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HomeMy WebLinkAbout07-6005UDREN 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 LaSalle Bank National :COURT OF COMMON PLEAS Association, as Trustee and :CIVIL DIVISION Custodian for Morgan Stanley, MSAC 2007-HE1 Cumberland 4708 Mercantile Drive Ft. Worth, TX 76137 Plaintiff V. Colleen F. Viccaro County 640 Bosler Avenue : NO. 01_ (Doo5 Lemoyne, PA 17043 Defendant (s) C*Ivl( erm COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones 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 PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: LaSalle Bank National Association, as Trustee and Custodian for Morgan Stanley, MSAC 2007-HEl 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: 640 Bosler Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Lemoyne COUNTY: Cumberland DATE EXECUTED: 7/31/06 DATE RECORDED: 8/2/06 BOOK: 1960 PAGE: 3429 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 10/3/07: Principal of debt due $91,409.18 Unpaid Interest at 9.849& from 5/1/07 to 10/3/07 (the per diem interest accruing on this debt is $24.64 and that sum should be added each day after 10/3/07) 3,797.09 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $128.07 and that sum should be added on the first of each month after 10/3/07) 179.67 Late Charges (monthlyy late charge of $39.73 should be added in accordance with the terms of the note each month after 10/3/07) 170.73 Fees 186.50 Attorneys Fees (anticipated and actual to 50 of principal) 4,570.46 TOTAL $100,918.63 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $100,918.63 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. /W) Mark J. U reh, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT PARCEL OF LAND IN BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 275, PAGE 4819, ID# 12-22-0824-130, BEING KNOWN AND DESIGNATED AS ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED IN ACCORDANCE WITH A OF SURVEY R.J. WALKER DATED SEPTEMBER 4, 1970, AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE SOUTHERLY LINE OF BOSLER AVENUE, WHICH POINT IS 20 FEET EAST OF THE SOUTHEASTERLY CORNER OF SEVENTH STREET AND BOSLER AVENUE; THENCE ALONG THE SOUTHERLY LINE OF BOSLER AVENUE NORTH 58 DEGREES 00 MINUTES EAST, 20 FEET TO A POINT; THENCE SOUTH 32 DEGREES 00 MINUTES EAST, 150 FEET TO A POINT ON THE NORTHERLY LINE OF APPLE ALLEY; THENCE ALONG THE SAME SOUTH 58 DEGREES 00 MINUTES WEST, 20 FEET TO A POINT; THENCE NORTH 32 DEGREES 00 MINUTES WEST AND THROUGH THE CENTER OF A PARTITION WALL ONE HUNDRED FIFTY FEET TO A POINT, THE PLACE OF BEGINNING. BEING PREMISES KNOWN AS 640 BOSLER AVENUE, LEMOYNE, PENNSYLVANIA. DEED FROM ANGELIA K. CAMPBELL, BY HER ATTORNEY IN FACT, LINDA K COOPER, MARRIED AS SET FORTH IN DEED BOOK 275, PAGE 4819 DATED 07/31/2006 AND RECORDED 08/02/2006, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA. Page 4 August 13, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The HOMEOWNFRD MORTGAGE, ASSISTANCE, PROGRAM (HF.MAZ may he ship to help n Pump. ronr hnme_ This Notice exniains how the. prngram works. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO OHOMEOWNERQS EMERGENCY MORTGAGE ASSISTANCE PROGRAMD EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page ] of l EXHIBIT A HOMEOWNER'S NAME(S): -Colleen F. Viccaro PROPERTY ADDRESS: 640 Bosler Avenue LOAN ACCT. NO.: _ 2000196085 ORIGINAL LENDER: Decision One Mo __ a e Com, pan„ y, CURRENT LENDER: Deutsche Bank _._..___.__?____.___.