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HomeMy WebLinkAbout07-3146MARTHA E. VON ROSENSTIEL, P.C. 4Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 #20590-CS CFC Attorney for Plaintiff BANK OF NEW YORK TRUST COMPANY : COURT OF COMMON PLEAS NA SUCCESSOR TO JPMORGAN CHASE : CUMBERLAND COUNTY BANK AS TRUSTEE 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 : Case No: 01 --314L. Plaintiff VS. DENNIS R. COLLIER AND DONNA L. COLLIER 5 Forest Avenue Marysville, PA 17053 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 a sentar 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 a visado que si usted no se defiende, la corte toma ra 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 provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 -- 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. 'MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 BANK OF NEW YORK TRUST COMPANY NA SUCCESSOR TO JPMORGAN CHASE BANK AS TRUSTEE 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff VS. Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Case No: 7 - DENNIS R. COLLIER AND DONNA L. COLLIER 5 Forest Avenue . Marysville, PA 17053 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee, a bank organized and existing under federal law, with offices for the conduct of business at 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. Defendants, Dennis R. Collier and Donna L. Collier are the mortgagors and real owners of premises 5 Forest Avenue, Marysville, PA 17053, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to 'Mortgage Electronic Registration Services, Inc. as Nominee for WMC Mortgage Corporation on August 31, 2005, which mortgage was recorded on September 2, 2005 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1921 Page 2594, secured on premises 5 Forest Avenue, Marysville, PA 17053 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the Plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from August 01, 2006 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $71,284.88 Interest from 7/2/2006to 5/21/2007 At $13.18 per diem $ 3,988.36 Accrued late charges to 5/21/2007 $ 209.88 Accrued Escrow deficit to 5/21/2007 $ 453.00 NSF Fees $ 20.00 Attorney's fee (5% of unpaid Principal Balance) $ 3,564.24 Title Information Certificate $ 515.00 Photostats and Postage $ 50.00 Notarizations $ 10.00 TOTAL $80,087.36 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to the Sheriff's sale, reasonable attorney's fees will be charged based on work actually performed. 10. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). , plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $80,087.36, plus per diem interest at $13.18 from May 22, 2007 to the date of judgment plus costs thereon. Martha E. Von Rosenstiel Attorney for Plaintiff VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, verifies that she is the attorney for the plaintiff in the foregoing action; that she is authorized to make this verification on behalf of plaintiff; and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. This verification is being executed by the attorney for plaintiff in accordance with Pa R.C.P. 1024(c) as a signed verification could not be obtained by plaintiff within the time allowed for filing of the pleading. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. LEGAL DESCRIPTION ALL THAT CERTAIN ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Overview, East Pennsboro Township, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which point is the northeast corner of Forest Avenue and North Second Street; thence eastwardly along the northern side of North Second Street thirty-five and four- tenths (35.4) feet to a point; thence northwardly and for part of the distance through the partition wall of a double two and one-half (21/2) story frame dwelling and beyond one hundred fifty-three and three-tenths (153.3) feet to a stake; thence westwardly forty-four and five-tenths (44.5) feet to Forest Avenue; thence southwardly along Forest Avenue one hundred fifty-six and two-tenths (156.2) feet to the point of Beginning. HAVING THEREON ERECTED a two and one-half (2 1/2) story frame house which was unnumbered, but is now numbered 5 Forest Avenue, Marysville, Pa. 17053. IT BEING Lot No. 115 and the eastern part of Lot No. 114 on the Plan of Lots known as Overview, East Pennsboro Township, Cumberland County, Pennsylvania, as laid out by D.S. Seitz, January 1910, and recorded in the Recorder's Office of Carlisle, Pennsylvania, in Plan Book 1, Page 53. TAX