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HomeMy WebLinkAbout07-6095GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. DUSTIN L. HUNTER Mortgagor and Real Owner 478 Stonehouse Road Carlisle, PA 17015 Plaintiff Defendant Term No. b,7 - (o0Q5 Civi I -rerrn CIVIL ACTION: MORTGAGE NOTICE 7-CRECLOSURE 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 the 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 claim in the Complaint of 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-776-0100 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionAgoldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 57461FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1, 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005. 2. The names and addresses of the Defendant is DUSTIN L. HUNTER, 257 Allen Road, Carlisle, PA 17015, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On October 26, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to FIRST NLC FINANCIAL SERVICES, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1971, Page 357. The mortgage has been assigned to: LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE 1 by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for June 01, 2007 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance .................... ...............$134,814.26 Interest from 05/01/2007 through 10/31/2007 at 8.5000% ....................... $5,777.59 Per Diem interest rate at $31.40 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$6,740.71 Late Charges from 06/01/2007 to 10/31/2007 .............................................$240.89 Monthly late charge amount at $48.18 Costs of suit and Title Search ...................................................................... $900.00 Property Inspections .......................................................................................$20.50 BPO ..............................................................................................................$100.00 $M48,593.95 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $148,593.95, together with interest at the rate of $31.40, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: LD ECK McCAFFERTY & MCKEEVER BY: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I Josh Lade , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: 0, OCA - ?2 L T) LaS A., as Trustee for the MLMI T s2007-HEI, by Wilshire Credit Corporation its Attorney in Fact Josh Lade Authorized Agent #4130803 - DUSTIN L. HUNTER E..x..hibitA A.L.T.A. COMMITMENT CHICAGO TITLE INSURANCE COMPANY Commitment No.: 3211•S SCHEDULE C The land referred to in this Commitment is described as follows: ALL that certain tract of land situated in the Township of Dickinson, County of Cumberland and State of Pennsylvania, more fully described as follows, to wit: BEGINNING at a point in the Mount Rock Road leading from Walnut Bottom Road to the Ritner Highway at corner of lands now or formerly of Alice M. Moore known as the Stone House lot; thence by the Stone House lot South 70 degrees West 150 feet; thence by land now or formerly of J. Earl Weibley and wife, North 17 degrees 13 minutes West 110 feet; thence by the same North 70 degrees East 150 feet to the center of Mount Rock Road; thence by the center of said road South 17 degrees 13 minutes East 110 feet to the place of BEGINNING OK1971PG0373 E..x.,hibit B I or,- ":ron Loan Nuntla Oete 1130903 ml-? NUNTE DMINNLL` ale STONE}IQUW RD CARLISLE PA 17015 1502 - MLad2DW44E1 CSS - OMNEN 99 - 3RD PARTY sERvcM 12202006 -1? 1 $130,816.47 a m% 9MrWaypayment 5969.56 Payrnem $969.58 p Psymem Date 6na2w wt Out Date 81012007 Oue 1026/2008 arSy Data 11N72RT8 :0 so zerd CLTV oa.nn $0.00 0 Tlxu due ud Lion Amoud will ea Bk UM date hrxlon Due 6k ChWw nt tax amoua $0.00 ncy Oslo Tax Amount slaral Vdue std Vdus xx"RUe Or Lion Amolrt real Senior Lion f0,00 25 tl 0elln ueni Tax 50.00 LArnn Debvpwx Tad Foredosua Cesb (114.5 20 Forecloaue Trannr tad (ss,a )-07 $0.00 Flue Property Tax (S2 7 07 S0 00 15 , Variute REO . 07 carry coats 51.2 $0.00 07 10 Evictioft Cone (57. 5979.56 ?T $000 Traehout cads ($1,51 50.00 $0.00 5000 °T $0.00 a ixed Mw Sale Cans Brdcara Fw (SZ,185.0c {SA220.00 a 5979 61 ° Tmrsfar Tax F 11 . A ared PlaeeO xtaurartee (53,856. pr-07 ,my.ar Anr07 luFOT AupOT e.Pa7 Nsl scum 5101,027.23 BA ampts ¦ Contacts O In 9 skip LOU sia Aty ( -? 11 Value FCIREO ExprWea 137,000,10 (535,972.77) .