____________ HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOTT MAY RF, ELIGTHLE, FOR FTNANC'IAL ASSISTANCE WRTC'H CAN SAVE. YOUR ]HOME. FROM FORE,CLOSITRF. AND HRLP YOU MAKE FUTURE MORTGAGF. PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE GACTO), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAV OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a dface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TATS MEETING,: MUST OC'CITR WITM ASSTSTANCF, YOU MTTST RRTNC,,YOTJR MORTCTACTF, TIP TO DATE. THF, PART OF THIS NOTICE CAT LED OT40W TO C1 IRE YOTJR MORTGAGF DEEATJT.TO, EXPLAINS HOW TO BRING YOT JR MORTGACM T JP TO DATE, C'ONSTTMFR CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and tele»hnne numbers are get forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender imm_ edi ateel of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. Page 2 of 2 YOU MITST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AC.FNCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES 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.) NATI RR OF THE DFEATILT _ The MORTGAGE debt held by the above lender on your property located at: 640 Bosler Avenue Lemoyne, PA 17043 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: Monthl Payments of 922.85 for June 1, 2007 throTgh ?u?ust 1 2007 =_$276$5,___.___ Mo %ftjaate Charles of $39.73 for hjoe 1-, 2007 through Ju 2007 = 79.46 __ Other charges (explain/itemize): Other Fee= $75.00 Property Inspection= $9.50 - Accmmulated Late Fee=X11.$1___,_ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Db not use i f not applicahle): NLA NOW TO CURE THE. DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2444.32, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must h made either by each cashiers check. certified check or mnn mniP? ms?rie payee and sent tc You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not ap plicahle ): 1A Page 3 of 3 TF YOL1 DO NOT CURE THE DEFAULT ._ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lend r intends to exercise its rights to accelerate the mortgage, de -t This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within. THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged pr tnerty IF THE, MORTGAGE TS F0RF.rL0SFn UPON _ 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 cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cur the default "within the THIRTY (3fl DAY rin you will not he required to pay attorney's fees OTHER UNDER REMEDIES - 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. RWHT TO CURE. THE DF.FATJ T PRIOR TO SHERIFF'S SAL F _ If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you -still have thet to cur the d fault and prevent the sale at any time inn to one hour before the 9heriffc Q. 1P Yov may and na)dn .the total mount then nact chip . Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. F.ARL,IEST POSSTRTE CHFRIFF'S SAT F DATF _ It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately ---6-- months from the date of this Notice. A notice of the actual date of the 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 fmd out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: Sgxon_Mortgj Address: 4708 Mercantile Drive North Fort Worth 76137_??_ Phone Number: 888-325-3502„? Fax Number: Contact Person: Loss Mitigation lossmit saxonms?.com EFFECT OF SHERIFF'S SAL 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 after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender. at any time. ASSTYMMON OF MORTGAGE -- You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 4 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of 5 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX. (717) 541-4670 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 17104 (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 Y r i oN xo8 Od 1o j : zl r3 C3 C3 Er of yuaS Lr' Cr' C C $ 8-:1 g 4DftSOd IW1 LNa LL_? L•V Ln Ln (peiinbedyuropu3) O C3 ea=l k.0e0 Payo.Js%4 CO (peg nbey yuetaompu3) CC 3 O 41 HAEWI60d ee3 jdjeaslj Wnyed 3 ? m (1 ae? peollie:, C C1 tJ a0eisod Cr Cf C3 0 Cr Er M C3 CTS m • • "IIVW 031-4118331 •d cc ui Z ti w D C?3 d tgp W ¢ Cr Ca LLZ Q Cr cc SUOcc z w LU cc rcr 0 L) 0 0 r o U?? liZ, <Zj CQ) X T Certified Mali Provides: s A mailing receipt to A unique identifier for your ma€$siece e A record of delivery kept by the Postal Service for two years Important Reminders: s Certified Mail may ONLY be combined with First-Class Malle or Priority Mail4 • Certified Mail is not available for any class of international mail. o NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. Foi valuables, please consider insured or Registered Mail. ro For an additional fee, a Ratum Receipt may be requested to provide proof of delivery. To obtain Retum Receipt service , please complete and attach a Return Receipt (PS Form 3811) to the article and add app€icable postage to cover this fee. Endorse mailpiece 'Return Receipt Requested". To receive a tee waiver for a duplicate to return receipt, a USPS9 postmark on your Certified Mail receipt is, M For an additional fee, delivery may be restricted to the addressee or addressee's authorized anent. Advise the clerk or mark the mailpiece with the: endorsement 'RestrlctedTeUvW. m If a postmark on the Certified Mail receipt is desired, pease present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail. receipt is not needed, detach and affix label with postage and mail. IMPORTANT, Save this receipt and present it when making an inquiry, PS Form 3800, August 2006 (Reverse) PSN 7530-02-000-9047 1 V 1 I a' t' .p C3 C3 C7 O O Ln ru ..rt d C3 r%- cc E m a E 8 9 cli 1105 L LL co .? LL N (L V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Marx J. uaren, ESQUIRE UDREN LAW OFFICES, P.C. ICA- 00 3 ?? ?v - W ° ?• --- rv T rT7 , . -r c UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee :COURT OF COMMON PLEAS and Custodian for Morgan :CIVIL DIVISION Stanley, MSAC 2007-HE1 :Cumberland County Plaintiff V. :NO. 07-6005 CIVIL TERM Colleen F. Viccaro Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: November 20, 2007 UDREN LAW OFFICES, P.C. BY: MAr4 J . \U(Yen, Esquire At rney or Plaintiff V E R I F I C A T 1 0 N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: }? 4 I"a.. Colleen F. Viccaro Loan #2000196085 MJU #07070543 Name : 'I- Title: PVV Company: Saxon Mortgage Services, Inc. as servicer on behalf of LaSalle Bank National Association, as Trustee and Custodian for Morgan Stanley, MSAC 2007-HEl r- ? ? ?_ ? ....? :' ??.: ^'ii } ? ? \..?1{ .y ""` y ..? Y LaSalle Bank National Association, COURT OF COMMON PLEAS as Trustee and Custodian for Morgan CIVIL DIVISION Stanley, MSAC 2007-HE1 4708 Mercantile Drive Ft. Worth TX- 76137 Cumberland County V. Colleen F. Viccaro No. 07-6005 Civil Term 640 Bosler Avenue Lemoyne, PA :17043 ANSWER TO COMPLAINT IN CIVIL ACTION Filed on Behalf of: Colleen F. Vicaro, Defendant Counsel of Record for this Party: Brian J. Bleasdale, Esquire PA I.D. Pa. I.D. #90576 BLEASDALE LAW OFFICE 931 Chislett Street Pittsburgh, PA 15206 (412) 726-7713 LaSalle Bank National Association, COURT OF COMMON PLEAS as Trustee and Custodian for Morgan CIVIL DIVISION Stanley, MSAC 2007-HE l 4708 Mercantile Drive Ft. Worth TX 76137 Cumberland County V. Colleen F. Viccaro No. 07-6005 Civil Term 640 Bosler Avenue Lemoyne, PA 17043 ANSWER TO COMPLAINT IN CIVIL ACTION AND NOW, comes Colleen F. Viccaro by and through her attorney, Brian J. Bleasdale, Esquire, and the Bleasdale Law Office, and files the following Answer To Complaint In Civil Action wherein the following is averred: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. It is denied that required payments have not been made and that said sums are immediately due. 5. Admitted. 6. Denied. The Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the allegation that the stated amounts in Plaintiff s Complaint are accurate, and therefore this allegation is denied and strict proof is demanded at the time of trial. 7. Plaintiffs corresponding paragraph is a conclusion of law to which no response is required. 