PARCEL NUMBER: 09-11-3002-012 EXHIBIT -- ? Wilshire° 01 / 10/2007 L1 78D COLLIER, DENNIS R 5 FOREST AVE MARYSVILLE, PA 17053 ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Phone 888.917.1052 888.917.1052 Fax 503.952.7476 Web site www.wcc.ml.com This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Spgciffc 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 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INEDITAMENTE 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 (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. I IOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D EXHIBIT -? Wilshire Credit Corporation Payments P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence P.O. Box 8517 Portland, OR 97207-8517 COLLIER, DENNIS R Page 2 DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME: PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT SERVICER: COLLIER, DEWS R 5 FOREST AVE MARYSVILLE, PA 170539625 2313723 CHASE Wilshire Credit Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: in Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D COLLIER, DENNIS R Page 3 APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after they receive 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 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 (Brim it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 5 FOREST AVE MARYSVILLE, PA 170539625 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $2,798.82 Late Charges $163.24 Other Charges $68.82 Suspense Amount -$356.01 TOTAL $2,674.87 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,674.87 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D COLLIER, DENNIS R Page 3 APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION •- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after they receive 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 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 held by the above lender on your property located at: 5 FOREST AVE MARYSVILLE, PA 170539625 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $2,798.82 Late Charges $163.24 Other Charges $68.82 Suspense Amount -$356.01 TOTAL $2,674.87 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,674.87 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUFFCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D COLLIER, DENNIS R Page 4 (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: Wilshire Credit Corporation, P.O. Box 7195, Pasadena, CA 91109-7195. IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise it's rights to accelerate the mortgage debt. This means that the entire outstanding balance of the debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct it's attorneys to start legal action to foreclose upon your morteaeed 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 refers your case to it's 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 actually incurred by the lender even if they exceed $50.00. The 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) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO 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 Drevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by ggying the total amount then past due, any late or other charges then due, reasonable attorney's fees any costs connected with the foreclosure sale. my other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Wilshire Credit Corporation Address: Pa ents: P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence: P.O. Box 8517 Portland, OR 97207-8517 Phone: Toll Free: 888.917.1052 Fax Number: 503.952.7476 (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collmdon Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D COLLIER, DENNIS R Page 5 Contact: Loan Servicing EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs 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 THE MORTGAGE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ATTACHED IS THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY If you have any questions regarding this matter, please do not hesitate to contact us at our toll free number above. Sincerely, Loan Servicing Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D Vilshire- MV 0 L178D COLLIER, DONNA L 5 FOREST AVE MARYSVILLE, PA 17053 ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Phone 888.917.1052 888.917.1052 Fax 501952.7476 Web Site WWW.WCc.ml.com The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice eLxRlains how the pro agr m 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 Agengy. 