-"- ,- - - , SWorUon 50.00 COMMENDATION: INITIATEF?O N REP y Position 1 . _ : PK ST CONTACT: C M3107, SPK W/ CUST, WORK SLOW, UNABLE TO AFFORD MTG N $ 01,027,23 CHECKED PHFA WESSITE, NO AppS RECV , O PP SETUP, NO PP ON FILE, FINAL CALL: 9123107, RNN ,. Ddklency SKIP TRACE: WA NOI EXP: 6/30107 SR STATUS: WA R OF R: WA FIELD CALLS: WA DELAY DUE TO: DRT RENEW: N/A era Tax Arrmn 5100 M"WMM TAX DBCISION l COM MTS Q Pa t y axes and c"e b "a" aceoum ? elor ? Period O Pay tax and open a ahaape on the main ban ° mendation Pay Don't Pay 13 Dont pay and set disposal coda Q Dont Pay Sad Dkwondnue Tax bwvnp aura: Signature: Signature: Nano: Name: Date: Data: F W Wilshire" 4130803 912812007 PRE FORECLOSURE MODEL a812007 7 Upload DOM I Fptrera FC Staan FoNeca BK Stslus ° Reafpl CURTAllEl UanMo kaurrip UN:NSUFtM -- - 1 SPIGlE FAM LY FaM Camara City GRE NO Callslru stab PA 00auplEDBYul9atlwM f'lA. , - - - edA pn --? v wC ofA cfera 00 DWraM a dAOCdaraxart i Danrarrd , Re ie dlpYled rrlaCaMrilldArt914Dam- DW coff~ erta Act 6 Oarrxutd ri Damrd Guarrar NO and GuararesrDwnWded dAmdoetion ErrWamtrtyl Ftoppt NO Norko t Le ter te9r Sam NO rqu9tl y1LlrkttR LOW Laear SerM Osys Odnqurx 113 n OF RVv 1 Low Sot F? Y Alan 2 L Saq State Alan YES 3 OW L Sarll Shon Forarlosm Shwa ND • W Leaer Srd am ordrey Dab 412 7 e Lear sera SPO Type am - Extab e r.er.. x:.w. Nnpectk n Ordered Dau, 61132007 'Wilshire- Wilshire Credit Corporation Payments P.O. Box 7195, Pasadena, CA 91109-7195 July 31, 2007 HUNTER, DUSTIN L L178E 478 STONEHOUSE RD CARLISLE, PA 17415 Correspondence P.O. Box 8517, Portland, OR 97207-8517 Phone 888.917.1052 Fax 503.952.7476 Web Site www.woc.mlCom ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FRAM FORE CLOSURE This is an official notice that the mort a e on our home is in default an the lender intends to foreclose. Sneciffc information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HE-M--APP home. may be able to 16e1- -J o sa1vour This Notice explains how the rogram works WITHIN 30 DAYS OF THE DATE OF THIS NOTICE?Take his notice wDith ouOwhenE oa meet wih the Counseling Agency. the end of this Notice toll-free at 1.800.342.2 This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR.GnANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT To COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE hltp://www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Co Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluodion is licensed to do business at 14523 5. W. Mill lean L178E HUNTER, DUSTIN L Loan No.:4130803 Page 2 July 31, 2007 PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME : HUNTER, DUSTIN L PROPERTY ADDRESS LOAN ACCT. NO. ORIGINAL LENDER CURRENT SERVICER 478 STONEHOUSE RD CARLISLE, PA 170159448 4130803 : OCWEN Wilshire Credit Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHI H CAN SAV O R HOME FROM FORECLOSURE AND HELP YOU MAKE F T RE MORTGAGE PAYMENTS IF YOU-CO APLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAYBE 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. TEMPOI?ARy STA OF FORE ('1 netrroE -Under the Act, you are foreclOSUre on your mortgage for thirty (30) days from the date of this otice.IDu During that temporary y uymust arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. -'- "' i " " E NEXT QM DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE Y U MUST BRING Y01 R MORTGA PTO DATE. THE PART OF THIS :)TICE N_CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW T9 BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT O INS>F1 Il?if sr?*rC?ES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty(30) days after the date of this meeting. The names addresses and telephone n m e f designated consumer credit c unselin agencies for the coup in which the ro i I Gated are set forth at the end of this tics It is only necessaryto schedule one face-to-face meeting. Advise your lender inns- d jM* of your intentions. (Continu YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http:/Av%vw.ago.state_co.us/caddcadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation Way. Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excl ded is licensed to do business at 14523 S. W, Milli kart L/78E HUNTER, DUSTIN L Loan No.:4130803 Page 3 July 31, 2007 APPLICATION FOR MORTGAGE ASSISTANCE later in this Notice (see following pages for specific informattion 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 from the Homeowner's Emergency Mortgage Assistance Program financial assistance . To do so, you must fill out, and file a completed Homeowner's Emergency Assistance Program Application with one of the desi sign gnated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have Housing applications for the program and they will assist you in submitting a complete application to the Pennsylvania Finance Agency. Your application MUST be filed or postmarked within thirty(30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after they receive your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YO IR MORTGAGE nMU T rin it up to date. NATURE OF THE nFFp 1i1 T - The MORTGAGE debt held by the above lender on our ro 478 STONEHOUSE RD Y p party located at: CARLISLE, PA 170159448 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $1,939.16 