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HomeMy WebLinkAbout07-4763UDREN 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 Trust Company .COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home Loan Trust 2006-EQl by: Saxon :Cumberland County Mortgage Services, Inc. as its attorney-in-fact 4708 Mercantile Drive Ft. Worth, TX 76137 Plaintiff v. Karena J. Winters 602 Hummel Avenue ' NO• ~ `'~- y',~~ cD ua ( 'Tc~"ti Lemoyne, PA 170.43 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 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 ~'EE. 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 torte. 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 notification. Hate 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 torte tomara medidas y puede continuar la demanda en contra soya sin previo aviso 0 notification. Ademas, la torte 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Assaciation 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 valfdity 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 Trust Company Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQl by: Saxon Mortgage Services, Inc. as its attorney-in-fact 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: 212 North 2nd Street MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 7/7/06 DATE RECORDED: 7/14/06 BOOK: 1958 PAGE: 2883 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 paay 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 8/1/07: Principal of debt due $93,115.06 Unpaid Interest at 8.75 from 3/1/07 to 8/1/07 (the per diem interest accruing on this debt is $22.32 and that sum should be added each day after 8/1/07) 3,394.80 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $139.33 and that sum should be added on the first of each month after 8/1/07) (1,285.79) Late Char es (monthlyy late charge of $36.77 should be added in accordance with the terms of the note each month after 8/1/07) 330.93 Fees 225 78 Attorneys Fees (anticipated and actual to 5~ of principal) 4,655.75 TOTAL $101,041.53 * 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 ~e collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sales reasonably 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 $101,041.53 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 Exhibit A al Descri tion ALL THAT PARCEL OF LAND W EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, ST~,TE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 197, PAGE 1146, ID# 45-17-1044-2000, BEING K1~1OWN AND DESIGNATED AS BEING ALL THAT CERTAIN LOT OF GROUND SITUATED ON THE WEST SIDE OF NORTH SECOND STREET, BEING KNOWN AND SHOWN AS LOT NO. 4A ON A CERTAIN PLAN OF LOTS ENTITLED "FINAL SUBIDIVISION PLAN FOR JANN7E M1I.DRED ESLINGER, ALSO KNOWN AS MILDRED, JENNIE ESLINGER" DATED MARCH 25, 1979, AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 38, PAGE 103. HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 212 SECOND STREET. DEED FROM TODD A. DIETRICH AND FRAM DIETR.CH, HUSBAND AND WIFE AS SET FORTH IN DEED BOOK 197, PAGE 1146 DATED 04/23/1999 AND RECORDED 04/2311999, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA, Page 3 June 13, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The AnMF.nWNF.RI~S MnRTGA(:F ASSiSTAN(''F PRG(:RAi1~ F '~ P~,mgy hp she ~_hein fin cSVp ynnr hnme_ This Nntirp exnlnin~ hew t~•o~~gram m^,a,~ This Notice contaias important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help ezplain it. You may also want to contact an attorney in your area. Thewlocal bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IlVIPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO CO~iPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMAl~iDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL ?YfJMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO DHOMEOWNERDS EMERGENCY MORTGAGE ASSIS'X'ANCE PROGR~M~ EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL' DERECHO A REDIMIR SU HIPOTECA. Page l of6 ~XH~B~T A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: _Karena 1. Winters 212 North 2nd Street Enol~, PA 17025 _~____ T____. 2000190329 _ E~First Cor,Porati~n ~~ Deutsche Bank National Trust Compi~ny HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM V[I~TJ MAY RF. F,I.i(:IRI.E FnR FiNAN(". I. AS~jSTAN(~F. WHTC.H C'AN SAVF. VC)TTR HnMF. FRnM F(1RF_.CT.nSTTRF, A-J~, HF.I.P VniT MAKE. FTITITRF MnRT(YA .F. PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE I~OMEOWNER~S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE tiACTO), 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. TF.MPnRARV STAY (?F FnREC.'T.nfiTTRF, -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 tune you must arrange and attend a face-to-faceLl meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THiS MEl~'TiNG MTTST n~_f''IIR WTTHTN THF, NEXT ('itll T)AVS_ TF YCli1 T)n N(~T APPT.Y Ff)R FMFR(:F1jjf=',Y M(~RTC.AC'TF ASSTSTANC'.F._ YOi T MT TRT I3R1N(i YnT IR MnRTCtAC'TF. i TP Tn 1~ATF THE PART nF THTS NnTT(''F. C~i_LED I~HCfW Tn C'TTRR V(~T1R MC3RTC:A[TF. T?EEA[.ILT~, Fxpt en~c un~xJ Tn BRTNC; Y(~TTR MnRTC~ACTF. iTP Tn T)ATF. C"nNSTTMF.R f'REDTT CnTTNSF.T.TNf AC,:F.NC'rF.S - 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 na;ryes, addresses~lld te:Tenhcne mimhers Qf designated cnnsnmer crPxiit nunseiing agencies fnr the cnnn~ in t=~hich the nTnn i~ ln_ a~teri are set forth at_tre end of this Nnti .e. It is only necessary to schedule one face-to-face meeting. Advise your lender imm iatP~ of your intentions. APPT.IC"'ATT[)N FnR MnRTf A[i'F. ASSTSTANC''E ~ y©~ mortgage is ~ 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 Homeowl~er's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counselin agencies have a~plieations for the program and they will assist you in submitting a complete appli~Cation to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postma~ced within thirty Q30) days of your face- to-face meeting. Page 2 of 6 YOU M[1ST 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 HOIV~IE IlVIMEDIATE)L,Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. A(:F.11TC'y A( TinN -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 it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY TH'E FII.ING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFbRMATiON 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.) NATTTRF, nF TAF, [1FFA[Tf ,T _ The MORTGAGE debt held by the above lender on your property located at: 212 North 2nd Street Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: . A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Moat P_.a,~ments of $874.90 for Aril l_., ZOtl7 through ~iLn~_1 2007 = ~2b24~70 M~ Late Charges of $36.77 for Aril 1, 2007 through. 1~Iay 1, 2007 = 73'54 Other charges (eaplain/itemize): Other-575.00 ~T~ Uncollected Late Fee--$183.85 NSF Fee=$40.00 Pr rerty Inspection F~2b.45 ~__ _TOTALL AMOUNT PAST DUE: ~ ~__~ ~~~ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION {Dn not ucP if not a ti ~hle): LY[A HnW Tn ("[TRF. TFiF. nFFeTn.T _ you may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING TAE TOTAL AMOUNT. PAST DUE TO THE LENDER, WHICH !IS~Q?~.Q4„ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments mutt hP maAe PithPr h~~h, r chi r'c ~hFrk~ certifi rl she k nr mnn~+ nrtlPr mariP 1~~~ anc~ c .nt n• You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (I]n not ncc if not a?mle'cahle 1; jy(A Page 3 of 6 iF Yt7i1 i)tl NnT r,rm~ TuF n~~,.rrr ~r _. If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends n py rcise its righ~,fo AcrplerntP the m{lrtggge dPht- This means that the entire outstanding balance of this debt will be considelred due immediatel}~ and you may lose the chance to pay the mortgage ixt monthly installments. l:f full. payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to fnrec)nse nnnn vnnr mnrtggg~pmi~rtvp, IF THF, MnRT(:Al:F iS FnRF[T,nSFn iTPnN _ The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cute the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay ail reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will. be added to the amount you owe the lender, which may also include other reasonable costs. if von c ~r . the d fan)t within the TiiTRTY,,,(~Ql nAY~~d~ ynn will not he rennin to ~,1~St~flLIISry_'S.ft:OS. nTNFR i.F.NflFR RF.MRT)TF.4 -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. Rif'AT Tn C'ilRF TAF i)F.FAiT1 T PRTnR Tn ~T~FRIFF'S RAi F - If you have nat cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, , nu still have the right to cure the defanit and n~ven th s 1 at and im n to nnP hnnr h. fnrP fhP Sheriff c SaiP Yn~may do } navin~ the fatal amnrznt then pact rl,xP nine anv io4Ra nr ntl,o« nl.n.~..e~ 4ke.. a..~ ..,~......_..tl.. ~a._-____~_ r___ . ~ Curing your defanit in the manner set forth in this notice will restore your mortgage to the same position as if yon had never defaulted. F.ARi.iF.~T Pl?S~iRi,F, SAF,RTFF'~ SAi F nATF _ It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could. be held would be approximately ~ months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: Saxon Mortgage Inc._ ~_~~ ~~ Address: 4708 Mercantile Drive North Fortwortls~TX 76137 _ ~~ Phone Number: _ __ _ 1-88&3253502 _ _ ~ ~ Fax Number: _ 1-871fi6S_7613~ _ _ ~~~~ ----_.._..._.