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 A ency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869.) This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INEDITAMENTE 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 (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D Wilshire Credit Corporation Payments P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence P.O. Box 8517 Portland, OR 97207-8517 COLLIER., DONNA L Page 2 DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME: COLLIER, DENNIS R PROPERTY ADDRESS LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT SERVICER: 5 FOREST AVE MARYSVILLE, PA 170539625 2313723 CHASE Wilshire Credit Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE_ ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the vrovertv_is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D COLLIER, DONNA L Page 3 APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after they receive 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 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 uo to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 5 FOREST AVE MARYSVILLE, PA 170539625 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $2,798.82 Late Charges $163.24 Other Charges $68.82 Suspense Amount -$356.01 TOTAL $2,674.87 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,674.87 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: in Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refine to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D COLLIER, DONNA L Page 4 (30) DAY PERIOD. Payments must be made either by.cashiees check certified check or money order made payable and sent to: Wilshire Credit Corporation, P.O. Box 7195, Pasadena, CA 91109-7195. IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise it's rights to accelerate the mortgage debt. This means that the entire outstanding balance of the debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct it's 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 off the mortgage debt. If the lender refers your case to it's 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 actually incurred by the lender even if they exceed $50.00. The 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) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO 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 Sheriffs Sale. You may do so by paving the total performing another requirements under the mortgage. Curing your default in the manner set forth in notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Wilshire Credit Corporation Address: Pa ents: P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence: P.O. Box 8517 Portland, OR 97207-8517 Phone: Toll Free: 888.917.1052 Fax Number: 503.952.7476 (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D COLLIER, DONNA L Page 5 Contact: Loan Servicing EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs 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 THE MORTGAGE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ATTACHED IS THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY If you have any questions regarding this matter, please do not hesitate to contact us at our toll free number above. Sincerely, Loan Servicing Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THF. COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D p ral V or F ra C..) ca TI 0 A #20590CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF NEW YORK TRUST COMPANY NA SUCCESSOR TO JPMORGAN CHASE BANK AS TRUSTEE V. : NO. 07-3146 Civil Term DENNIS R. COLLIER AND DONNA L. COLLIER PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Dennis R. Collier and Donna L. Collier for want of an answer. (X) Assess Damages as Follows Debt $ 80,087.36 Interest from 5/22/07 to 6/27/2007 At $13.18 per diem $ 487.66 Total $ 80,575.02 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 Attorney for Plaintiff Martha E. Von Rosenstiel Attorney I.D. #52634 Print/Type Name and ID Number Phone: (610) 328-2887 This da of JU-0E-- 2007 'ud ent is entered in favor of the Plaintiff and against Defendant(s), Dennis R. Collier and Donna L. Collier by default for want of an answer and damages assessed at the sum of $80,575.02 as per the a ve certificati 'Prothonotary, Cumberland County / 1* Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 #20590-SS CTD Attorney for Plaintiff BANK OF NEW YORK TRUST COMPANY : COURT OF COMMON PLEAS NA SUCCESSOR TO JPMORGAN CHASE : CUMBERLAND COUNTY BANK AS TRUSTEE