Late Charges $145.44 Other Charges $11.00 Suspense Amount -$0.00 TOTAL $2,095.60 HOW TO CURE THE DEFA LT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,095.60 PLUS (Continued} YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DE13T COLLECTION PRACTICES ACT, SEE hitp://www.ago, state. co.us/caddcadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR_ Wilshire's office hours are Monday- Friday 6:00 am to 5:00 pm Pacific time, holidays excluded. L17SE HUNTER, DUSTIN L Loan No.:4130803 Page 4 July 31, 2007 ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: Wilshire Credit Corporation, P.O. Box 7195, Pasadena, CA 91109-7195. IF YOU DO NOT C iRE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends t o ex rcise it' ri hL t o n cceI to the This means the entire outstanding balance of the debt will be consid red due immediately annd mayy lose he chance tohat pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct it's attorneys to start legal action to-foreclose upon your oortgaeed property IF THE MORTGAGE I FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to it's attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to actually incurred by the lender even if they exceed $50.00. The attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY X41 DAY Deriod. ill not be reau'red to may attorney's fees. OTHER LENDER R_FMFL)LES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. ALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you stil I have the rittht to cure the default and prevent the sale at an time up to one hour before the Sheriffs -Sale. You may do so by navt o the total amount then ast due an late or other char es then due reasonable attorne s fees an co is con cted with the foreclosure sale an other costs connected with the Sheriffs Sale ass specified in writing b the tender and by performing any other requirements under the mortealre 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 EARL ST POS. IB .F Di I V SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender. HOW TO ONTAC"r'rur r tcrmtcu. Name of Lender : Wilshire Credit Corporation Address Pa ents: P.O. Box 7195, Pasadena, CA 91109-7195 Corres ondence: P.O. Box 8517, Portland, OR 97207-8517 Phone : Toll-Free: 888.917.1052 Fax Number : 503.952.7476 YOU SHOULD CONSIDER THIS LETTER AS -COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER 1S NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago,state.co.ustcadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. Wilshire's office hours arc Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded. L178E HUNTER, DUSTIN L Loan No.:4130803 Page 5 July 31, 2007 Contact : Loan Servicing EFFECT OF SHERIFF' SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property lawsuit to remove you and your furnishings and other belongings could be started by elender th any time. me. a ASSUMPTION OF Me?RTr' a -- - You may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY AL HA THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE MORTGAGE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. If you have any questions, please contact us at our toll-free number above. Sincerely, Loan Servicing Enclosures: PA CCCS List, How to Avoid Foreclosure YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO; FOR INFORMATION UT THE http://H?vw.ago.state.co.us/cadclcademain.cfm. NEW YORK CITY. License 1032551. NORTH CAROLINA: Perm 3g pH T NNESSEE This PRACTICES ACT SEE licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporat Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays exc udedwn is licensed to do business at 14523 S. W. Milliken L178E Ui C o CD r t? ? V ro ? . In the Court of Common Pleas of Cumberland County LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HEI 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff DUSTIN L. HUNTER vs. No. 07-6095 (Mortgagor(s) and Record Owner(s)) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DUSTIN L. HUNTER by default for want of an Answer. Assess damages as follows: Debt Interest from 11/28/2007 to Date of Sale Total (Assessment of Damages attached) $149,489.93 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 r?? k Jo eph A. oldbeck, Jr. Attorney for Plaintiff I.D. #16132 AND NOW Not M1110-1- a$ JM7 , Judgment is entered in favor of LASALLE BANK N.A., AS TRUSTEE FOR MLR-1 TRUST SERIES 2007-HE I and against DUSTIN L. HUNTER by default for want of an Answer and damages assessed in the sum of $149,489.93 as per the above certification. S 1khonotary L If I 57461FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: November 13, 2007 TO: DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HEI 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. DUSTIN L. HUNTER (Mortgagor(s) and Record Owner(s)) 478 Stonehouse Road Carlisle, PA 17015 TO: DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-6095 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 (10) 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Joseph A. Goldbeck. A GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DUSTIN L. HUNTER, is about unknown years of age, that Defendant's last known residence is 478 Stonehouse Road, Carlisle, PA 17015, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: \\ ?? ? GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW DUSTIN L. HUNTER (Mortgagor(s) and Record owner(s)) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 07-6095 ORDER FOR JUDGMENT Please enter Judgment in favor of LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1, and against DUSTIN L. HUNTER for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $149,489.93. Jos ph A. Goldbeck, Jr. Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 and that the name(s) and last known address(es) of the Defendant(s) is/are DUSTIN L. HUNTER, 478 Stonehouse Road Carlisle, PA 17015; OosephlA. cCAFFERTY & McKEEVER B Goldbeck, Jr. Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $134,814.26 Interest from 05/01/2007 through $6,625.39 11/27/2007 Reasonable Attorney's Fee $6,740.71 Late Charges $289.07 Costs of Suit and Title Search $900.00 Escrow Payments Due 0 X $0.00 $0.00 Property Inspections $20.50 BPO $100.00 $149,489.93 LD ECK Mc FERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney for Plaintiff AND NOW, this ole day of 00 V. , 2007 damages are assessed as above. X/ r Prothy 0-- a r7l k r CD ¢s ? c J L w 1 ,?,... Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way - Suite 200 Beaverton, OR 97005 Plaintiff No. 07-6095 vs. DUSTIN L, HUNTER (Mortgagors and Record Owner(s)) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: L-51 D1413 i?as?o7 If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. DUSTIN L. HUNTER Mortgagor(s) and Record Owner(s) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-6095 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 11/28/2007 to Date of Sale at 8.5000% (Costs to be added) $149,489.93 NBBECK c& McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney for Plaintiff w a z tr) CN O o U H°O z? O W F z rn a H x 0 w W W H x u q o o N cn ¢ W Qw Q G? w a a a C? F? O ,j ? W T wo ?? O r, ? Ll! O O y ? .,. 0 ?D ° r- q t? 0 0? ?b c? U v ? b Y ¢ O r, ? .d ° W C7 Ln a ao 9.x W S lv 00 DI -? ,'° C:zp a -,j Q 00 8! {y4r+' a 0 9o v ~ r r7 r-- o a CO J The land referred to in this Commitment is described as follows: ALL that certain tract of land situated in the Township of Dickinson, county of Cumberland and State of Pennsylvania, more fully described as follows, to wit: BEGINNING at a point in the Mount Rock Road leading from Walnut Bottom Road to the Ritner Highway at corner of lands now or formerly of Alice M. Moore known as the Stone House lot; thence by the Stone House lot South 70 degrees West 150 feet; thence by land now or formerly of J. Earl Weibley and wife, North 17 degrees 13 minutes West 110 feet; thence by the same North 70 degrees East 150 feet to the center of Mount Rock Road; thence by the center of said road south 17 degrees 13 minutes East 110 feet to the place of BEGINNING. MUNICIPALITY: TOWNSHIP OF DICKINSON PROPERTY ADDRESS: 478 STONEHOUSE ROAD, CARLISLE, PA 17015 TAX PARCEL #: 08-10-0626-015 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HEl 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. DUSTIN L. HUNTER (Mortgagor(s) and Record Owner(s)) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-6095 LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE I, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 478 Stonehouse Road Carlisle, PA 17015 I.Name and address of Owner(s) or Reputed Owner(s): DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 478 Stonehouse Road Carlisle, PA 17015 VIRGINIA R. ADAMS 917 West Luther Street Carlisle, PA 17013 LES ADAMS D/B/A BUDGET EXCAVATING AND CONTRACTING 23 Frey Lane Galeton, PA 16922 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 27, 2007 CAP x zl?? GOL BECK cCAFFERTY & McKEEVER oseph A. Goldbeck, Jr., Es q. Attorney for Plaintiff c I' ? C7 ?^ co y? 07-6095 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. DUSTIN L. HUNTER Mortgagor(s) and Record Owner(s) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6095 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HUNTER, DUSTIN L. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 Your house at 478 Stonehouse Road, Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $149,489.93 obtained by LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE I, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and IN THE COURT OF COMMON PLEAS 07-6095 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 below 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE, A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6095 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-776-0100 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkgoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 57461 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HEI 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Vs. DUSTIN L. HUNTER Mortgagor(s) and Record Owner(s) 478 Stonehouse Road Carlisle, PA 17015 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 07-6095 I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. '-- A, A K6 Jose h A. Goldbeck, Jr. & ri Attorney for plaintiff ? ? ?- , - c.:? ?..a i . ? ,. ? ?.? °w-„ -r^ fYs'T N --? i,? ? iJ _ -? -- ? •, 7 r_- a_'? ., ? d'G ?;,? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6095 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK N.A., as Trustee for MLMI TRUST SERIES 2007-HE1, Plaintiff (s) From DUSTIN L. HUNTER (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 gamishee(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 $149,489.93 L.L.$ 0.50 Interest from 11/28/07 to Date of Sale at 8.5000% Atty's Comm % Atty Paid $179.52 Plaintiff Paid Date: 11/28/07 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs rotho otary By: Deputy Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 if - CASE NO: 2007-06095 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NA VS HUNTER DUSTIN L MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HUNTER DUSTIN L the DEFENDANT , at 1720:00 HOURS, on the 23rd day of October , 2007 at 478 STONEHOUSE ROAD CARLISLE, PA 17015 by handing to DUSTIN HUNTER 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 6.72 Affidavit .00 Surcharge 10.00 .00 i r1a -7107 34.72 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 10/24/2007 GOLDBECK MCCAFFERTY CKEEVER By: Deputy Sheriff A. D. SHERIFF'S RETURN - NOT FOUND f CASE NO: 2007-06095 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK NA VS HUNTER DUSTIN L R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HUNTER DUSTIN L but was unable to locate Him in his bailiwick. He therefore returns the n?rrrt w TtT 11R/TT T/T T.I , NOT FOUND , as to the within named DEFENDANT HUNTER DUSTIN L 257 ALLEN ROAD CARLISLE, PA 17015 DEFENDANT DOES NOT LIVE AT THIS ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge hib"i'0 7 So answer . 6.00 4.80 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 25.80 GOLDBECK MCCAFFERTY MCKEEVER 10/24/2007 Sworn and Subscribed to before me this day of A. D. GOLDBECK MCCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 VS. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 No. 07-6095 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, David B. Fein, Esq., in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 478 Stonehouse Road, Carlisle, PA, 17015, hereinafter, the "mortgaged premises". 2. Defendant, DUSTIN L. HUNTER, is the mortgagor and real owner of the mortgaged premises. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, David Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant, Dustin L. Hunter, has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant, Dustin L. Hunter, to request his concurrence. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 4. The last known address of Defendant, Dustin L. Hunter, is 257 Allen Road, Carlisle, PA, 17013. 5. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant, Dustin L. Hunter, at his property address, 478 Stonehouse Road, Carlisle, PA, 17015, after numerous attempts. The Defendant, Dustin L. Hunter, moved and left no forwarding address, per Sheriff. Service was also attempted at the Defendant's last known address, 257 Allen Road, Carlisle, PA, 17013, without success. The Defendant, Dustin L. Hunter, moved, per Process Server. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Dustin L. Hunter. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Dustin L. Hunter, by posting the premises and certified and regular mail to the Defendant's last known address. /-. 12? BY: David B. ein, Esq. ProVest, LLC Affidavit of Good Faith Investigation Client provided information: File Number: 57461 FC Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: Dustin L. Hunter Property Address: Street: 478 Stonehouse Road City: Carlisle State: PA Zip 17015 Sldp Results: Last Known Street: 257 Allen Road City: Carlisle Date of Birth: None Found State: PA ProVest File Number: 830163 Dates: As of 2/6/2008 Phone: Zip: 17013 Death Records: As of 2/6/2008, the Social Security Administration has no death record on file for Dustin L. Hunter. Social Security Number Search Completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Dustin L. Hunter as 257 Allen Road, Carlisle, PA 17013. Department of Motor The Pennsylvania Department of Motor Vehicles provided no change for Dustin L. Hunter from Vehicle Records: 257 Allen Road, Carlisle, PA 17013. Public Licenses (Pilot, Search performed provided no information. Real Estate, etc): Voter Registration The County Voters Registration Office has no listing for Dustin L. Hunter. Information: National Postal Has no change for Dustin L. Hunter from 257 Allen Road, Carlisle, PA 17013. Address Search: Comments: 717-243-1146: Called possible neighbor, R.L. Gingrich, answering machine answered, no message left. 717-245-9081: Called possible neighbor, Michael McCullough, there was no answer. 