8. Denied. The Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the allegation that Act 6 and Act 91 Notice(s) were forwarded properly to Defendant, and therefore this allegation is denied and strict proof is demanded at the time of trial. WHEREFORE, the Defendant, respectfully request that the Plaintiff's Complaint be dismissed with prejudice and that judgment be entered in her favor and against the Plaintiff plus cost of suit as sustained. Respectfully submitted, BLE,ASDALE LADS' OFFICE By: Brian J. Bleasdale, Esquire Counsel for Defendant VERIFICATION I, Brian J. Bleasdale, Esq., verify that the statements made in this Answer to Complaint in Civil Action are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unworn falsification to authorities. November 28, 2007 Date (Signature of Defendant or Authorized person) .r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee :COURT OF COMMON PLEAS and Custodian for Morgan :CIVIL DIVISION Stanley, MSAC 2007-HEl :Cumberland County 4708 Mercantile Drive Fort Worth, TX 76137 :MORTGAGE FORECLOSURE Plaintiff V. Colleen F. Viccaro ::NO. 07-6005 CIVIL TERM 640 Bosler Avenue Lemoyne, PA 17043 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Colleen F. Viccaro 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 $100,918.63 Interest Per Complaint 1,182.72 From 10/4/07 to 11/20/07 Late charges per Complaint 79.46 From 10/4/07 to 11/20/07 Escrow payment per Complaint 128.07 From 10/4/07 to 11/20/07 TOTAL $102,308.88 I hereby certify that (1) the addresses of the Plaintiff nd Defendant are as shown above, and (2) that notice has been given in cordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW FICES, P.C. Mar J. Udren, E Atto v for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE : /l?oZo?O9 INDICATED S PROTHY b VDRSN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Require ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003 856-669-5400 nleadinasludron.com LaSalle Bank National Association, as =COURT OF COMMON PLEAS Trustee and Custodian for Morgan Stanley, :CIVIL DIVISION MSAC 2007-HE1 '-Cumberland County Plaintiff = V. Colleen F. Viccaro Defendant(s) NO. 07-6005 Civil Term TO: Colleen F. Viccaro 640 Bosler Avenue Lemoyne, PA 17043 DATE of Notice: November 8, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249=3166 600-990-9108 NOTIFICACION IMPORTANTR USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO TEE FAIR DEBT COLLECTIOTHIS LhW FIRS IS DRZKRD TO DE A DEBT COLL R THIS IS LLECT A DEBT. ANY INFORMATION OBTAINED NIL 8 U THAT t ren, Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 Ft. Worth, TX 76137 Plaintiff NO. 07-6005 Civil Term V. Colleen F. Viccaro 640 Bosler Avenue Lemoyne, PA 17043 Defendant(s) ATTORNEY FOR PLAINTIFF LaSalle Bank National :COURT OF COMMON PLEAS Association, as Trustee and :CIVIL DIVISION Custodian for Morgan Stanley, :Cumberland County MSAC 2007-HEl 4708 Mercantile Drive ;MORTGAGE FORECLOSURE UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-69,00 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF . 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: Colleen F. Viccaro Over 18 As captioned above Unknown Sworn to and subscribed Name : t-?0L H?5 C Title Company: Saxon Mortgage Services, Inc. as servicer on behalf of LaSalle Bank National Association, as Trustee and Custodian for Morgan Stanley, MSAC 2007-HEl JAMES C. MORRIS NOTARY PUBLIC - MINNESOTA EXPIRES JAN. 311, 009 1119 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06005 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS VICCARO COLLEEN F SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon VICCARO COLLEEN F the DEFENDANT , at 2048:00 HOURS, on the 18th day of October , 2007 at 640 BOSLER AVENUE LEMOYNE, PA 17043 by handing to COLLEEN VICCARO a true-and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of 18.00 15.36 .00 10.00 .00 43.36 day So Answers: 10000 _o? 11.1 R. Thomas Kline 10/19/2007 UDREN LAW OFFTCPS A ra S6 po UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee :COURT OF COMMON PLEAS and Custodian for Morgan :CIVIL DIVISION Stanley, MSAC 2007-HEl ::Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE : Colleen F. Viccaro NO. 07-6005 CIVIL TERM Defendant(s) To: Colleen F. Viccaro 640 Bosler 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. Prothonotary X Judgment by Default 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 Il/aa/07 /-S/ a.4-0, fox, 046 f UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee =COURT OF COMMON PLEAS and Custodian for Morgan :CIVIL DIVISION Stanley, MSAC 2007-HEl :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Colleen F. Viccaro :NO. 07-6005 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $102,308.88 Interest From 11/21/07 2,611.84 to Date of Sale 3/5/08 Ongoing Per Diem of 24.64 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAK OFFICES, P.C. ATT&&EY v FOR+.PLAINTI FF n AJ, EA 8 0 F 00 '0 N e.:) C;=) N CD ..Zw W ?