c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff vs. DENNIS R. COLLIER AND DONNA L COLLIER 5 Forest Avenue Marysville, PA 17053 Defendant TO: Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 : Case No: 07-3146 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 NOTICE TO A 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Martha E. Von Rosenstiel Attorney for Plaintiff Dated: June 15, 2007 r #20590CFJ-DN Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 Attorney for Plaintiff BANK OF NEW YORK TRUST COMPANY NA SUCCESSOR TO JPMORGAN CHASE BANK AS TRUSTEE Plaintiff VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY : No: 07-3146 Civil Term DENNIS R. COLLIER AND DONNA L. COLLIER Defendant(S) NON MILITARY AFFIDAVIT Martha E. Von Rosenstiel, Esquire hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 5. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel Attorney for Plaintiff Dated: June 27, 2007 ?QC (1? r 8 ZRI ;:TD - 41 r c 17? . s «d KJ ?a rv CJ v -3 .) 0 y l'.5 tai rn -? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA17053 Curt Long, Prothonotary BANK OF NEW YORK TRUST COMPANY NA COURT OF COMMON PLEAS SUCCESSOR TO JPMORGAN CHASE BANK AS CUMBERLAND COUNTY TRUSTEE PLAINTIFF VS. NO: 07-3146 CIVIL TERM DENNIS R. COLLIER AND DONNA L. COLLIER DEFENDANT(S) 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 in the amount of $80,575.02 on June 27, 2007. Curt Long Prothonotary ?X Judgment by Default A F1 Money Judgment Judgment in Replevin ` Judgment for Possession F] Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Martha E. Von Rosenstiel, Esquire at this telephone number: 610-328-2887. PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee V. NO. 07-3146 Civil Term Dennis R. Collier and Donna L. Collier Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $80,575.02 INTEREST from 6/28/07 to 12/5/07 At $13.25 per diem $ 2,133.25 (Costs to be added) p. h ? o C d ra C O C C o a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3146 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF NEW YORK TRUST COMPANY NA SUCCESSOR TO JPMORGAN CHASE BANK AS TRUSTEE, Plaintiff (s) From DENNIS R. COLLIER AND DONNA L. COLLIER (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 $80,575.02 L.L. $.50 Interest FROM 6/28/07 TO 12/5/07 AT $13.25 PER DIEM -- $2,133.25 Atty's Comm % Due Prothy $2.00 Atty Paid $177.40 Plaintiff Paid Date: JULY 23, 2007 (Seal) Other Costs REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P.O.BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 1ieputy Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff Bank of New York Trust Company NA COURT OF COMMON PLEAS successor to JPMorgan Chase Bank as Trustee : CUMBERLAND COUNTY c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 Plaintiff VS. Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Defendants No: 07-3146 Civil Term CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) Asa result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of 30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the 1 Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff for any false statements given herein. Attorney for Plaintiff Dated: July 19, 2007 __ 1 J ?? W? D3 Martha E. Von Rosenstiel, P.C. Mactfial' Von Rosenstiel 649 South Avenue, Unit 7 P.Q. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff Bank of New York Trust Company NA COURT OF COMMON PLEAS successor to JPMorgan Chase Bank as Trustee : CUMBERLAND COUNTY c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 Plaintiff : No: 07-3146 Civil Term VS. Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Defendants AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 5 Forest Avenue, Marysville, PA 17053. 1. Name and address of owners(s) or reputed owner(s) Dennis R. Collier 5 Forest Avenue Marysville, PA 17053 Donna L. Collier 5 Forest Avenue Marysville, PA 17053 2. Name and address of defendant(s) in the judgment: Dennis R. Collier 5 Forest Avenue Marysville, PA 17053 Donna L. Collier 5 Forest Avenue Marysville, PA 17053 3. Name and address of the last recorded holder of every mortgage of record: Mortgage Electronic Registration Systems, Inc, as nominee for WMC Mortgage Corp. •' P.O. Box 2026, Flint, MI 48501-2026 4. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the United States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128-1100 Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Bureau of Compliance Clearance Support Section/ATTN: Sheriff's Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 OCCUPANTS/TENANTS 5 Forest Avenue Marysville, PA 17053 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to ° unsworn falsification to authorities. MaAha-E. Von Rosenstiel Attorney for Plaintiff t"? ?' `= t ` `- ..a ":"! ?? ?t i ('\J ,?r ; _ ~ ?