___._ Contact Person: _.__._____ _._..__`_ Loss Mitigation _lossmi saxonmsico n ~__ _ _ _~_ F.FFFf"'i' nF SNF;RiFF', fiAT.F. _ 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 alter the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASfiiTMPTTnN nF MnRTf;.'Af F _ you may not transfer your home to a buyer or tr$nsferee 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 mc~rigage are satisfied., Page 4 of 6 NOTICE The amount of your debt is as stated in the attached document. The namGe 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 informationthat 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 l l l Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856} 669-5400 Page 5 of 6 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 POSTI'ION 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 PROCEEDIlVG OR ANY OTHER LAWSUIT L~tSTTTUTED UNDER THE MORTGAGE DOCUMEN'T'S, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, lnc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717} 541670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA I7104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 {717} 243-3818 FAX {717) 731=9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717)334-1518 FAX (717) 334-8326 Page 6 of 6 ~, { V I ~ ~ ~ . _ `. ,. f,~ S ~~ ~1 1 ~ ~ ~ 1 qx; C `~:^ 'w, c $ ~.: LL. r s ~,~_: .. '~ y 2 . ^-, t p. `-~ a .' ~ ' :y-..,,. ~~ #'p ........ 4 O II' . i..U In O 0 0 ='~ w ~- UuZ.l~ ~VQ~ U~IN~ ~'~W Z ~ Lr,,V J ~~~= 3~~$~ u ~''~ w C ~'',r 5 j ~'; C.` O O 2 r~ Q, ~[`~ '~ V 44 JJ . (~. ~~ y ~ ~~ ~ ~ ~~ -`, ~ ~ O t Certified Mlaii Provides: ^ A recast e A unique idergifier for Your rrse6pfece ^ A recxsrid of delhrery kept by the Poetaf Service for two years ~: • Cert~ied Mel may OMiY be combined wkh Fksi-CUSS AAail®ar Priority Maps s CerUited Mee is notavatfe~rle for any cuss of irsterrsatiorsaf ntaii. a I`tO tNStJRA1~CE COVERAGE IS PROVIDED with Certified {Ned, ~ vea, please conatdbr Insured or I4egistered Mall. • For an addftlorael fee, a Ftehxrs R~alpf be requested to rxovide proof of delivery. To obtain Rehrm fiecalpt aervicease complete aru! attach a Return Receipt (PS Fotm ~11~ to the ertirle end add applicable postal to cover the fee. Endorse mel~feCe Return Receipt Requeabad'. To recaFre a tee waiver to a duplicate return reoipt, a USFS®poslmark on your Certified MaiE receipt ie required. ^ For an addklortaf tee, delivery may Ue reairicted to 1t1e addressee d addressee's authorized aggraant. Advise the dark or mark the mailpfece with the endorsement "Resirlcda~daetlvery". a fi a postmark ~ the Certffled Maif receipt is desired, please present the arts: Ge at the poet office for postmarking. If a postmark cn the Certified Mai receipt la not needed, detach and affix label with postage and mail. tMPORTAtQT: Save tkis reeipt aitG gresent it.rtitelt making an itfgalrq. P5 Fenn 3800. August 2008 (ReveiseJ PSN 7530.02.000.9047 t] ! ai ni ~ I *I ,.. a I ~~ ~~ D to l~ u7 m a Q r~ 0 g .~ v o° i p m~ N t1 LL TM W z~ M t: N a. a _ .,~ ~~} •~ ~ 3. +~~ i ?z E ~. t(' 'f ~ A..+. i bb ,L~A,r ~ ~ •~~~ ¢ l „ a4 . J '~i MJa r- ;6~, ~'.7 ~ %~3 ~~, *~ "") l "ffi - ~~ Q n , +~ ~ - „~_ o ---*-~" o '=='` 0 ~,, =^~ O ~~~ ~+ --~~. a !~ ,,I ~~~ ~ ===~ s u-~ r V °a S 0 ~~ `~ ~ Z ~i ~ L (r ...( j U J 3W0~ ?qtr ~r,~~ .~ ~j ,- C: !`` '~ ~ ..~, V ~` ''~ V '`` t T Cetfil3ied Maii Provides; ^ A rrtai~rtg recut w A unique idetrlNler for your rrtailpieoe ^ A record of dedvery kept by the Postal Service for rim years i'raportarlt Reminotens: ~ Certified Mali may ONLY be censbined wph First-t;teas IVIBi~ or prbrit}r MaB~, s CettiSad fop fe notava0able far any dasa of interrtatlonaf mail. ~ des please +.rons~ider Ir~xed a ~ latOer'ed Aka Ger4fied 4AaR For: 'q For en additlor~ fee, a Redrm be requested to proof of Ret~ipt~( ~nFonri 36f 1 j ~ azH~a~nd~ canPlete and atf~h a Ret<un appik:eble postage to cover the fee. Endw'se me'Retum Rec~pt Requested". To receive a fee watver for a duoticate return receipt, a USPS®postmark on your Certified Mail receipt is required. rd For an additional fee. deMery may rte resUicied to the addressee or addressee's authorized aggent Advise the dark a mark the meilpiece wHh the. endorsement FleBtrkledZ7eRvery'. ^ H a postmark on the Certified Mail receipt is desired, pplease present the artl- de at the post office for postmarking. ff a posen-ark on the Certified Mai{ receipt is not needed, detach and affix label with postage and rnaH. tkblPQttl'AtiT: Santa this receipt aad present ii erhen rttatlirtp as ingairy. PS Form 31106, AugttSt 2008 (Reverse} P9N 7rr3~~00-8047 i U7 17" ~ ~ I a; ~ I ~ I r-~ a a~ m p ¢ 1~ ~ rz .7' v aig a~ r~ S ~ ~~ ~ ~~ ~ $ ~ r ~ '~• ~ Ct ~ ~ ~ ~ ~ m ~ ~ '~ ~~ a N V E R I F I CAT 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. \ ~ Mark J. dren, ESQUIRE UDREN LAW OFFICES, P.C. ~~ 1 ~ ~ ~~ V ~~ ~~ `h r C'~ ^~ - r_~ ('.' ~ - - ,-... 7 " - ~ T -~.~ _ n.1 ~-~t y .;; L.:~ ` 51'T`d ._ :. •~ -- ~ C,.+3 •{ l~J ., SHERIFF'S RETURN - NOT SERVED CASE NO: 2007-04763 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS WINTERS KERENA J R. Thomas Kline Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 212 NORTH 2ND STREET ENOLA, PA 17025 WINTERS KARENA J NOT SERVED as to SERVICE WAS MADE AT LEMOYNE ADDRESS. Sheriff ' s Costs : So answers • _ .~..-~- Docketing 6.00 Service .00 Affidavit .00 R. Thomas ine Surcharge 10.00 Sheriff of Cumberland County .00 9~64~67 G),,,,, ~ 16.00 823/ 007OFFICES Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - REGULAR CASE N0: 2007-04763 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS WINTERS KERENA J STEPHEN BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE WINTERS KARENA J DEFENDANT was served upon the at 1930:00 HOURS, on the 21st day of August 2007 at 602 HUMMEL AVENUE LEMOYNE, PA 17043 JOSHUA HARA, ADULT IN CHARGE 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 15.36 Affidavit .00 Surcharge 10.00 q(b4~b1 ~,,,, .00 43.36 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/23/2007 UDREN LAW OFFICES By: eputy Sheriff of A.D. .~. UDRBN LAW OFFICES, P.C. HY: ffiark J. IIdrea, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inca as its attorney-in-fact Plaintiff v. Karena J. Winters Defendant(s) ATTORNEY FOR PLAINTIF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County N0. 07-4763 CIVIL TERM PRAECIPE TO SIIBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for th Verification attached to the Complaint in Mortgage Foreclosure wit: regard to the captioned matter. UDREN LAW OFFICES, P.C. DATED: September 22, 2007 BY: r J. U e Esquire A t rney f Plaintiff ,,w V E R B F I B .~ ~' I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which.is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff hereby verifies that the facts set forth in the foregoing Complain are taken from records maintained by Plaintiff in the ordinar course of business and that those facts are true and correct to th best of the knowledge, information and belief of the undersigned The undersigned understands that this statement is Date : ~~ O'L~ v ' Name : LrR.1~.1r0. 1~iQ5Gd ~- Title: ,~fp Company: Saxon Mortgage Services Inc. as servicer on behalf o Deutsche Bank Trust Compa Americas, as Trustee a Custodian for Soundview Ho Loan Trust 2006-EQ1 by: Sax Mortgage Services, Inc. as i attorney-in-fact subject to the penalties of 18 Pa. C.S. Section 4904 relating t unsworn falsification to authorities. Karena J. Winters Loan #2000190329 MJU #07060019 C ra o° ~ ...,, CT' ^-'T'! G...:i .F t/? "~~ _. `T ~ ~ -^ ~, „fir ~' ~., ~ "'".""'_ } . ~ ~ 0 ~ IIDREN LAW OFFICES, P.C. BY: Mark J. IIdren, $equire ATTY I.D. NO. 04302 WOODCRBST CORPORAT$ CBNTER 111 WOODCR$3T ROAD, SIIITg 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact. 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff v. Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 Defendant (s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-4763 CIVIL TERM PRAECIP}3 FOR JIID(NLSNT FOR FAILIIR$ TO ANS~PBR AND ASB88S~L8NT OF DAM7-C~SS TO THE PROTHONOTARY: Kindly enter judgment. in favor of the Plaintiff and against the Defendant (s) Kareaa J. Winters 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 8/2/07 to 9/22/07 Late charges per Complaint From 8/2/07 to 9/22/07 Escrow payment per Complaint From 8/2/07 to 9/22/07 $101,041.53 1,160.64 73.54 139.33 TOTAL $102,415.04 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. j' LAW OFFICES, P.C. DAMAGES ARE HEREBY ASSESSED AS DATE : ~!~~oZA07 , '''wY ~~ torne or Plaintiff INDICATED C 0 PROTHY d ~~ z.~x oFFlcss, p . c . ArroRNSY FoR PIJII~ITIlF SY: Msrk J. tAdrea, ssquire A'1TY I.D. N0. 