«h CA) 2 €l t • UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee :COURT OF COMMON PLEAS and Custodian for Morgan :CIVIL DIVISION Stanley, MSAC 2007-HE1 :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Colleen F. Viccaro :NO. 07-6005 CIVIL TERM Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. REN LAW OFFICES, P.,Z. lark J. Udren,` QUIRE TTORNEY FOR PLAINTIFF c z ca -? a Y. r 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 LaSalle Bank NA, as Trustee =COURT OF COMMON PLEAS and Custodian for Morgan :CIVIL DIVISION Stanley, MSAC 2007-HEl :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Colleen F. Viccaro :NO.- 07-6005 CIVIL TERM Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF AFFIDAVIT PURSUANT TO RULE 3129.1 LaSalle Bank NA, as Trustee and Custodian for Morgan Stanley, MSAC 2007-HE1, 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: 640 Bosler Avenue, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s): Name Address Colleen F. Viccaro 2. Name and address Name SAME AS #1 ABOVE 3. Name and address record lien on the Name 640 Bosler Avenue Lemoyne, PA 17043 of Defendant(s) in the judgment: Address of every judgment creditor whose judgment is,a real property to be sold: Address CACV of Colorado, LLC 1999 Broadway, Denver, CO 80202 c/o Robert M. Reibstein, Esquire 705 Montgomery Avenue Narbeth, PA 19072 4. Name and address of the last recorded holder of every mortgage of record: Name Address LaSalle Bank NA, as Trustee 4708 Mercantile Drive and Custodian for Morgan Fort Worth, TX 76137 Stanley, MSAC 2007-HEl 1 t 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 640 Bosler Avenue Lemoyne, PA 17043 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. i UDREN LAW OFFICES, P.C. DATED: November 20, 2007 rk \Z/ Udren, ksQ% torney for Plaintiff C V UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee ;COURT OF COMMON PLEAS and Custodian for Morgan =CIVIL DIVISION Stanley, MSAC 2007-HEl :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Colleen F. Viccaro NO. 07-6005 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Colleen F. Viccaro 640 Bosler Avenue Lemoyne, PA 17043 Your house (real estate) at 640 Bosler Avenue, Lemoyne, PA 17043 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 $102,308.88, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6005 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NA, as Trustee and Custodian for MORGAN STANLEY, MSAC 2007-HE1, Plaintiff (s) From COLLEEN F. VICCARO (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 $102,308.88 L.L.$ 0.50 Interest from 11/21/07 to Date of Sale 3/05/08 Ongoing Per Diem of $24.64 to actual date of sale including if sale is held at a later date -- $2,611.84 Atty's Comm % Atty Paid $162.36 Plaintiff Paid Date: 11/20/07 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Due Prothy $2.00 Other Costs rBy: Deputy SHERIFF'S RETURN - REGULAR CASE NO: 2007-06005 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS VICCARO COLLEEN F SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon VICCARO COLLEEN F the DEFENDANT , at 2048:00 HOURS, on the 18th day of October , 2007 at 640 BOSLER AVENUE LEMOYNE, PA 17043 by handing to COLLEEN VICCARO a true-and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 4- So Answers: 18.6 15.336 .00 p 10.00 R. Thomas Kline nn \/43.36 10/19/2007 UDREN LAW OFFICES By. day eputy Sheri A.D. Sworn and Subscibed to before me this of March 2008 \ 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 LaSalle Bank NA, as Trustee and ;COURT OF COMMON PLEAS Custodian for Morgan Stanley, :CIVIL DIVISION MSAC 2007-HE1 :Cumberland County 4708 Mercantile Drive Fort Worth, TX 76137 Plaintiff V. Colleen F. Viccaro 640 Bosler Avenue NO. 07-6005 CIVIL TERM Lemoyne, PA 17043 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B.. 