+ti"`' 3 ,1::? Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Bank of New York Trust Company NA : COURT OF COMMON PLEAS successor to JPMorgan Chase Bank as Trustee : CUMBERLAND COUNTY c/o Wilshire Credit Corp 14523 SW Millikan : Way, Suite 200 Beaverton, OR 97005 : No: 07-3146 Civil Term Plaintiff VS. Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Your house and/or real estate at 5 Forest Avenue, Marysville, PA 17053 is scheduled to be sold at Sheriff's Sale on December 5, 2007 at 10:00 a.m. to enforce the court judgment of $80,575.02 obtained by Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee against you. NOTICE OF OWNERS 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 Bank of New York Trust Company NA success( to JPMorgan Chase Bank as Trustee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call (610) 328-2887. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open t judgment, if the judgment was improperly entered. You may also ask the Court to postpone the s for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may contact 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 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 bid price by calling (610) 328-2887. 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 the 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 (610) 328-2887. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 (717) 249-3166 P Ob CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 fit t 1 ?? ai LEGAL DESCRIPTION ALL` THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Overview, East Pennsboro Township, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which point is the northeast corner of Forest Avenue and North Second Street; thence eastwardly along the northern side of North Second Street thirty-five and four-tenths (35.4) feet to a point; thence northwardly and for part of the distance through the partition wall.of a double two and one-half (21/2) story frame dwelling and beyond one hundred fifty-three and three- tenths (153.3) feet to a stake; thence westwardly forty-four and five-tenths (44.5) feet to Forest Avenue; thence southwardly along Forest Avenue one hundred fifty-six and two-tenths (156.2) feet to the point of Beginning. HAVING THEREON ERECTED a two and one-half (2 1/2) story frame house which was unnumbered, but is now numbered 5 Forest Avenue, Marysville, Pa. 17053. IT BEING Lot No. 115 and the eastern part of Lot No. 114 on the Plan of Lots known as Overview, East Pennsboro Township, Cumberland County, Pennsylvania, as laid out by D.S. Seitz, January 1910, and recorded in the Recorder's Office of Carlisle, Pennsylvania, in Plan Book 1, Page 53. TAX PARCEL NUMBER: 09-11-3002-012 TITLE TO SAID PREMISES IS VESTED IN Dennis R. Collier and Donna L. Collier, his wife by Deed from Loretta Clugh, dated 8/31/2005 and recorded 9/2/2005 in Record Book 270, Page 3990. SHERIFF'S RETURN - REGULAR CASE NO: 2007-03146 P COMMONWEALTH OF PENNSYLVANIA: CbUNTY OF CUMBERLAND BANK OF NEW YORK TRUST COMPANY VS COLLIER DENNIS R ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COLLIER DENNIS R DEFENDANT the at 1238:00 HOURS, on the 25th day of May , 2007 at 5 FORREST AVENUE MARYSVILLE, PA 17053 BRIAN RADLE, SON by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 00 4/oYle 42.40 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/29/2007 MARTHA VON ROSENSTIEL By: Deputy S eri of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-03146 P COMMONWEALTH OF PENNSYLVANIA: CC VNTY OF CUMBERLAND BANK OF NEW YORK TRUST COMPANY VS COLLIER DENNIS R ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COLLIER DONNA L the DEFENDANT , at 1238:00 HOURS, on the 25th day of May , 2007 at 5 FORREST AVENUE MARYSVILLE, PA 17053 BRIAN RADLE, SON by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 ?)oy/o1 - ? 16.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/29/2007 MARTHA VON ROSENSTIEL By: , e p u t y he f -if lff of A. D. #20590-DK -4 _ 1 h Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Bank of New York Trust Company NA : COURT OF COMMON PLEAS successor to JPMorgan Chase Bank as Trustee : CUMBERLAND COUNTY c/o Wilshire Credit Corp 14523 SW Millikan : Way, Suite 200 Beaverton OR 97005 No: 07-3146 Civil Term Plaintiff Vs. Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Defendants AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE l1?1 MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of the last recorded holder of every mortgage of record: Mortgage Electronic Registration Systems, Inc, as nominee for WMC Mortgage Corp. P.O. Box 2026, Flint, MI 48501-2026 2. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Register of Wills J County Courthouse Carlisle, PA 17013 Attorney General of the United States r c/o Assistant Attorney General, Tax Division U S*Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenues/ Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128-1100 Family Court/Domestic Relations Offid One Courthouse Square Carlisle, PA 17013 Bureau of Compliance Clearance Support Section/ATTN: Sheriff's Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 OCCUPANTS/TENANTS J 5 Forest Avenue Marysville, PA 17053 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Von Rosenstiel for Plaintiff ,? ". For Accountable Mail 1?2 6sgo ?? . ?? p tD OD V O? Ch •P W N .? ? QZ OO O Z 9 O OU -n:v 3 a. 8° r'crp ;vp 0 ?° ?xwD(?w ?? ` -w gi mtnoy *.vC-•1?D a I 00= m-A z z VC ? ? x _ x= ? ; ? °, N rooo g a o a ? * ro o ? rog m cs, D D.rl? . , g f n obi DI mm ycnC, > ?S 3 ?!J) 1 D < O v b a Z ? 7 W d J C11 V ? ;U 0 W ..J J CO 3C ? 0 ? m a ? V Z Is ;D (D , 0 v mo ' 3' 8 Z o n IZZ-3 st Q ?1 -M0 s,? -p ODD D n O" :0 ' K O , i'? m LI-2 V 2. - t ??; v D D OD 'r1 X mg X ° .3 ?a p M 'DD?o S a C @ c I ? d I w ? Qua ? ? r 06 3 d p S, B S F o m" $x 00) -n A $ ?? 3 3 w $, FiT to _N 9 c?c? o e W H O 0 A A I p.3 ? Gn . #20590CPG-tm (praecipe to assign DJ) Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff BANK OF NEW YORK TRUST COMPANY : COURT OF COMMON PLEAS NA SUCCESSOR TO JPMORGAN CHASE CUMBERLAND COUNTY BANK AS TRUSTEE VS. Plaintiff DENNIS R. COLLIER AND DONNA L. COLLIER Defendant Case No: 07-3146 Civil Term ASSIGNMENT OF JUDGMENT TO THE PROTHONOTARY: Kindly assign the Judgment in the amount of $80,575.02 to: Lasalle Bank, NA as Trustee located at c/o Wilshire Credit tttome: SW Millik Way, Suite 200, Beaverton, OR 97005 in the above cap on Rosenstiel Plaintiff Dated: December 04, 2007 V_ M ioc? 00 'O l 1 4 (C1 { 0-7 J31ef & COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which LaSalle Bank N A 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 23rd day of July, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 3146, at the suit of Bank of New York Tr Co NA Tr against Dennis R Collier & Donna L is duly recorded as Instrument Number 200801482. IN TESTIMONY WHEREOF, I have her,?unto set my hand an seal of said office this j day of A.D. ?d`0 off, Recorder of Deeds RaWift d Deeds, Cw bv" Cmly, CadWs, PA My Conrini AM E* w ttie Fin t Monday of Jan. 2010 Bank of New York Trust Company NA In the Court of Common Pleas of Successor to JP Morgan Chase Bank as Trustee Cumberland County, Pennsylvania VS Writ No. 2007-3146 Civil Term Dennis R. Collier and Donna L. Collier Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on October 09, 2007 at 1800 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Dennis R. Collier and Donna L. Collier by making known unto Dennis R. and Donna L. Collier personally at 94 Autumn Lane, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to them personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 1458 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 Dennis R. Collier and Donna L. Collier located at 5 Forest Ave., Marysville, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Dennis R. Collier and Donna L. Collier by regular mail to their last known address of 94 Autumn Lane, Enola, PA 17025. These letters were mailed under the date of October 12, 2007 and never returned to the Sheriff s 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 Martha E. Von Rosenstiel, on behalf of LaSalle Bank, NA as Trustee. It being the highest bid and best price received for the same, LaSalle Bank, NA as Trustee, of c/o 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $990.75. Sheriffs Costs: Docketing $30.00 Poundage 19.43 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 31.68 Levy 15.00 Surcharge 30.00 Law Journal 359.00 Patriot News 335.72 Share of Bills 14.92 Distribution of Proceeds 25.00 Sheriff s Deed 39.50 $ 990.75 ? ??/??n? +4 So Answers: R. Thomas Kline, Sheriff B ? ? ?? Real Estate 'ergeant Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 Plaintiff vs. Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Defendants Attorney for Plaintiff Uf COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 07-3146 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 5 Forest Avenue, Marysville, PA 17053. 