717-245-2913: Called possible relative, B. N. Hunter, left message on answering machine, no response. On 2/6/2008, I, Patti Garrett being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investgation. Affiant am P i Garrett Date: 2/6/2008 Subscribed and pom to before me, Notary is `i U t IMISSI(W I RI S ..?,? ?y 73, ?t?91 Feb. 4. 200$ 5:12PM Cumberland Co. Sheriff LaSalle Bank N.A., as Trustee for MLMI Trust Series 2007-HE 1 VS Dustin L. Hunter No. 074$ P. 2 In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-6095 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Dustin L. Hunter, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sheriffs Sale and Description as NOT FOUND as to the defendant, Dustin L. Hunter. Per the Carlisle Post Office the defendant moved and left no forwarding address. Sterne Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2009 at 1400 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 Dustin L. Hunter located at 478 Stonehouse Road, Carlisle, Cumberland County, Pennsylvania according to law. So Answers: R. Thomas Kline, Sheriff BYJc, Real Estate Sergeant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA AFFIDAVIT OF SERVICE LASALLE BANK N.A DUSTIN L. HUNTER Plaintiff (Petitioner) vs. Defendant (Respondent) CASE and/or DOCKET: 07-6095 //m 1A I, f ??? ? declare that I am a Pennsylvania State Constable and/or Process Server, in and for the County of Berks, that I am not a party to this action, not an employee of a party to this action, or an attorney to the action, and that within the boundaries of the state where service was effected. I was authorized by law to perform the said service. SERVICE UPON: DUSTIN L. HUNTER ADDRESS: 257 ALLEN RD, CARLISLE PA 17013 On: At: Description: Approximate Age Height Weight Race Sex Hair With Documents: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Manner of Service By handing to: ? DEFENDANT(S) PERSONALLY SERVED ? ADULT FAMILY MEMBER WITH WHOM THE SAID DEFENDANT(S) RESIDES. NAME: RELATIONSHIP: ? ADULT IN CHARGE OF DEFENDANTS RESIDENCE. NAME: RELATIONSHIP: ? POSTED PROPERTY ? AGENT OR PERSON IN CHARGE OF PLACE OF BUSINESS. NAME: TITLE: ? MILITARY STATUS: NO / YES BRANCH: COMMENTS: DEFENDANT NO LONGER RESIDES AT THIS ADDRESS, TOBY POSTER PURCHASED THE PROPERTY FROM DEFENDANT'S AUNT OCTOBER 2006. EFEND NT WAS NOT SERVED BECAUSE: MOV UNKNOWN NO ANSWER VACANT OTHER: SERV E WAS ATTEMPTED ON THE FOLLOWING DATES/TIMES: l.) a' ?q c t2 /2.) 3.) S O TO AND SUBSCRIBED EFO ME THIS O' DAY OF )W 2008 NSTA E/PROCESS SERVER NOTARIAL SEAL Public ERIC M. AFFLERBACH, Notary S y 1 ?G Washington Twp., Berks County I Commission Expires November 18, 2009 PROVEST, LLC P.O BOX 118093E MAIN STREET, BAY SHORE NY 11706 631.666.6168 (F) 631 666.6295 GOLDBECK MCCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 VERIFICATION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 07-6095 I, David B. Fein, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. / -- I BY: David B. Fein, Esq. GOLDBECK WCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HEl 14523 SW Millikan Way Suite 200 Beaverton, OR 97005" vs. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 No. 07-6095 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Notice of Sheriff's Sale against Defendant, Dustin L. Hunter, which the Sheriff has been unable to personally serve upon Defendant, Dustin L. Hunter. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Notice of Sheriff's Sale upon Defendant, Dustin L. Hunter, by posting the premises and certified mail and regular mail to the Defendant's last known address. Respectfully submitted, David B. Fein, Esq. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY GOLDBECK McCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 CERTIFICATE OF SERVICE No. 07-6095 David B. Fein, Esq., does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, Dustin L. Hunter, this I Oh day of March 2008, by first class mail, postage prepaid. Z/1? BY: David B. Fein, Esq. IN THE COURT OF COMMON PLEAS Of Cumberland County (`) ?