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "Big. 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 28, 2008 UDREN -LAW OFFICES, P.C. , BY : -? - t Z. P. sz` , Att6rneys foroWaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE v w? 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 LaSalle Bank NA, as Trustee and Custodian for Morgan Stanley, MSAC 2007-HE1 Plaintiff V. Colleen F. Viccaro Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-6005 CIVIL TERM TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Colleen F. Viccaro PROPERTY: 640 Bosler Avenue, Lemoyne, PA 17043 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. EXHIBITA .,, ; Y YI I m N ci m _ m N c°'O emu. O ? iEis o' ? ? N O In SS R w R C-0> p W N v) AM jz m+ r 7 cr Q ? ? • + Q7 a'$ a o ? y .L. C m c ?p? ? Z, U 0 8 ? ? a D 'a- m o p ymi 'y 'r c ? c ? 3 a 0 W N L - s E m ?N• ? F- 'Fj m m C O " « Yn W is 5 0 0o m ? ? C m T m m ? , ( gg pp, al C ? QE 6 m o O ? N G 0 a, b G `1 G ?'€5 ? m m A AT cSZEE 9 ? °°° mvE m m o ? R m ¢ N m O 3 ? Q m { p p80 `o owyN? • m ? c t6 O co 3a a w o E rn G N o oQ E ? n Y ? ??m = a ` .o •? 7 E6 _ LL m ? G LLt 0 41 uj H' O m T ? 2 p? ° o ? y d x C> ? O 4 4 W04.Z G N p 4 ul NNZ i m W j 0 M tV?rs ? 04. J ? v o C, va j ?jM G E °° b? (0 4 v4Z ? u N n ?' Z?Qu u.o N ?dr? 3N= m m NOG gvo a ?= ~ c Z 111._ ? c n m m . i ? e[ 7? W v U ? z r 3 N ? QZ M ? N m Zx - J r ? m N Q O t u°G,? ; ga. N O m ;a Imo 07- -a ci u. 4 7- O = y$ 0 -0 64 z , m ! p U At o 0 0 n.NisW U 0 >) <LpzY o 70 Urn W.2 QNO QO v w U aG 00. cIc.?- C d a G 0 aM W O r m .r. d a n m ? a. y a E ? w rn O c ? y o Z E 0 d ? a o a N I N O Q !? 0 om0. As Z o? F^ _ ul e! 0 P- O 0 M O ? T T T, N T ` d T c? m a_ ° to c -a m ? .J N M It CD ,D 0 00 01) jgvT A rn w N LL N Cl) t LL U) a- ?G G 7 ILI) M UD O 3 0 0 co V L1. m Q U C"a ^a r? n j f( a..y.? 4?MJ ? tl '4 ?Z t z 5 CD ? LaSalle Bank NA as Trustee and Custodian In the Court of Common Pleas of For Morgan Stanley, MSAC 2007-HE1 Cumberland County, Pennsylvania VS Writ No. 2007-6005 Civil Term Colleen F. Viccaro Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on December 04, 2007 at 1951 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: Colleen F. Viccaro, by making known unto Colleen F. Viccaro, personally at 640 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copies of the same. Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 1039 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Colleen F. Viccaro located at 640 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Colleen F. Viccaro by regular mail to her last known address of 640 Bosler Avenue, Lemoyne, PA 17043. These letters were 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 Mark Udren. Sheriffs Costs: Docketing 30.00 Poundage 18.52 Advertising 15.00 Posting Bills 15.00 Law Library .50 Prothonotary 2.00 Mileage 28.80 Levy 15.00 Surcharge 20.00 Postpone Sale 40.00 Law Journal 371.00 Patriot News 372.59 Share of Bills 16.17 n $ 944.58 ? X113 /Or l,o CIP vpak So - C. e ? "e &Z., r. 0 R. Thomas Kline, Sheriff BY & Real Estate rgeant UDREN'LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF HY: Mask J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee :COURT OF COMMON PLEAS and Custodian for Morgan :CIVIL DIVISION Stanley, MSAC 2007-HEl :Cumberland County Plaintiff V. 