1. Name and address of owners(s) or reputed owner(s) Dennis R. Collier 5 Forest Avenue Marysville, PA 17053 Donna L. Collier 5 Forest Avenue Marysville, PA 17053 2. Name and address of defendant(s) in the judgment: Dennis R. Collier 5 Forest Avenue Marysville, PA 17053 Donna L. Collier 5 Forest Avenue Marysville, PA 17053 3. Name and address of the last recorded holder of every mortgage of record: Mortgage Electronic Registration Systems, Inc, as nominee for WMC Mortgage Corp. P.O. Box 2026, Flint, MI 48501-2026 4. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the United States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax Bureau Strawberry Square, 11 ', Floor Harrisburg, PA 17128-1100 Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Bureau of Compliance Clearance Support Section/ATTN: Sheriff's Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 OCCUPANTS/TENANTS 5 Forest Avenue Marysville, PA 17053 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. MatfhdE Von Rosenstiel Attorney for Plaintiff Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Bank of New York Trust Company NA : COURT OF COMMON PLEAS successor to JPMorgan Chase Bank as Trustee : CUMBERLAND COUNTY C/o Wilshire Credit Corp 14523 SW Millikan : Way, Suite 200 Beaverton, OR 97005 : No: 07-3146 Civil Term Plaintiff VS. Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dennis R. Collier and Donna L. Collier 5 Forest Avenue Marysville, PA 17053 Your house and/or real estate at 5 Forest Avenue, Marysville, PA 17053 is scheduled to be sold at Sheriff s Sale on December 5, 2007 at 10:00 a.m. to enforce the court judgment of $80,575.02 obtained by Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee against you. NOTICE OF OWNERS 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 Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call (610) 328-2887. 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 contact 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 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 bid price by calling (610) 328-2887. 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 the 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 (610) 328-2887. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 (717) 249-3166 t CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 MVR# 20590 cm WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. Dennis R. Collier and Donna L. Collier Commonwealth of Pennsylvania: County of No. 07-3146 Civil Term Term, 20------- E.D. No. Term, 20...... A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 134 East North Street Carlisle, PA 17013 Amount Due interest from 06/28/07 to 12/5!07 @ $13.25 per diem Attorney's fees Costs Total $ 80,575.02 $ 2,133.25 as endorsed Dated (SEAL) Deputy By: Prothonotary, Common Pleas Court of Cumberland County, Penna. W e Oz y N ? ? ? = M O N' W ? U o - 15 Q ? O N • ? ? O O ? W C Ov" A A W 7-0 N O U ¢- op W ? c Y O w T d w 0 .y N S? G 010 CIO O Q b a N 7 M W go o °? °'M 0 id o ,a a Q N w a W V) N d Y a 7 Y N N d T N Y d G KS m Y d LEGAL DESCRIPTION ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Overview, East Pennsboro Township, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which point is the northeast corner of Forest Avenue and North Second Street; thence eastwardly along the northern side of North Second Street thirty-five and four-tenths (35.4) feet to a point; thence northwardly and for part of the.distance through the partition wall, of a double two and one-half (21/2) story frame dwelling and beyond one hundred fifty-three and three- tenths (153.3) feet to a stake; thence westwardly forty-four and five-tenths (44.5) feet to Forest Avenue; thence southwardly along Forest Avenue one hundred fifty-six and two-tenths (156.2) feet to the point of Beginning. HAVING THEREON ERECTED a two and one-half (2 1/2) story frame house which was unnumbered, but is now numbered 5 Forest Avenue, Marysville, Pa. 17053. IT BEING Lot No. 115 and the eastern part of Lot No. 114 on the Plan of Lots known as Overview, East Pennsboro Township, Cumberland County, Pennsylvania, as laid out by D.S. Seitz, January 1910, and recorded in the Recorder's Office of Carlisle, Pennsylvania, in Plan Book 1, Page 53. TAX PARCEL NUMBER: 09-11-3002-012 TITLE TO SAID PREMISES IS VESTED IN Dennis R. Collier and Donna L. Collier, his wife by Deed from Loretta Clugh, dated 8/31/2005 and recorded 9/2/2005 in Record Book 270, Page 3990. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3146 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF NEW YORK TRUST COMPANY NA SUCCESSOR TO JPMORGAN CHASE BANK AS TRUSTEE, Plaintiff (s) From DENNIS R. COLLIER AND DONNA L. COLLIER (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 $80,575.02 L.L. $.50 Interest FROM 6/28/07 TO 12/5/07 AT $13.25 PER DIEM -- $2,133.25 Atty's Comm % Due Prothy $2.00 Atty Paid $177.40 Plaintiff Paid Date: JULY 23, 2007 (Seal) REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P.O.BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Other Costs "epury Supreme Court ID No. 52634 tub f C=A JIM Real Estate Sale # 33 On August 15, 2007 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 5 Forest Avenue, Marysville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 15, 2007 By: Real Estate Sergeant -? L J C t i °' ,J ii' C?!'r) ``The Patriot-News Co. r 1 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 a"v iotwXtw s Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/24/07 NO 611101111 ads Na?. 10/31107 Wd: No. 200Y-3146 OATwm Do* of HilwIbftt1hat 11/07/07 tt35 0M p "oeacoaorW i ? ?I?ilrtr tl iftwM VS ' D C60W WW I N Sworn o d subs me this 30 day of November, 2007 A.D. E O AIL I' CHISM ttaa at WA Mpdw ' Notary Public with tk in 1 1, - tba3oa a 'lilos, Ovrtvierr, Earl Aerbuo Y of tYw*db ak and sate afPm orylvrade Wore paTiedaix boaoddd ad dear&W n Nkors, i ot G t COMMONWEALTH OF PENNSYLVANIA o )190DR W at a>pot, Thieb pai? is the I Notarial Seal soribma sum of.i3or K Avow nal_Nordt r James L Clark. Notary Public Second -%am iha aArvn* ohing the t City Of Harrislx% Dauphin County nupberit. silo afAxth Secod llear 6kyive My Commission Expires Jute 2,20D8 sd faECrir (33,4) fort to a po tk throne m thoostaadfarp softhei- ? Wowmh Member. Pennsylvania Association of Notaries the pnailwa was of a dedb No ad domes is iflbatan i 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. 33 ie Coyne, Editor Writ No. 2007-3146 Civil Bank of New York T t C rus ompany SWO O AND SUBSCRIBED before me this NA successor to JP Morgan Chase Bank as Trustee day of November, 2007 vs. Dennis R. Collier and /? / C; Donna L. Collier . i /_ Atty.: Martha Von Rosenstiel Notary DESCRIPTION ALL THAT CERTAIN tract of land , together with the improvements thereon erected, situate in Overview, NOTARIAL SEAL East Pennsboro Township, County of DEBORAH A COLLINS Cumberland, and State of Pennsylva- Notary Public nia, more particularly bounded and described as follows to wit: CARLISLE BORO, CUMBERLAND COUNTY , BEGINNING at a point which .+?+*.1 is tf+ rn *l? o ? e My Commission Expires Apr 28, 2010 420590-CMI- LAH BANK OF NEW YORK TRUST COMPANY NA : COURT OF COMMON PLEAS SUCCESSOR TO JPMORGAN CHASE BANK CUMBERLAND COUNTY AS TRUSTEE CIVIL ACTION - LAW Plaintiff Case No: 07-3146 Civil Term VS. DENNIS R. COLLIER AND DONNA L. COLLIER Defendant(s) ASSIGNMENT OF SHERIFF'S SALE BID 1. I, Martha E. Von Rosenstiel, Esquire am the Attorney of record for the Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee, Plaintiff/Bank, on the Writ of Execution in connection with a Mortgage Foreclosure Action as captioned above. 2. At the Sheriff's execution sale, I Martha E. Von Rosenstiel, Esquire was the successful bidder on behalf of Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee, Plaintiff/Bank. 3. I, Martha E. Von Rosenstiel, Esquire, being authorized by Bank of New York Trust Company NA successor to JPMorgan Chase Bank as Trustee, Plaintiff/Bank to do so, hereby assign the bid to Lasalle Bank, NA as Trustee and instruct the Sheriff, upon payment of the costs of settlement, to record said Sheriff's Deed in favor of the said Assignee. y submitted, E. VON ROSENSTI , P.C. Martha E. Von Rosenstiel Attorney for Plaintiff P.O. Box 307 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 DATED: December 20, 2007 #2059 CPG-±:.m (praecipe to assign DJ) Martha E. Von Rosenstiel. P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 BANK OF NEW YORK. TRUST COMPANY : COtiRT Ot? COMMON PLEAS NA SUCCESSOR TO JTPMORGAN CHASE CUMBERLAND COUNTY BANK AS TRUSTEE Plaintiff vs. DENNIS R. COLLIER AND DONNA I, COLLIER Defendant ASSIGNMENT OF JUDGMENT TO THE PROTHONOTARY: Kindly assign the Judgment in the amount of $80.575.02 to: Lasalle Bank, NA as Trustee located at c/o Wilshire Credit Corporation, 14523 SW MillikWay, Suite 200, Beaverton., OR 97005 in the above capt'1vtned matter. lartha E. Von Rosenstiel ttornev for Plaintiff Dated: December 04, 2007