0*30Z NOODQisT C01lp01D1~ Cia'1'iR 111 N~ ROAD, SQITa 200 ~7[ HILL, lIJ 00003 e36-669-300 oi~aeliaerudr . aem Deutsche Bank Trust Companyy Americas, as COURT OF COMMON PLEAS Trustee and Custodian for Soundview Home =CIVIL DIVISION Loan Trust 2006-EQ1 by: Saxon Mortgage Cumberland County Services, Ina. as its attorney-in-fact ! Plaintiff ~ ' i V. Karena J. Winters Defendantts) :NO. 07-4763 Civil Term TO: Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 DATE of Notice:September 11, 2007 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED.TO 8NT$R A WRITTEN APPANCB PPlR,SONAZ~LY OR BY ATTORNEY AND FILS IN ~iRITING WITH THS COURT YODR DBFB~tgES OR OBJECTIONS TO TH8 CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN T8N DAYS FROM TpIE DATE OF THIS NOTICE, A JUDC3M$N'P MAY BB AaAINBT YOII MITHOUT A. HEAR,INC# AND YOU MAY LOSE-YOUR PROPERTY OR OTH$R IMPORTANT RIGHT$.YOU SHOULD TAKE THIS PAP$R TO YOUR LAWYER AT ~iCB. IF YOU DO NOT HAVE A LAWYffit GO TO OR TBLEPHQ3i8 THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER . IF YOU CANNOT AFFORD TO ~HIRB A LAWY~[t, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AC3ffitCI83 THAT MAY OFFER LEGAL SBRVICSS TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEB. LAWYER RBF$RRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle., PA 17013 717-249-3166 800-990-9108 NOTIFICIICION DD~OkT~ LISTED SE ffidCUENTRA EN ESTADO DE RffiELDIA POR NO HABER TOMADO LA ACCION T~BRMIl~ 8 E DIEZ x(10 ) DIASE DBE F$TA NOTIF ~ ~ACC~i~O ~DiBB~ DB~N'IDR~O DESLTN NECESIDAD DE COMPARARECER LISTED EN CORTL O gSCUCHAR PREUBA AI,GUNpi, DICTAR SBNTBNCIA EN 3U CONTRA, LISTED PUSDE PBRDER BIBNES Y OTBt08 DCHOS, IMPORTANTES. DEBE LLEVAR BSTA NOTIFICACION A UN ABOdADO IMMSDIATAMENTE SI LISTED NO TIENE Aa0©ADO, 0 SI NO TIENE DINERO SUFICIBriTE PARA TAL SBRVICIO, VAYA EN PERSONA O LLAMT POR TELEFONO A LA OFICINA,. CUYA DIRECCION SE SNCQSNTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDB CONSSatTIR A3S2$TENCIA LBC3AL. SERVICIO D8 REFERSNCIA LEGAL LAWYER REFERRAL 38RVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-.990-9108 IPOTICRt POHSIIIINT 'PO THH FAIR DINT COLLSCTIOM PRAiC.TIClS ACT, s LilN -Iltt[ IS D~ TO H= 7- DiNT COLL3CTOlt AND THIS IS AN AT'PEIfST TO l- DST. ANY IN!'ORNATICIN OsTAIN~D HILL $E ZTSHD~F01t TlDIT P{7$~E. .,~~~.. W est Co to Center 111 Woodcreat oad, Suite 200 Cherry Hill, New Jersey 08003-3620 t7DR~T LAW OFFICES, P. C. BY: Mark J. Udren, Esquire ATTY I.D. N0. 04302 WOODCRB$T CORPORATH CSNTBR 111 WOODCR88T ROAD, SIIITB 200 CHERRY HILL, NJ 08003-3620 85S_482-69dd Deutsche Bank Trust Company Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 4708 Mercantile Drive Ft . Wort.,. .TX 7 613 7 . Plaintiff v. Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 Defendant (s ) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF hI/J COUNTY OF ®~ lC V~ ATTORNSY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0. 07-4763 Civil Term SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Karena J. Winters Over 18 As captioned above Unknown ~- ame : ~~G~Q. .(~. Title: p Company: Saxon Mortgage Services, Inc. as servicer on behalf of Deutsche Bank Trust Company Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Sworn to and subscribed 0 me ~) d 20 Matthew Allan Banaszewski NOTARY PUBLIC -MINNESOTA MY COMMISSION EXPIRES JAN. 31, 2011 s Verbal Confirmation of Service of Complaint Date: ~ c~~ ~~ S oke with: 4~} Defendant(s): at: Defendant(s): was• served on at: - Defendant(s): was served on ~- was served on at: Are there any additional fees due? Yes o !f so how much?_$ l ~ -~• ~ ~ ' .~ ~- r1~ - ~ ~ ~ $ w...1 _ ~~. v ~ -~s a G ~.. ~ ~ D ~ " ~ ~ ..k.+ -~ UDRBN LAW OF•FICBB, P.C. BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 WOODCRBST CORPORATE CENTER 111 WOODCRBST ROAD, SIIITB 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNS'Y FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County .MORTGAGE FORECLOSURE Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff v. NO. 07-4763 CIVIL TERM Karena J. Winters Defendant(s) To: Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 • 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. X Judgment by Default Prothonotary Money Judgment Judgment in Replevin 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 ~~~~o~ 9~a~~aca~ r ~ ~ r IIDREN LAw oFFICBS, P.c. 8Y: Mark J. IIdrea, Esquire ATTY I.D. NO. 04302 wOODCREST CORPORATE CENTER 111 wOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundvew Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Karena J. Winters Defendant(s) NO. 07-4763 CIVIL. TERM PRASCIPg FOR WRIT OF $XECIITION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $102,415_.04 Interest From 9 23 07 3,660.48 to Date of Sale 3 08 Ongoing Per Diem of 2.32 to actual date of sale including if sale is held at a Iater date (Costs to be added) $ UDREN LAW OFFICES, P.C. M r Udren, UIRE TORNEY FOR PLAINTIFF ~ ~; ~ r' ~ -~ ~~~~; ~ ~; ~ F - ¢ x "` ~ ~ ~Q y N n d UDRffi~T LAW OFFICBS, P . C . BY: Mark J. IIdrea, ]3aquire ATTY I.D. NO. 04302 WOODCRSST CORPORAT$ CHNTBR 111 WOODCR$ST ROAD, SIIITB 200 CHBRRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff v. ATTORN$Y FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Karena J. Winters NO. 07-4763 CIVIL TERM Defendant(s) C$RTIFICAT$ TO TH8 SHERIFF I HEREBY CERTIFY THAT: ~. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass {Accident) x C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: x A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): x A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant .and either A or B above is not applicable,, state which Defendant is resident of the Commonwealth of Pennsylvania. / Resident: ~ I~rJ~,y! Udren, ESQUIRE Address & I.D. # as above ~ r __.r cn r~i i _ ~.. r~ ,c ~r`-~ ~. C" ~ ~~` ~~ ~ ~ ~ ~ 1 *~ IIDRSN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF HY: Nark J. IIdren, 8squire ATTY I.D. N0. 04302 1POODCRSST CORPORATE CSNTSR 111 i1O0DCRSST ROAD, SIIITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and ':CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact ' Plaintiff v. Karena J. Winters ENO. 07-4763 CIVIL TERM Defendant(s) C S R T I F I CAT S 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. ICES, ~!C. ~blark J. Udren,. ESQUIRE ATTORNEY FOR PLAINTIFF C7 rs Ga C ° rn r °~ -~ -.~ tV ~, W V i '~ ~ ,' UDREN LAN OFFICES, P.C. BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and.. Custodian for 5oundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff v. Karena J. Winters Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0. 07-4763 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact, 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: 212 North 2na Street, (East Pennsboro Township) Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karena J. Winters ATTORNEY FOR PLAINTIFF 602 Hummel Avenue Lemoyne, PA 17043 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 Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services Inc. as its attorney-ia-fact 4708 Mercantile Drive Fort Worth, TX 76137 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 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 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: September 22, 2007 rk J. Udren, ESQ. torney for Plaintiff C s c!~ -v t~' t.~ + ~n .' ., C9 f~ ~j ~; rs._. ~ N ' 1/ ~ e:. U) ~~' .F , ~~.. ~=~ ~ ~ ~ , 7> ~ '" ~: , a"~~ IIDREN LAW OFFiCEB, P.C. BY: Nark J. IIdrea, Laquire ATTY I.D. NO. 04302 NOODCRBST CORPORATE C$NTER 111 ~POODCRBST ROAD, SIIITB 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQl by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Karena J. Winters ENO. 07-4763 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SAL$ OF REAL PROPERTY To: Karena J. Winters 602 Hummel Avenue Lemoyne, PA .17043 Your house (real estate) at 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriffs Sale on March 5, 2008, at 10:00 am in the, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,415.04, 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 01PN8R' S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent .this Sheriff's Sale, you must take immwdiate actioa: 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.) ~. ~; ,' fx ,. YOII HAY STILL B8 ABLE TO SAVE YOIIR PROPERTY AND YOII HAVE OTHER RI(3HT8 8V'8N IF THE SHERIFF' S SALE D08S TA1C8 PLAC8. 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. YOII S80IILD T711CE T8I8 P11PER TO YOIIR LAiiYER ]1T ONCE. IF YOII DO NOT S71V8 1- LA9PYER OR C~10T 7\FFORD ONE, GO TO OR TELEPHONE TH8 OFFICE LISTED BELOi~ TO FIND OIIT IiHERB YOV CJ~N GET LEGAL HELP . L~1iiYER 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 • - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-4763 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST CO. AMERICAS, as Trustee and Custodian for SOUNDVIEW HOME LOAN TRUST 2006-EQl by: SAXON MORTGAGE SERVICES, INC. as its attorney-in-fact, Plaintiff (s) From KARENA J. WINTERS (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 duected to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $102,415.04 L.L. $.50 Interest from 9/23/07 to Date of Sale 3/05/08 -Ongoing Per Diem of S2232 to actual date of sale including if sale is held at a later date - $3,660.48 Atty's Comm % Due Prothy $2.00 Atty Paid $178.36 Other Costs Plaintiff Paid Date: 9/24/07 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. C 's R. Long, Prothonotary By: Deputy WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUTIE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 .~ IIDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. IIDREN, ESQIIIRE - ID #04302 STUART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQIIIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, ;COURT OF COMMON PLEAS as Trustee and Custodian for € CIVIL DIVISION Soundview Home Loan Trust 2006- = Cumberland County EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff v. Karena J. Winters 602 Hummel Avenue ENO. 07-4763 CIVIL TERM Lemoyne, PA 17043 Defendant(s) AFFIDAVIT OF SERVICE PIIRSIIANT TO Pa.R.C.P.RIILE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B" 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: January 8, 2008 UDRE ~LnAW OF/FIC~E }S, ~jP~.C. BY : ~~i/ I/L~i[~ /, Al /A/~~/~ i Attorneys for plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. N0.04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in- fact Plaintiff v. Karena J. Winters Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-4763 CIVIL TERM TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Karena J. Winters PROPERTY: 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 5. 2008, at 10:00 am, in the Commissioners Hearing Room 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A N ~ ~ ~ ~ ~p O m m J N LL m a~ W O ~ N Q W p `~ ~ A ' D . N E a$w m '€ N ~' ?' N ~' N ~' O ~ N m. m E °n ~ m w 9 w 'v ~ 'm m` N ~ C W O C y e8~omh 7 C ~' y ~ m fAii EmEm.~u N Ec ~$ ~~ N N U ~N I~-~m3~m 'p On N w ~ NLL _~ mEv 'ab ~c m£ ~ V1 ~ ~ ~ 47 E w m 0 0 d C O m ~ "•C ~ N f0 d N d Q Ali ~ ~.U 1 c tP C m W O 01 m T 0. W T LEa U C m~anE°n E°y. m ~ ~p ov°'c£Om V .~~y W U0 N O °' ~ •W ~ F Efacc y x~~ H ~ ~Q ~ c a c y 9 0 E •~ o ~~ m -mom m W'K EC c a. ... i mmEmc~ m N y 7 E3LH .~ ~ ~ ~ Y ~ CVO { i," ~ m~ iN mEooo= m~ v m c U C o y ; ~ ~ tooE °p m N • , ~ .... ~ o m o ~ ~ N m d N C N. _ ~ . N ~a N,N ~~ _ ~ ;ma~oo d W n w .ru `m E m o ~ O w d 2Bid 7 ~ m.~ Qom- H $,o m 'm moa= c Wco %°'c L m N L > c voi p_N O w m _ ~y33 ~ =_~ : o ~~o~~~ 4 0~ E9 m U~~^ o O) cm ~ m~_~m~ ~ mL 2 m cM ! 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Americas, as Trustee In the Court of Common Pleas of And Custodian for Soundview Home Loan Trust Cumberland County, Pennsylvania 2006-EQ 1 by: Saxon Mortgage Services, Inc. Writ No. 2007-4763 Civil Term as its attorney-in-fact VS Kazena J. Winters Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on December 10, 2007 at 1738 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: Karena J. Winters, by making known unto Kazena Winters, personally, at 602 Hummel Ave., Lemoyne, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copies of the same. Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 0937 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 Kazena J. Winters located at 212 North 2nd Street, Enola, 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: Karena J. Winters by regulaz mail to her last known address of 602 Hummel Ave., Lemoyne, PA 17043. This letter was mailed under the date of January 8, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Udren. Sheriffs Costs: Docketing 30.00 Poundage 17.37 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 30.72 Levy 15.00 Surchazge 20.00 Postpone Sale 40.00 Law Journal 355.00 Patriot News 328.88 Share of Bills 16.17 $ 885.64 ~~Sr ~ d ~ ~-.. So Ans ers: '~~'"'~''° R. Thomas Kline, Sheriff BY~_ GG ~ . . _. _. Real Estate ergeant (,o~ ~~~. Ck. G y X37 2~ ~ ~~ t A ODREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. IIdren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SOITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its `MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters €NO. 07-4763 CIVIL TERM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact, 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: 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 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 the last recorded holder of every mortgage Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services Inc. as its attorney-in-fact Address 4708 Mercantile Drive Fort Worth, TX 76137 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 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 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: September 22, 2007 rk J. Udren, ESQ. torney for Plaintiff UDR$N LAW OFFICES, P.C. BY: Mark J. .IIdrea, ]3squire ATTY I.D. NO. 04302 WOODCR$ST CORPORAT$ CENTER 111 WOODCRBST ROAD, SUIT}3 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundniew Home Loan Trust 2006-EQi~by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff v. Karena J. Winters Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-4763 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 Your house (real estate) at 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 5, 2008, at 10:00 am in the, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,415.04, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOZ+IC$ OF OoPIdBR' 3 RI«HTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent .this Sheriff's Sale, you must take immediate actioa: 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) 669-54.00. 2. You maybe 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.) YOII DRAY STILL 88 ABLE TO SAVE YOIIR PROPERTY AND YOII RAVE OTHER RIC3HT3 EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are-filed with the Sheriff within ten'(10) days after Schedule of Distribution is filed. 7. .You may also, have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU 380ULD TARE IBIS PAPER TO YOUR LAiPYER AT ONCE. IF YOU DO NOT 8AV8 A L7-9iY8R OR CANNOT AFFORD ONE, GO TO OR T8LSP80N8 T88 OFFICE LISTBa 88LOW TO FIND OUT 9i88RB YOU CAN fiBT L$GAL SSLP . LAIQYER REFERRAL 88RVICB 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 ALL THAT PARCEL OF LAND IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED INDEED BOOK 197, PAGE 1146, ID# 45-17-1044-2000, BEING KNOWN AND DESIGNATED AS BEING ALL THAT CERTAIN LOT OF GROUND SITUATED ON THE WEST SIDE OF NORTH SECOND STREET, BEING KNOWN AND SHOWN AS LOT N0.4A.ON A CERTAIN PLAN OF LOTS ENTITLED "FINAL SUBDIVISION PLAN FOR JANNIE MILDRED ESLINGER, ALSO KNOWN AS MII.DRED, JENNIE ESLINGER" DATED MARCH 25, 1979, AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 38, PAGE 103. HAVING TI~REON ERECTED A DWELLING KNOWN AND NUMBERED AS 212 SECOND STREET. DEED FROM TODD A. DIETRICH AND FRAN DIETRCH, HUSBAND AND WIFE AS SET FORTH IN DEED BOOK 197, PAGE 1145 DATED 04/23/1999 AND RECORDED 04/23/1999, CUMBERLAND. COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA. BEING KNOWN AS: 212 NORTH 2~ STREET, (EAST PENNSBORO TOWNSHIP) ENOLA, PA 17025 PROPERTY ID NO.: 45-17-1044-2000 TITLE TO SAID PREMiSES IS VESTED IN KARENA J. WINTERS, SINGLE PERSON DATEDE4/23/9gTRECORDEDI4/23 99AIN DEE BOOKR1g7~PAGEB1146~D WIFE . . ~ WRIT OF EXECUTION and/or ATTACHMENT r COMMONWEALTH OF PENNSYLVANIA) NO 07-0763 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST CO. AMERICAS, as Trustee and Custodian for SOUNDVIEW HOME LOAN TRUST 2006-EQl by: SAXON MORTGAGE SERVICES, INC. as its attorney-in-fact, Plaintiff (s) From KARENA J. WINTERS (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 $102,415.04 L.L. $.50 Interest from 9/23/07 to Date of Sale 3/05/08 -Ongoing Per Diem of $22.32 to actual date of sale including if sale is held at a later date -- $3,660.48 Atty's Comm % Due Prothy $2.00 Atty Paid $178.36 Other Costs Plaintiff Paid Date: 9/24/07 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. C 's R. Long, Prothonotary By: Deputy I WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUTIE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 28 On November 1, 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 212 North 2nd St., Enola, more fully described on Exhibit "A" filed with this writ and by this reference ~' incorporated herein. Date: November 1, 2007 By t "~ ~ ~J ~y"Lt%~' ~1,, Real Esta Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn., according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1 and February 8, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid natice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie SW'6R~ TO AND SUBSCRIBED before me this 8 day of February, 2008 Notary NOTARIAL SEAL DEBORAH A COLIINS Notary Pubiic CARLISLE BORO, CUMBERLAND COUNTY MY Commission Expires Apr 28, 2010 >~ii, ,~Aii M. f~ Writ No. ~7-4763 t~ivsl Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact vs. Karena J. Winter Atty.: Mark J. Udren DESCRIPTION ALL that parcel of land in East Pennsboro Township, Cumber- land County, State of Pennsyl- vania, as more fully described in Deed Book 197, page 1146, ID# 45-17-1044-2000, being known and designated as Being all that certain lot of ground situated on the west side of North Second Street, being known and shown as Lot No. 4A on a certain plan of lots entitled °Fina1 Subdivi- sion Plan for Jannie Mildred Edinger, also known as Mildred, Jennie Es- linger dated March 25, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 38, page 103. Having thereon erected a dwelling known and numbered as 212 Second Street. Deed from Todd A. Dietrich and Fran Dietrich, husband and wife as set forth in Deed Book 197, page 1146 dated 04/23/1999 and re- corded 04/23/ 1999, Cumberland County Records, Commonwealth of Pennsylvania. Being known as: 212 North 2nd Street (East Pennsboro Township), Enola, PA 17025. Property ID No: 45-17-1044- 2000. Title to said premises is vested in Karena J. Winters, single person by deed from Todd A. Dietrich and Fran Dietrich, husband and wife dated 4/3/99 recorded 4/23/99 in Deed Book 197 page 1146. ' ~ e Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c'~e patriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/30/08 02/06/08 02/13/08 ............ .. ..G1.4dAM~ ....... . Sworn to s ed before a Is 25 d ebrua 2008 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shseie L lCianer, Natay Public CilyOfHetrielwrg; Dauphin County My CatnmMbr ::xpire. Nov. 26, 2011 AAambar, Pannsylvanla AssoGation of Notaries REAL ESTATE SALE N0.28 Writ No. 2007-4763 Civil Term ~J' eutsclw Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Vs Karena J. Winter Attorney Mark J. Udren DESCRIPTION ALL that parcel of land in East Pennsboro Township, Cumberland County, State of Pennsylvania, as more fully described in Deed Book 197, page 1146, ID# 45-17-1044-2000, being known and designated as Being al] that certain lot of ground situated on the west side of North Second Street, being known and shown as Lot No. 4A on a certain plan of lots entitled "Final Subdivision Plan for Jannie Mildred Eslinger, also known as Mildred, Jennie Eslinger dated Mazch 25, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 38, page 103. Ha~1ng thereon erected a dwelling known and numbered as 2I2 Second Street. Deed from Todd A. Dietrich and Fran Dietrich, husband and wife as set forth in Deed Book 197, page 1146 dated 04/23/1999 and recorded 04/ 311944, Cumberland County Records. Commonwealth of Pennsylvania. °•eing known as: 2I2 North 2nd Street (East nnsboro Township) Enola, PA 17025 Property ID No: 45-17-1044-2000 Title to said premises is vested in I{arena J. Winters, single person by deed from Todd A. Dietrich and Fran Dietrich, husband and wife dated 4/3/99 recorded 4123/99 in Deed Book 197 page 1146. IIDREN LAW OFFICES, P.C. MARK J. UDREN, ESQIIIRE - ID #04302 3TIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE ~ ID #34576 ALAN M. MINATO, ESQIIIRE ~ ID #75860 CHANDRA M. ARREMA, ESQIII E - ID #203437 WOODCREST CORPORATE CENT~3R 111 WOODCREST ROAD, SIIITL 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinga~udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank Trust Co. Americas, :COURT OF COMMON PLEAS as Trustee and Custodian for :CIVIL DIVISION Soundview Home Loan Trust 2006- :Cumberland County EQl by: Saxon Mortgage Services, Inc. as its attorney-in-fact :MORTGAGE FORECLOSURE Plaintiff v. Karena J. Winters =NO. 07-4763 CIVIL TERM Defendant(s) PRAECIPE TO I33II8 WRIT OF EXECIITION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 9 23 07 to Date of Sale 3 4 09 Ongoing Per Diem of 22.32 to actual date of sale including if sale is held at a later date $102,415.04 11,807.28 (Costs to be added) $ UDR~,N LAW OFFICES, P.C. BY ATTC7RNEYS FOR""PLAINTIFF MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE R~ _~ ~ .~4~ © ~ ~~ ~ w ~ .~. o ~ ~ o a o ~0~0 ~ S r ~ V` •.+~ ~ .. c~,, Q~ d .n ~ 'r'1 ~ ~ ~ D 7~ T~ ~` s~ ~ ~n ~ =~; y t 1 ~ f?~° v ~ ;,=, ,: 4 '~ y ~% ~ ~ „~ ~ ~ { - -~ ~. c IIDRI3N LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. IIDRLN, E3QIIIRL - ID #04302 3TIIART WINNBG, BSQIIIRS - ID #45362 LORRAINB DOYLE, g3QIIIRE ~ ID #34576 ALAN M. MINATO, S3QIIIR$ ~ ID #75860 CHANDRA M. ARKEMA, $SQIII~t$ - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCR133T ROAD, 3IIIT~ 200 CHBRRY HILL, NJ 08003-36110 856-669-5400 pleadings~udren.com Deutsche Bank Trust Co. Americas, :COURT OF COMMON PLEAS as Trustee and Custodian for ':CIVIL DIVISION Soundview Home Loan Trutt 2006- :Cumberland County EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in~fact =MORTGAGE FORECLOSURE Plaintiff v. Karena J. Winters €NO. 07-4763 CIVIL TERM Defendant(s) C L R T I F I CAT S I hereby state that as 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. BY ~,~Y~ /'Ya'~~ ~.~~vr~~ . ATTrORNEYS FOR PLAINTIFF MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE r-~ C='. ,,,~ c'~ '.! j~~,7 i~ ~ , ~ C r`_ ~',r .-«- _ i ~- tJDRSN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. IIDRSN, SSQIIIRS - ID #04302 3TIIART WINNSG, SSQIIIRS - ID #45362 LORRAINS DOYLS, SSQIIIRS ~ ID #34576 ALAN M. MINATO, SSQIIIRS r ID #75860 CHANDRA M. ARKSMA, SSQIIIRS - ID #203437 WOODCRSST CORPORATE CSNT~R 111 WOODCRSST ROAD, SIIIT$ 200 CHERRY HILL, NJ 08003-36$0 856-669-5400 pleadings~udren.com Deutsche Bank Trust Co. Americas, :COURT OF COMMON PLEAS as Trustee and Custodian for :CIVIL DIVISION Soundview Home Loan Trust 2006- :Cumberland County EQ1 by: Saxon Mortgage services, Inc. as its attorney-in-fact :MORTGAGE FORECLOSURE Plaintiff v. Karena J. Winters NO. 07-4763 CIVIL TERM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc: as its attorney-in-fact, 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: 212 North 2na Street, (East Pennsbaro Township) Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 2. Name and address of Deefendant(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 t 4. .Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank Trust Co. 4708 Mercantile Drive Americas, as Trustee and', Fort Worth, TX 76137 Custodian for Soundview Home Loan Trust 2006-EQ1. by: Saxon Mortgage Services, Inc. as its attorney-in-iEact 5. Name and address of el~rery other person who has any record lien on the property: Name Address none 6. Name and address of evvery 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 Sectipn 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 evvery other person of whom the plaintiff has knowledge who has anjy interest in the property which may be affected by the sale: Name Address Tenants/Occupants 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 I verify that the statemeents made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November 20, 2008 UDREN LAW OFFICES, P.C. ATTORNEYS FOR PLAINTIFF MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~ a ~ cy ~' .a - ~ 1, -- : ,-, i t-;~; ~ ,:,:3 ,,,~ ~ i ..~'~r, ~~ , ~.; ~: c.1`ti ~ c` L., ^~ <; C ..~, g' IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA ~ RE; CHAPTER 13 KARENA J. WINTERS, CASE NO: 1-08-bk-00746-MDF Debtor SAXON MORTGAGE SERVICES AS SERVICER FOR DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1, Movant v. KARENA J. WINTERS CHARLES J. DeHART, III, ESQUIRE, TRUSTEE, Respondents RE: DOCKET ENTRY NO: 58 CERTIFICATE OF DEFAULT ORDER MODIFYING AUTOMATIC STAY Upon consideration of the Motion of Saxon Mortgage Services as Servicer for Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-EQ1 for Relief from Automatic Stay, as well as the Certification of Default filed by same, it is hereby ORDERED AND DECREED THAT: The 11 U.S.C. §362 Automatic Stay of all proceedings is hereby modified with respect to premises located at: 212 North Second Street Enola, PA 17025 so as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. $~ the Comrr•C, (mrc}, Dated: October 29, 2008 TJ~is docu# is ,~leetrc~riically stgn~d and 3d on ~~r~s d~r~e Case 1:08-bk-00746-MDF Doc 60 Filed 10/30/08 Entered 10/30/08 08:57:21 Desc Maih Document Page 1 of 1 IIDREN LAW OFFICES, P.C. MARK J. IIDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINS DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE ~ ID #75860 CHANDRA M. ARKEMA, 83QIII8 - ID #203437 WOODCREST CORPORATE CENT R 111 WOODCR83T ROAD, 3IIIT~3 200 CHERRY HILL, NJ 08003-360 856-669-5400 pleadiagsQudrea.com Deutsche Bank Trust Co.~~,Americas, as Trustee and Custodian for Soundview Home Loan Tru t 2006- EQ1 by: Saxon Mortgage ~ervices, Inc. as its attorney-in~fact Plaintifff v. Karena J. Winters De f endanlt (s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-4763 CIVIL TERM NOTICE OF SH~RIFF'S SALE OF REAL PROPERTY To: Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 Your house (real estate)'at 212 North 2nd Street, (East Pennsboro Township) Enola, PA 1702 is scheduled to be sold at the Sheriff's Sale on March {~, 2009, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, ;Courthouse, Carlisle, PA, to enforce the court judgment of $102,415.04, obtained by Plaintiff above (the mortgagee) against you. ', If the sale is postponed, the property will be relisted for thelNext Available Sale. NOZ~ICB OF OWN8R'3 RIGHTS YOU MAY BE ABLE TOYOU MAY BE ABLE TO PREVENT~THIS SHERIFF'S SALESHERIFF'S SALE To prevent this Sheriff's Salje, you must take immediate actioa: 1. The sale will be cancellled 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 ay 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 Conrt to postpone the sale for good cause. 