'MORTGAGE FORECLOSURE Colleen F. Viccaro :NO. 07-6005 CIVIL TERM Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 LaSalle Bank NA, as Trustee and Custodian for Morgan Stanley, MSAC 2007-HE1, 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: 640 Bosler Avenue, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed owner(s): Name Address Colleen F. Viccaro 640 Bosler 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 CACV of Colorado, LLC 1999 Broadway, Denver, CO 80202 c/o Robert M. Reibstein, Esquire 705 Montgomery Avenue Narbeth, PA 19072 4. Name and address of the last recorded holder of every mortgage of record: Name Address LaSalle Bank NA, as Trustee 4708 Mercantile Drive and Custodian for Morgan Fort Worth, TX 76137 Stanley, MSAC 2007-HEl 4 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 640 Bosler Avenue Lemoyne, PA 17043 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: November 20, 2007 rk \11 Udren, torney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 LaSalle Bank NA, as Trustee '--COURT OF COMMON PLEAS and Custodian for Morgan 'CIVIL DIVISION Stanley, MSAC 2007-HE1 :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Colleen F. Viccaro €NO. 07-6005 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Colleen F. Viccaro 640 Bosler Avenue Lemoyne, PA 17043 Your house (real estate) at 640 Bosler Avenue, Lemoyne, PA 17043 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 $102,308.88, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if.you act immediately after the sale. YOU SHOULD 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 ALL THAT PARCEL OF LAND IN BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 275, PAGE 4819, ID# 12-22-0824-130, BEING KNOWN AND DESIGNATED AS ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED IN ACCORDANCE WITH A OF SURVEY R.J. WALKER DATED SEPTEMBER 4, 1970, AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE SOUTHERLY LINE OF BOSLER AVENUE, WHICH POINT IS 20 FEET EAST OF THE SOUTHEASTERLY CORNER OF SEVENTH STREET AND BOSLER AVENUE; THENCE ALONG THE SOUTHERLY LINE OF BOSLER AVENUE NORTH 58 DEGREES 00 MINUTES EAST, 20 FEET TO A POINT; THENCE SOUTH 32 DEGREES 00 MINUTES EAST, 150 FEET TO A POINT ON THE NORTHERLY LINE OF APPLE ALLEY; THENCE ALONG THE SAME SOUTH 58 DEGREES 00 MINUTES WEST, 20 FEET TO A POINT; THENCE NORTH 32 DEGREES 00 MINUTES WEST AND THROUGH THE CENTER OF A PARTITION WALL ONE HUNDRED FIFTY FEET TO A POINT, THE PLACE OF BEGINNING. BEING PREMISES KNOWN AS 640 BOSLER AVENUE, LEMOYNE, PENNSYLVANIA. DEED FROM ANGELIA K. CAMPBELL, BY HER ATTORNEY IN FACT, LINDA K COOPER, MARRIED AS SET FORTH IN DEED BOOK 275, PAGE 4819 DATED 07/31/2006 AND RECORDED 08/02/2006, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA. BEING KNOWN AS: 640 BOSLER AVENUE, LEMOYNE, PA 17043 PROPERTY ID NO.: 12-22-0824-130 TITLE TO SAID PREMISES IS VESTED IN COLLEEN F. VICCARO, SINGLE BY DEED FROM ANGELIA K. CAMPBELL, BY HER ATTORNEY IN FACT, LINDA K. COOPER, MARRIED DATED 7/31/06 RECORDED 8/2/06 IN DEED BOOK 275 PAGE 4819. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6005 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NA, as Trustee and Custodian for MORGAN STANLEY, MSAC 2007-HE1, Plaintiff (s) From COLLEEN F. VICCARO (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 $102,308.88 L.L.$ 0.50 Interest from 11/21/07 to Date of Sale 3/05/08 Ongoing Per Diem of $24.64 to actual date of sale including if sale is held at a later date -- $2,611.84 Atty's Comm % Due Prothy $2.00 Atty Paid $162.36 Other Costs Plaintiff Paid Date: 11/20/07 othonotary (Seal) By: REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Deputy Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale #49 On November 27, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA Known and numbered as 640 Bosler Ave., Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. oa?o Date: November 27, 2007 By: Q&W-9- 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 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 notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SW&Rlb70 AND SUBSCRIBED before me this 8 day of February, 2008 C Notary ORAH A COLLINS FCAMRLISLe OTARIAL SEAL otary Public O, CUMBERLAND COUNTY on Expires Apr 28, 2 010 RZAL IiWATE SALE NO. 49 Writ No. 2007-6005 Civil LaSalle Bank NA as Trustee and Custodian for Morgan Stanley, MSAC 2007-HE I VS. Colleen F. Viccaro Atty.: Mark Udren DESCRIPTION ALL that