" No. 11, sdd point being disaam ftom the mlimieation of the above named meth ti& of_wgy hme with the went psopcM him ofam hand now at foomaiy of Cbn mae F. and Edna E Keller, by the following am= and dia met, comely, north slaty (60) dep om twaomy-fm (24) minuets east (eacamusly c nkwd is pravions deed), two hundred sad e4ftt4aatbs (200.8) f ut thence along the aid north d&-cf-way line by a hide cuavbg to as kdt whose long chord less the fohlowing bearing ad tiisbnoe, iv v4% north flfly-sovaa (s7) (6) mhNdw .taro r-P04) feat to an ievm piM *mm ObM o dw property formerly of the add CLeeoce F. Kdlw and Edna E. KeW, his wife, and ww or f rawly of B.H. Snyder, the fallowing tmse ocarina smd disumm. to wit, with twenty then M dignm Sty-m.(Sl) voloulm west Sm hsmdmd Eoety-free smd dobt- land- (443.8) feet to an iron pipe; scan fitly of t (58) d gram Say-five (SS) mipeaee wart, one bAWred seventy (1710) feet to m imn pipe, loath ahwo m (19) dgpm W five (SS) nsbMw cost. four lamdmd forty-Ak and two-tmebs (446.2) he to a point, the PLACE OF BBQII4XN0. CONTARMO one and ninety-one hundrvftw (1.91) acres of lms4 be ft same nsore cr hers. BEING KNOWN AS: 2065 RITNER HIGHWAY, (WEST PENNSBORO TOWNSHIP) CARLISLE, PA 17013- PROPERTY ID NO.: 46-08-0581-018 TITLE TO SAID PREMISES IS VESTED IN JOSHUA MITTEN, A SINGLE MAN BY DEED FROM DEBORAH L. MULLEN EXECUTRIX OF THE ESTATE OF THOMAS F. ALEXANDER, JR., DECEASED DATED 10/31/05 RECORDED 11/3/05 IN DEED BOOK 271 PAGE 3990. • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-2422 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., AS TRUSTEE, Plaintiff (s) From JOSHUA MITTEN (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 $236,741.97 L.L. $30 Interest FROM 6/17/07 TO DATE OF SALE 12/5/07 - ONGOING PER DIEM OF $46.00 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $7,912.00 Atty's Comm % Due Prothy $2.00 Atty Paid $151.80 Other Costs Plaintiff Paid Date: JUNE 18, 2007 Curtis X. Long, on tal (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 I % . . AAA an mn m Real Estate Sale # 18 On August 3, 2007 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA Known and numbered as 2065 Ritner Highway, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 3, 2007 By: LIO d Yi?tc.G ?i?, Real Esta Sergeant :Z 0 1 Z.i' i ?t The Patriot-News Co. 'A •.- ' 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE 14C Pahiot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10!24/07 a?•a? i - 10/31/07 wr% NO. 20"4m'2 *aT 4 grs 80* 11107/07 ce" , VA . ........ ........? be Sworn to and r me this 30 day of November, 2007 A.D. AD 60 "e ails IM of W IM0 d OW ptinbom ToRaA 001MANd Cmi% ramytrsaia, 1t umm at &%&W ` u >? - i a BEGROEM at a pails 9* OW& rim N ary Public Tay Am d a psb&c mad. knms as Ibe (ioveraor Inn" aom sly ; a aW known as us. EEO" No. it pains being 4599 Enos the isle+taeelkw above COMMONWEALTH OF PENNSYLVANIA Based me Lae idl* ww 'lire a rie T »o? at of gi Notarial Seal James L G * N y r ap a , otary public C1aaoe F. aad &W B Isdler, by ' (qty Of Harrft", paup * Courtly COINS! ad W00! 110116h My Commission EWres June 2, 2008 dWW tw 44-fssr (U) to SOM OW (waseoady aaarhd ! p deed, 4xo Member, Pennsylvania Associstlon ;Molar as baardapd aad eigl , (M) >ec>4aaae . ' two ibe aw mob iw bk by a fir cs9ing b toe idt Muse beg dafl? baa the 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. 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: October 26, November 2 and November 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 18 is Writ No. 2007-2422 Civil t Deutsche Bank National Trust Co., as Trustee I vs. Joshua Mitten I Atty.: Mark Udren t DESCRIPTION All that certain tract of land I situate m West Pennsboro Township, 'Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the north right-of-way line of a public road, known as the Governor Ritner Highway, which highway is also 'known as U.S. Highway No. 11, said point being distant from the intersec- tion of the above named north right- 'of-way line with the west property line of the land now or formerly of Clarence F. and Edna E. Keller, by L' a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 9 day of November, 2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010