3. You may also be able toj 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 obtai,in an attorney.) YOII DRAY STILL BE ABLE TO SAVE YOIIR PROPERTY AND YOII HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's dale 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 tm 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 duefrom 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 anal 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 withi}~ 30 days after the sale. This schedule will state who will be receiving tat money. The money will be paid out in accordance with this schedule''unless exceptions (reasons why the proposed distribution is wrong) are fi ed with the Sheriff within ten (10) days after Schedule of Distribution is f led. 7. You may also have~iother 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 YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LE HELP. WYSR REFERRAL 3SRVICE Cumber]~and County Bar Association 2 Liberty Avenue ',Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumber and County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. MARK J. tJDREN, ESQUIRE - ID #04302 STIIART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE r ID #75860 CHANDRA M. ARREMA, ESQUI~tE - ID #203437 WOODCREST CORPORATE CENT~R 111 WOODCREST ROAD, SUIT$ 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~udren..com ATTORNEY FOR PLAINTIFF Deutsche Sank Trust Co. Americas, ':COURT OF COMMON PLEAS as Trustee and Custodian for :CIVIL DIVISION Soundview Home Loan Trust 2006- :Cumberland County EQ1 by: Saxon Mortgage ervices, Inc. as its attorney-in fact Plaintif €N0. 07-4763 CIVIL TERM v. Karena J. Winters Defendan (s) TO: ALL PARTIES IN OWNER(S): Karena J. taint 3T AND CLAIMANTS CE OF SHERIFF'S SALE OF REAL PROPERTY PROPERTY: 212 North tad Street (East Pennsborp Township) Enola, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 4, 2009, at 10:00 am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate th t you may hold a mortgage or judgment on the property which will ~e 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 madle in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4763 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST CO. AMERICAS, as Trustee and Custodian for SOUNDVIEW HOME LOAN TRUST 2006-EQ1 BY: SAXON MORTGAGE SERVICES, INC. as its attorney-in-fact, Plaintiff (s) From KARENA J. WINTERS (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 $102,415.04 L.L. Interest from 9 /23/07 to Date of Sale 3/04/09 Ongoing per diem of $22.32 to actual date of sale including if sale is held at a later date -- $11,807.28 Atty's Comm % Due Prothy $2.00 Atty Paid $1,085.50 Other Costs to be added Plaintiff Paid Date: 11/25/08 Curtis R. Long, Prothonot y (Seal) By: Deputy REQUESTING PARTY: Name: CHANDRA ARKEMA, ESQ RE Address: UDREN LAW OFFICES, P. . WOODCREST CORPORA E CENTER 111 WOODCREST ROAD SUTIE 200 CHERRY HILL, NJ 0800 i 3620 Attorney for: PLAINTIFF Telephone:856-669-5400 Supreme Court ID No. 203437 IIDR$N LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. IIDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE - ID #75860 CIiANDRA M. ARREMA, ESQIIIRE - ID #203437 WOODCRSST CORPORATE CENTER 111 WOODCREST ROAD, SIIITB 200 CHI3RRY HILL, NJ 08003-3620 856-669-54.00 Deutsche Bank Trust Co. Americas, :COURT OF COMMON PLEAS as Trustee and Custodian for ? CIVIL DIVISION Soundview Home Loan Trust 2006- Cumberland County EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff v. Karena J. Winters .`.`-NO. 07-4763 CIVIL TERM Defendant (s ) AFFIDAVIT OF SERVICE PORSIIANT TO Pa.R.C.P.RIILE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date{s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 3, 2009 UD~I~,~W_ Qk'FICES, ~P.C. B At'fbrne~s-for 'Pl"aih~i'ff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE IIDRLN LAW OFFICES, P.C. MARK J. iTDRSN, }3SQIIIRE - ID #04302 STIIART WINNEG, BSQIIIRE - ID #45362 LORRAINL DOYLS, ESQIIIR$ - ID #34576 ALAN M. MINATO, ESQIIIRL - ID #75860 CHANDRA M. ARKSMA, ESQIIIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@tudrea.com Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006- EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Karena J. Winters €NO. 07-4763 CIVIL TERM Defendant(s) AM}3NDED AFFIDAVIT PIIRSIIANT TO RIILE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact, 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: 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 1. Name and address of Owner(s) or reputed Owners}; Name Address Karena J. Winters 602 Hummel Avenue Lemoyne , PA 17 04 3 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 the last recorded holder of every mortgage Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact Address 4708 Mercantile Drive Fort Worth, TX 76137 5. Name and address of every other person who has any record lien on the property: Name Address East Pennsboro Township 98 South Enola Drive Enola, PA 17025 c/o Henry F. Coyne, Esquire Coyne & Coyne PC 3901 Market Street Camp Hill, PA 17011-4227 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 212 North 2nd Street (East Pehnsboro Township} Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: February 3, 2009 UD LAW OFFICES, P.C. B ATT RNEYS FO PLAINTIF MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in- fact Plaintiff v. Karena J. Winters Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-4763 CIVIL TERM TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Karena J. Winters PROPERTY: 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 4. 2009, at 10:00 am, in 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 fled by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A m CL G fA 0 O 0 O to n C rn Q. 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O o c o ~ Q N m c i o a o O C 7 C °--'~O°~md - m ~ x g1~~mo_n O. y A O ~ ~ w m m o d j ~' tD N ~ . .. n m m ~ °-c ~~j~` ~ ~.O ~ a~ D a 'ony3v° ,3 n~ y a'1-"X Z ~a..m =' ~m m ~001m °: ` m a O s 2.o ~ ~ ~ ~ ~b 4 'o m ~- ^ y .~ ~~ !D ~ ~ mo O~a ~ T N /V m .Z'1 m m- O .7 ~` m t0 -y N O 4 a-'y w9~- m c. ~ ~ -. ~ ~ T(n m O m p0 C7 = ~' m O a>>m~m m N a' ~ma S3 ~ i u ~~ m m ~9/'m~m 3 TfA y~pm~n3 w ~ 6 ~ m v -'~ N2 c3~ co m m ay.m n .w.. H N ~ ~ ~ ~ • .Z7 ;TJ n y mw° o 3 fD N o . o~ a m d X IBI q m y p ~° > »~. ~ o~ ~, ~~o ' ~ Deutsche Bank Trust Co. Americas, as In The Court of Common Pleas of Trustee and Custodian For Soundview Cumberland County, Pennsylvania Home Loan Trust 2006-EQ1 by: Saxon Writ No. 2007-4763 Civil Term Mortgage Services, Inc. as its attorney-in-fact VS Karena J. Winters Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 15, 2009 at 1954 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: Karena J. Winters, by making known unto Karena Winters personally, at 212 North 2°d Street, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to laws, states that on January 15, 2009 at 1954 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 Kazena J. Winters located at 212 North 2°d Street, Enola, 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: Kazena J. Winters, by regular mail to her last known address of 212 North 2°~ Street, Enola, PA 17025. This letter was mailed under the date of January 16, 2009 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff B~~ Real Estat ergeant EXHIBIT B t~ ~.,~, -*~ _1 `"~ t "~„ ~: 4 -~ ...y ' Deutsche Bank Trust Co. Americas, as In The Court of Common Pleas of Trustee and Custodian For Soundview Cumberland County, Pennsylvania Home Loan Trust 2006-EQ1 by: Saxon Writ No. 2007-4763 Civil Term Mortgage Services, Inc. as its attorney-in-fact VS Karena J. Winters Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 15, 2009 at 1954 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: Karena J. Winters, by making known unto Karena Winters personally, at 212 North 2nd Street, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 15, 2009 at 1954 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 Karena J. Winters located at 212 North 2nd Street, Enola, 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: Karena J. Winters, by regular mail to her last known address of 212 North 2nd Street, Enola, PA 17025. This letter was mailed under the date of January 16, 2009 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff s Costs: Docketing 30.00 Poundage 18.71 Posting Bills 15.00 Advertising 15.00 Prothonotary 2.00 Mileage 27.90 Levy 15.00 Surcharge 20.00 Postpone sale 40.00 Law Journal 355.00 Patriot News 400.13 Share of bills 15.52 954.26 / 4 ~~ Y~oq C~,,.,, So Ans *'~~C R. Thomas Kline, S eriff 1 BY Real Estate Coordinator - ~~' , ~ ~ - ~, ~, " ., ~ = , _. j..,~~ . c. ~ _ ,_. v~ ~ ~. t' lZ ~ ~~~~~ y MARK J. UDR,EN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIR,B - ID #45362 LOR.R.AINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARItEMA, 83QUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~udren.com Deutsche Bank Trust Co. Americas, :COURT OF COMMON PLEAS as Trustee and Custodian for :CIVIL DIVIST_ON Soundview Home Loan Trust 2006- :Cumberland County EQl by: Saxon Mortgage Services, Inc. as its attorney-in-fact 'MORTGAGE FORECLOSURE Plaintiff v. Karena J. Winters NO. 07-4763 CIVIL TERM Defendant (s) UDR.EN LAW OFFICES P.C. ATTORNSY FOR PLAINTIFF AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc: as its attorney-in-fact, 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: 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 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 Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 4708 Mercantile Drive Fort Worth, TX 76137 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 212 North 2°d Street (East Pennsboro Township.) Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November 20, 2008 UDREN//~LA}W~~O/FFIC/E}S , P . Cry/ ATTORNEYS FOR PLAINTIFF MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE IIDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQIIIRE - ID #04302 3TIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE - ID #75860 CHANDRA M. ARKEMA, ESQIIIRE - ID #203437 WOODCREST CORPORATB CENTER 111 WOODCREST ROAD, SIIITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~udren.com Deutsche Bank Trust Co. Americas, :COURT OF COMMON PLEAS as Trustee and Custodian for :CIVIL DIVISION Soundview Home Loan Trust 2006- :Cumberland County EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact :MORTGAGE FORECLOSURE Plaintiff v. Karena J. Winters ': NO. 07-4763 CIVIL TERM Defendant (s ) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Karena J. Winters 602 Hummel Avenue Lemoyne, PA 17043 Your house (real estate) at 212 North 2nd Street, (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 4, 2009, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,415.04, 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 actioa: 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 ASLB TO SAVE YOUR PROPERTY AND YOII HAVE OTHER RIGHTS EVEN IF THS SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU 3SOULD TA1CS THIS PAPER TO YOUR LAIPYSR AT ONCE. IF YOU DO NOT SAVE A LANYSR OR CANNOT AFFORD ONE, GO TO OR TSLSPSONB TS8 OFFICE LISTED BSL01P TO FIND OUT WHSRS YOU CAN GST LEGAL $SLP. LA~J7t8R 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 ALL THAT PARCEL OF LAND IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED INDEED BOOK 197, PAGE 1146, ID# 45-17-1044-2000, BEING KNOWN AND DESIGNATED AS BEING ALL THAT CERTAIN LOT OF GROUND SITUATED ON THE WEST SIDE OF NORTH SECOND STREET, BEING KNOWN AND SHOWN.AS LOT N0.4A ON A CERTAIN PLAN OF LOTS EN'ITTLID 'T'INAL SUBDTVLSION PLAN FOR JANNIE ]vIILDRED ESLINGER, ALSO KNOWN AS MII,DRED, JENNIE ESLINGER" DATED MARCH 25, 1979, A1~ID RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 38, PAGE 103. HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 212 SECOND STREET. DEED FROM TODD A DIETRICH AND FRAN DIETRCH, HUSBAND AND WIFE AS SET FORTH INDEED BOOK 197, .PAGE 1146 DATED 04/23/1999 AND RECORDED 04/23/1999, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA. BEING KNOWN AS : 212 NORTH 2'''D STREET (EAST PENNSBORO TOWNSHIP) ENOLA, PA 17025 PROPERTY ID NO.:, 45-17-1044-2000 TITLE TO SAID PREMISES IS VESTED IN KARENA J. WINTERS, SINGLE PERSON BY DEED FROM TODD A. DIETRICH AND FRAN DIETRICH, HUSBAND AND WIFE DATED 4/23/99 RECORDED 4/23/99 IN DEED BOOK 197 PAGE 1146. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-4763 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST CO. AMERICAS, as Trustee and Custodian for SOUNDVIEW HOME LOAN TRUST 2006-EQ1 BY: SAXON MORTGAGE SERVICES, INC. as its attorney-in-fact, Plaintiff (s) From KARENA J. WINTERS (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 $102,415.04 L.L. Interest from 9 /23/07 to Date of Sale 3/04/09 Ongoing per diem of $22.32 to actual date ot'sale including if sale is held at a later date -- $11,807.28 Atty's Comm % Due Prothy $2.00 Atty Paid $1,085.50 Other Costs to be added Plaintiff Paid Date: 11/25/08 urtis R. L ng, Pr thonota (Seal) By~ Deputy REQUESTING PARTY: Name: CHANDRA ARKEMA, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCRE5T ROAD, SUTIE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone : 856-669-5400 Supreme Court ID No. 203437 Real Estate Sale #72 u l~- On December 18, 2008 the Sheriff levied upon the defendant's interest in the real property situated in East PennsboroTownship, Cumberland County, PA Known and numbered as 212 North 2nd Street, Enola more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 18, 2008 sy: .~ ~,L 6~ Real Estate Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 30, February 6, and February 13, 2009 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. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 13 day of February 13, 2009 Notary NOTARIAL SFAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commisslon Expires Apr 28, 2010 lF3~AL 11/T~ W.)g 110. 72 Writ No. 2007-4763 Givil Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ 1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact vs. Karena J. Winters Atty.: Chandra Arkema ALL that parcel of land in East Pennsboro Township, Cumberland County, State of Pennsylvania., as more fully described in Deed Book 197, Page 1146, ID# 45-17-1044- 2000, being known and designated as BEING all that certain lot of ground situated on the west side of North Second Street, being known and shown as Lot No. 4A on a certain plan of lots entitled "Final Subdivi- sion Plan for Jannie Mildred Edinger, also known as Mildred, Jennie Es- linger" dated March 25, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 38, Page 103. HAVING THEREON ERECTED a dwelling known and numbered as 212 Second Street. DEED FROM Todd A. Dietrich and Fran Dietrich, husband and wife as set forth in Deed Hook 197, Page 1146 dated 04/23/1999 and recorded 04/23/1999, Cumberland County Records, Commonwealth of Pennaylvarua. BEING KNOWN AS: 212 NGRTH 2ND STREET (EAST PENNSBORO TOWNSHIP ), ENOLA, PA 17025. PROPERTY ID NO.: 45-17-1044- 2000. TITLE TO SAID PREMISES IS VESTED IN Karena J. Winters, single person by deed from Todd A. Dietrich and Fran Dietrich, husband and wife dated 4/23/99 recorded 4/23/99 in Deed Hook 197 Page 1146. ThE P2~°iot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUf~TY COURT HOUSE c~he ~latriot 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 REAL ESTATE SALE N0.72 Writ No. 2007-4763 Civil Term Deutsche Bank7tust Co. Amerias, as Trustee and Custodian for Soundvlew Home Loan Trust 2006-EQ1 by: Saxon MOrtgege ServtceS, Inc. as its attorney-in-fact VS Karma J. Winters Attorney Chandra Arkema LEGAL DESCRIPTION ALL THAT PARCEL OF LAND IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRB3ID IN DEID BOOK 197, PAGE 1146, ID# 45-17-1044-2000, BEING KNOWN AND DESIGNATEDAS BEING ALL THAT CERTAIN LOT OF GROUND STTUATID ON TIID WEST SIDE OF NORTH SECOND STREET. BEING KNOWN AND SHOWN AS LOT N0.4A ON A CERTAIN PLAN OF LOTS ENITIT.ED `FINAL SUBDIVISION PLAN FOR JANNIE MB.DRID ESLINGER, ALSO KNOWN AS MjLDRID, JENNIE ESLINGER" DATED MARCH 25,1979, AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 38, PAGE 103. HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 212 SECOND STREET: DEED FROM TODD A DIETRICH AND FRAN DIETRCH, HUSBAND AND WIFE AS SET FORTH IN DEID BOOK 197, PAGE 1146 DATID 04!23/1999 AND RECORDID 04/23/ 1999, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA. BEING KNOWN AS: 212 NORTH 2nd STREET (EAST PENNSBORO TOWNSHIP) INOLA, PA 17025 PROPERTY ID NO.: 45-17-1044-2000 TITLE TO SAID PREMISES IS VESTID IN KARINA J. WINTERS, SINGLE PERSON BY DEED FROM TODD A. DIETR[CH AND FRAN DIETRICH, HUSBAND AND WIFE DATED 4/23/99 RECORDID 4/23/99 IN DEID BOOK 197 PAGE 1146. This ad ran on the date(s) shown below: r .-~ . ......... -. ~siL_~s- .~.. .. . Sworn to and subscribed before me this;25 day o~e ruary, 2009 A.D. -` •~ -: ~ -- ~., ~,. _ C ~ ~~.~~~ `~._~ /--_. Notary Public ..a' `.-~~I i Berrie L. Karr ~i. r-I,a.ary Pubiic ~ ~ pi Marr~s3:.~::~, ':1~:~phin GotMrtY 1 ~gSi(>r': rr ;~1fts=,c 1~iOV. ~6. - nation of Noterle~ Member, penns~+h~ . 01/21/09 01128109 02104/09 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-4763 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST CO AMERICAS, AS TRUSTEE AND CUSTODIAN FOR SOUNDVIEW HOME LOAN TRUST 2006-EQl BY: SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT Plaintiff (s) From KARENA J. WINTERS (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$102,415.04 L.L. Interest FROM 9/23/07 TO DATE OF SALE DECEMBER 9, 2009 -ONGOING PER DIEM OF $22.32 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $18,056.88 Atty's Comm Atty Paid $2,063.76 Plaintiff Paid Due Prothy $2.00 Other Costs Date: July 14, 2009 (Seal) REQUESTING PARTY: urtis R. Lon not By: Deputy Name STUART WINNEG, 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. 45362 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Co. ':COURT OF COMMON PLEAS Americas, as Trustee and =CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its ':MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters =NO. 07-4763 CIVIL TERM Defendant (s ) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $102,415.04 Interest From 9 23 07 18,056.88 to Date of Sale December 9. 2009 Ongoing Per Diem of 22.32 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN L.~Vd/OA'F' ; /P . C . BY: Att6.~Yieys~or P1~zri-rr~ff /M,~.,A,.,,RK J. UD EN, ESQUIRE rL?~iiUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE $~-~~0°0 !~~ ~-a79~`~ - ~ Z ~ S'~ cos B ~ ,~ ~~ t, ~ ~~ . UD ~~ ~~ _ v ~y~~ ~ ,~ ~4 . v v ,~ 9 ~~~, to "! ~` ~r ~ ~ 5 1 ~ ~~ `s `/ `~ ~, DO D ~e c o UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKSMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Co. €COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home =Cumberland County Loan Trust 2006-EQl by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters €NO. 07-4763 CIVIL TERM Defendant (s ) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: ~~ UDREN BY_: SJ P.C. At~ofney~r Plaintiff MARK J. R N, ESQUIRE L-QUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ,. _. . ,; ,,;, .. v: _ ~ ~ . 