parcel of land in Borough of Lemoyne, Cumberland County, State of Pennsylvania, as more fully described in Deed Book 275, page 4819, ID# 12-22-0824-130, being known and designated as ALL that certain piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and de- scribed in accordance with a survey of R.J. Walker dated September 4, 1970, as follows, to wit: Beginning at a point on the south- erly line of Bosler Avenue, which point is 20 feet east of the south- easterly corner of Seventh Street and Bosler Avenue; thence along the southerly line of Bosler Avenue north 58 degrees 00 minutes east, 20 feet to a point; thence south 32 degrees 00 minutes east, 150 feet to a point on the northerly line of Apple Alley; thence along the same south 58 degrees 00 minutes west, 20 feet to a point; thence north 32 degrees 00 minutes west and through the center of a partition wall one hun- dred fifty feet to a point, the place of beginning. Being premises known as 640 Bosler Avenue, Lemoyne, Pennsyl- vania. Deed from Angelia K. Campbell, by her attorney in fact, Linda K. Cooper, married as set forth in Deed Book 275, Page 4819 dated 07/31/2006 and recorded 08/02/2006, Cumber- land County records, Commonwealth of Pennsylvania. Being known as: 640 Bosler Av- enue, Lemoyne, PA 17043. Property ID No: 12-22-0824-130. Title to said premises is vested in Colleen F. Viccaro, single by deed from Angelia K. Campbell, by her at- torney in fact, Linda K. Cooper, mar- ried dated 7/31/06 recorded 8/2/06 in Deed Book 275 ??? page 4819. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE 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 z4f Pd tflotANNIfW5 Now you know 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 02106108 02113/08 Ah"O... Sworn to before ;ebruary, 2008 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notary Public =Of"Wrisburg, SQal aurnin county ,'. 'Iov. 26, 2011 Member,Panneylvania Assoclatlon of Notaries REAL ESTATE SALE NO. 49 Writ No. 200741005 Civil Term LaSalle Bank NA as Trustee and Custodian for Morgan Stanley,. MSAC 2007-HE1 VS Colleen F. Viccaro Attorney Mark Udren DESCRIPTION ALL. that parcel of land in Borough of Lemoyne, Cumberland County, State of Pennsylvania, as more fully described in Deed Book 275, page 4819, ID# 12-22-0814-130, being known and designated as ALL that certain piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey of R.J. Walker dated September 4, 1970, as follows, to wit: Beginning at a point on the southerly line of Bosler Avenue, which point is 20 feet east of the southeasterly comer of Seventh Street and Bosley Avenue; thence along the southerly line of Bosley Avenue north 58 degrees 00 minutes east, 20 feet to a point; thence south 32 degrees 00 minutes east, 150 feet to a point on the northerly line of Apple Alley; thence along the same south 58 degrees 00 minutes west, 20 feet to a point; thence north 32 degrees 00 minutes west and through the center of a partition wall one hundred fifty feet to a point, the place of beginning. Being premises known as 640 Bosler Avenue, Lemoyne, Pennsylvania. Deed from Angelis IC Campbell, by her attomey in fact, Linda R Cooper, married as set forth in Deed Book 275, page 4819 dated 07/31/2006 and recorded 08102/2006, Cumberland County records, Commonwealth of Pennsylvania. Being known as: 640 Bosler Avenue, Lemoyne, PA 17043 Property ID No: 12-22-0824-130 Tide to said premises is vested in Colleen F. Viccaro, single by deed from Angelia K Campbell, by her attorney in fact, Linda K. Cooper, married dated 7/31/06 recorded 8/2/06 in Deed Book 275 page 4819. " ?1 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com LaSalle Bank NA, as Trustee and Custodian for Morgan. Stanley, MSAC 2007-HEl Plaintiff V. Colleen F. Viccaro Defendant: ATTORNEY FOR PLAINTIFF ::COURT OF COMMON PLEAS =CIVIL DIVISION Cumberland County -NO. 07-6005 CIVIL TERM PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: May 30, 2008 UDREN P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ..?: ??