_ r* e? fWY3 ?.r_ rn MAR 14 ZOOS,pi tA LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 ORDER AND NOW, this / P ` day of ~A 2008, upon consideration _ o u Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff pod faith efforts to ascertain the present whereabouts of Defendant, Dustin L. Hunter, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff's Sale upon Defendant, Dustin L. Hunter, by posting a copy of the Notice upon the premises 478 Stonehouse Road, Carlisle, PA, 17015, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 257 Allen Road, Carlisle, PA, 17013, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Dustin L. Hunter, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: 4A Distribution list: ?14ichael T. McKeever, Esquire, Suite 5000 - Philadelphia, PA 19106-1532 J. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Independence Center, 701 Market Street, DUSTIN L. HUNTER, 257 ALLEN ROAD CARLISLE, PA 17013 spy Mai? 07-6095 Uaz Z ' lips, V 1 B?fig ?} U(? xw!u'''?' ,. J?1? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. DUSTIN L. HUNTER Mortgagor(s) and Record Owner(s) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 07-6095 Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. Premises was posted by Slmriffs @ffiee/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, 57461 FC CF: 10/16/2007 SD: 05/07/2008 $149,489.93 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE BY: Michael T. McKeever Attorney for Plaintiff K LL LL U) LL I ? i 97 ?u ,13 r ? O y n ? 330 0 m 4 > Z 000 ?b4?a - o ?'? P 0O O a u' Of r; a. W W a?1tNn o ° g Q a •? (D ? ? m i n E wa-oma- M a n w x ti? o Y N2 r CU Qcr')' o`o COL Q I I I co a) o O a C ? t ?2 ) ? t - o o z a O 0 o v U J < H a a W co J C N Q 8 10 ats W?v ? Q U 0 ?n ai Z) U m E U 2 O X ?0?? LL _ J ° ? W H a v co c Z) W . LO I? W 0 N CO d. m CO m m N 0 0 CL co U) c o zm - In N 2 00 v 0 M Q W zcn c0 Y N c ) LO l U nM Z N mU 02 E 9? ?i Of W -p ?L Q m Q) O ? U Q ?O QL ? QQ N E Z.N.a O C0 > o`_T a 0a U oNQ Md ~ r- jXU-0 Q D- m } ~ 7 0 1) Cn a?a ,, ?JQ U)F- CQ cUa ? ZS `w C x c CL U U w- ¢ } (n 1- X 6 o x d M O (6 F- c Q..n v? Z Q J a ????CI W Z° 7 W c'vym 0 C72 I z° ai Q(n z aS 0 ? ? Q? o Q y °' 000 ca Q S a3 I-`r = Z°° E ?? 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C p J Form 3877 Domestic USPS Firm Mailing Book Name and Address of Sender: Permit Number Sequence Number JOSEPH A GOLDBECK JR 2097A MELLON INDEPENDENCE CE NT 701 MARKET ST STE 5000 As cent - MAC v7.20.7.20.I PHILADELPHIA, PA 19106 ----- -- ------------------ - -------------------------- ----------- Piece ID Article N ---------------------- Delivery Address ----------------------- SS Fee ---------- Postage - -- ------ --- value Sender Charges Addressee Name -- - Type ---------------- ---- ---------- Insur./Register Due Total -------------------------------------- ------------------------------------- 62825FCSE5-6 71114342363000293861 ----- -------------- EVANS, SHALAMAR -- - C 2.65 0.41 5.21 2247 LEAGUE STREET RR 2.15 PHILADELPHIA, PA 19146 62825FCSE5-6.071114342363000293878 EVANS, SHALAMAR C 2.65 0.41 3.91 315 PARK STREET APT 2 RRE 0.85 SYRACUSE, NY 13203 62825FCSE5-6.071114342363000293885 EVANS, SHALAMAR C 2.65 0.41 3.91 ,. 115 Vanderveer Street RRE D.85 Brooklyn, NY 11207 57461FCDH5-7 71114342363000293892 HUNTER, DUSTIN L_ C 2.65 0,41 3.91 257 ALLEN ROAD RRE 0.85 CARLISLE, PA 17013 _-? 56488FCLM5-6 71114342363000293908 MIDDLETON, LOUIS J. C 2.65 0.41 3.91 416 McClellan Street RRE 0.85 Philadelphia, PA 19148 ------------------------------------- Page Totals: 5 ---------- ----------- ----------------------- 18.80 ---------- 2.05 ---------------- -------------------- 20.85 Cumulative Totals: 5 18.80 2.05 20.85 ,NENT,44 ----- ------------------------------- -- --- - SY ------------------------------------------------------ ------ r l USPS CERTIFICATION ? Q`' o 2001 2 Total Number of Pieces Received: o 4 11. Round Stamp: OftFH11Q Signature of Receiving Employee Form 3877 (Facsimile) Date of Manifest: 03/31/2008 Page 1 MAR 14 2008 I LASALLE BANK N.A., AS TRUSTEE FOR MI MI TRUST SERIES 2007-BE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 VS. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 ORDER IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 07-6095 AND NOW, this /8?k day oflbA 008, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Dustin L. Hunter, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff's Sale upon Defendant, Dustin L. Hunter, by posting a copy of the Notice upon the premises 478 Stonehouse Road, Carlisle, PA, 17015, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 257 Allen Road, Carlisle, PA, 17013, and that all further service of legal papers including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Dustin L. Hunter, by sending copies of same to Defendant's last known address by certified and regular mail and by postin the premises. g BY THE COURT: Distribution list: J' Michael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 701 Street, Philadelphia, PA 19106-1532 Market DUSTIN L. HUNTER, 257 ALLEN ROAD CARLISLE PA ••°7..01.3: n `?'gr f??