'e , UDREN LAW OFFICES P C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQl by: Saxon Mortgage Services, Inc. as its =MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters €NO. 07-4763 CIVIL TERM Defendant (s) C E R T I F I C A T E I hereby state that as 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 LA,b~f'/~F'F~F~S', P,lC . BY: Atttpz'neyor Plaintiff MARK J. EN, ESQUIRE ~5'FUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE Fri ~- - ~ _ rr.r~Y ,~ ~, ~' ~ ~~ ,_ ,-. ~ E.J ~_ Y FOR PLAINTIFF Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and '=. CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters ENO. 07-4763 CIVIL TERM Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQl by: Saxon Mortgage Services, Inc. as its attorney-in-fact, 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: 212 North 2nd Street, Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karena J. Winters 212 North 2nd Street, Enola, PA 17025 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 r 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank 4708 Mercantile Drive Trust Co. Americas, Fort Worth, TX 76137 as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St. 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 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 1, 2009 UDREN P.C. BY : / / I1~ Att~n~/y~for Plaintiff MARK J. ~N, ESQUIRE ~iJART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~ ~ f:' ~~~ ' ; ; I ~ ,~ - '" _ Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters €NO. 07-4763 CIVIL TERM Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Karena J. Winters 212 North 2nd Street, Enola, PA 17025 Your house (real estate) at 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,415.04, 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 canceled 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 TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10)-days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar 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 E i- ` n, ? ' !~y V c.u~~-' l•E' ~ p ,. ~,._ UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU; WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQl by: Saxon Mortgage Services, Inc. as its € attorney-in-fact Plaintiff v. Karena J. Winters Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Karena J. Winters PROPERTY: 212 North 2nd Street, Enola, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 9, 2009, at 10:00 am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later 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. - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-4763 CIVIL TERM ALL THAT PARCEL OF LAND IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 197, PAGE 1146, ID## 45-17-1044-2000, BEING KNOWN AND DESIGNATED AS BEING ALL THAT CERTAIN LOT OF GROUND SITUATED ON THE WEST SIDE OF NORTH SECOND STREET, BEING KNOWN AND SHOWN AS LOT NO. 4A ON A CERTAIN PLAN OF LOTS ENTITLED "FINAL SUBDIVISION PLAN FOR JANNIE MILDRED ESLINGER, ALSO KNOWN AS MILDRED, JENNIE ESLINGER" DATED MARCH 25, 1979, AND RECORDED IN THE OFFICE OF-THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 38, PAGE 103. HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 212 SECOND STREET. DEED FROM TODD A. DIETRICH AND FRAM DIETRCH, HUSBAND AND WIFE AS SET FORTH IN DEED BOOK 197, PAGE 1146 DATED 04/23/1999 AND RECORDED 04/23/1999, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA. BEING KNOWN AS: 212 NORTH 2ND STREET, ENOLA, PA 17025 PROPERTY ID NO.: 45-17-1044-2000 TITLE TO SAID PREMISES IS VESTED IN KARENA J. WINTERS, SINGLE PERSON BY DEED FROM TODD A. DIETRICH AND FRAM DIETRICH, HUSBAND AND WIFE DATED 4/23/99 RECORDED 4/23/99 IN DEED BOOK 197 PAGE 1146. DDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 ' CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. RAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home €Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 2N0. 07-4763 CIVIL TERM Plaintiff v. Karena J. Winters Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November 2, 2009 UDREN 'IZ'~-P7C . r '/ Attorneys ....~fZSY'-P3&3~it~ f f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE. ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Deu,~cNe Bank Trust Co. Americas, as Trustee, et. al., Plaintiff(s) ` vs. Karena J. ViLinters, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Ste 200 Cherry Hill, NJ 08003-3620 --Karena J. Winters Court Case No. 4763 Civil Term State of:,~e ~ ~V r/y W ) ss. County of: 2sZ ~ Name of Server: Id f4N T • ~LRRn~cK~ck , dR. ,undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the ~ ~'~ day of ©C'~ 0 R e R , 20 ~, at a'• ~ S o'clock ~M Place of Service: at 210 Richwine Road Documents Served Service of Process on: Person Served, and Method of Service: Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 099922-0001. AFFIDAVIT OF SERVICE -- Individual Service of Process on: in Shermans Dale. PA 17090 the undersigned served the documents described as: Notice of Sheriff s Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Karena J. Winters ~ By personally delivering them into the hands of the person to be served. ^ By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Karena J. Winters at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex ~; Skin Color 1rH~7 £ ;Hair Color 1<i1.0-UO ;Facial Hair N~R Approx. Age 3.S ;Approx. Height 3 `(D ;Approx. Weight l ~ S ^ To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under pe4nalty of perjury/~~^ edy nd syva t~ me this that the foregoing is true and c rrect. `~ da o , 20 ire of Server International, Ltd. COMMONWEgLm Op PENNSYLVANIA M. Michelle GuytonSNota Carlisle Born, Cumberla County My Commission Expires July 1, 2012 Member, Pennsylvania Association of Notaries FI~.Ei~::~ r~i~v~ 2Q~9 ~~Y -6 P~ I ~ ~ ~ „ . _~ IIDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. IIDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE - ID #75860 CHANDRA M. ARREMA, SSQIIIRE - ID #203437 LOIIIS A. SIMONI, ESQIIIRE - ID #200869 ADAM L. KAYES, ESQIIIRE - ID #86408 MARGUERITE L. THOMAS, ESQIIIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee E COURT OF COMMON PLEAS and Custodian for Soundview Home Loan Trust '-CIVIL DIVISION 2006-EQ1 by: Saxon Mortgage Services, Inc. as :Cumberland County its attorney-in-fact Plaintiff v. Karena J. Winters Defendant(s) NO. 07-4763 CIVIL TERM AFFIDAVIT OF SERVICE PIIRSIIANT TO Pa.R.C.P.RIILE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November 9, 2009 UDRE LA ES, P.C. BY: Attorneys Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. ?COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its 'MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters `NO. 07-4763 CIVIL TERM Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact, 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: 212 North 2nd Street, Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karena J. Winters 210 Richwine Road Shermans Dale, PA 17090 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 4708 Mercantile Drive Trust Co. Americas, Fort Worth, TX 76137 as Trustee and Custodian for Soundview Home Loan Trust 2006-EQl by: Saxon Mortgage Services, Inc. as its attorney-in-fact 5. Name and address of every other person who has any record lien on the property: Name Address East Pennsboro Township 98 South Enola Drive, Enola, PA 17025 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St. 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 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November 9, 2009 UDREN W ES, P.C. BY: Attorn s for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE /LbUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in- fact Plaintiff v. Karena J. Winters Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-4763 CIVIL TERM TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Karena J. Winters PROPERTY: 212 North 2nd Street, (East Pennsboro Township) Enoia, PA 17025 improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 9. 2009, at 10:00 am, in the Commissioners Hearing Room 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the safe. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. 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MINATO, ESQUIRE - ID #7~i860 CHANDRA M. ARKEMA, ESQIIIRE - ID #203437 LOIIIS A. SIMONI, ESQIIIRE - ID #200869 ADAM L. RAYES, ESQIIIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PL~NT~*F ~ .~ 'T'~ ~' c~~ --r ~1 v,Y ~ SZ ` _ _ t rn r_r~ <:~ '? -t, =~ ~ == -'c: .~- ;--t Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundvievr Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its € attorney-in-fact €NO. 07-4763 CIVIL TERM Plaintiff v. Karena J. Winters De f endant i s ) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November 2, 2009 UDREN ,--8'FF'S~~, -P7C . B ,/ At t orne~ts ~~~ f Or- ~P ~ant~i f f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ~~~~~~~ ~ i ~~ t 1)eutseite 13stnl: i rust C: ss..~nreriea~. a4 7'rustre. et, u.. Fiaitt€tt(s) yrs. karen~ J. 11~:irtfers, et. al.. T)eCentiant(sI ~1W. tlenni Cremns:trf l t 1 ~i'aodcrest_Ftd, Ste_20fi i~err*," t3ilt, !4~l FtFi011a-3~?U ~;crviee a(I'races~ 1rti _ ~P~± rnt~rnnrions~4. ~tt~. .iPC t°~"tt"R`''~ icr~.~~, a,3'~ intern~tionat Pta ~:-- ^f6{li:M Gieeres!r Rai. 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