• *nt ,.c, ?.'v'uV 1 iCTY3 i:'" ?+ Gaud yl?.•riti.'':Ly a luck- ?. .r M IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA AFFIDAVIT OF SERVICE LASALLE BANK N.A. Plaintiff (Petitioner) vs. DUSTIN L. HUNTER Defendant (Respondent) CASE and/or DOCKET: 07-6095 I, ?? eresk - declare that I am a Pennsylvania State Constable and/or Process Server, in and for the g le- County of Berks, that I a not a party to this action, not an employee of a party to this action, or an attorney to the action, and that within the boundarie of the state were service was effected. I was authorized by law to perform the said service. SERVICE UPON: DUSTIN L. HUNTER ADDRESS: 478 STONEHOUSE ROAD CARLISLE, PA 17015 On: ! /l I V q At: } 1 4 Description: Approximate Age Height _ Weight ` Race - Sex - Hair - With Documents: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Manner of Service By handing to: ? DEFENDANT(S) PERSONALLY SERVED ? ADULT FAMILY MEMBER WITH WHOM THE SAID DEFENDANT(S) RESIDE. ? NAME: RELATIONSHIP: ? ADULT IN CHARGE OF DEFENDANTS RESIDENCE. ? NAME: RELATIONSHIP: X POSTED PROPERTY ? AGENT OR PERSON IN CHARGE OF PLACE OF BUSINESS. ? NAME: _ TITLE: ? MILITARY STATUS: NO / YES BRANCH: COMMENTS: DEFENDANT WAS NOT SERVED BECAUSE: MOVED UNKNOWN NO ANSWER VACANT OTHER: SERVICE WAS ATTEMPTED ON THE FOLLOWING DATES/TIMES: 1.) 2.) -3.) SWORN TO AND SUBSCIBED BEFORE ME THIS 2 DAY OF Y 2008 NOTARY COMMONWEALIH OF PENNSYLVANIA NOTARIAL SEAL ERIC M. AFFLERBACH, Notary Public Washington 7wp., Barks County _MX t ommi_ scion Expires No"ember 16, 2009 CONSTA E/P O ESS SERVER 5 _ 461 FC PROVEST, LLC P.O BOX 1180,93 EAST MAIN STREET, BAY SHORE, NY 11706 631.666.6168 631.666.6295 (F) GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. DUSTIN L. HUNTER Mortgagor(s) and Record Owner(s) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6095 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE 1, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 478 Stonehouse Road Carlisle, PA 17015 1.Name and address of Owner(s) or Reputed Owner(s): DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CHASE BANK USA 3700 WISEMAN BLVD SAN ANTONIO, TX 78251 MID ATLANTIC COOP 230 LINCOLN WAY E DBA AERO ENERGY NEW OXFORD, PA 17350 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. VIRGINIA R. ADAMS 917 West Luther Street Carlisle, PA 17013 LES ADAMS DB/A BUDGET EXCAVATING AND CONTRACTING 23 Frey Lane Galeton, PA 16922 TENANTS/OCCUPANTS 478 Stonehouse Road Carlisle, PA 17015 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 9, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff i - ? • ? ?:, ? --, ?, - i ""? --, i ? r7i ?.ri ?i:? A?, L4? f, .J i?iN! --fir . • :?.r ?1 -r ?? w COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which MLMI TRUST SERIES 2007-HEI TR is the grantee the same having been sold to said grantee on the 7TH day of MAY A.D., 2008, under and by virtue of a writ Execution issued on the 28TH day of NOV, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 6095, at the suit of MLMI TRUST SERIES 2007-HE I TR against DUSTIN L HUNTER is duly recorded as Instrument Number 200820636. IN TESTIMONY WHEREOF, I have he eunto set my hand and al of said office this day of A.D. of Deeds RaoorMof Ms" Cumo"nd County, Cark* PA My Carrnia w F.xp m tMw Fins Monday of Jan. 2010 'LaSalle Bank N.A., as Trustee for MLMI In the Court of Common Pleas of Trust Series 2007-HE1 Cumberland County, Pennsylvania VS Writ No. 2007-6095 Civil Term Dustin L. Hunter R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Dustin L. Hunter, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sheriffs Sale and Description as NOT FOUND as to the defendant, Dustin L. Hunter. Per the Carlisle Post Office the defendant moved and left no forwarding address. Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 1400 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 Dustin L. Hunter located at 478 Stonehouse Road, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on May 7, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck, on behalf of LaSalle Bank, N.A., as Trustee for MLMI Trust Series 2007-HEL It being the highest bid and best price received for the same, LaSalle Bank N.A., as Trustee for MLMI Trust Series 2007-HE I, of 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $929.53. Sheriff s Costs: Docketing $30.00 Poundage 17.83 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 15.36 Levy 15.00 Surcharge 20.00 Post Pone Sale 20.00 Law Journal 355.00 Patriot News 285.17 Share of Bills 16.17 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 929.53 0j/`' q Y' Ck? d l05W So Answers: R. Thomas Kline. heriff 1 1 (, v lil,? L,w BY' Real Estate Se#geant Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HEl 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. DUSTIN L. HUNTER (Mortgagor(s) and Record Owner(s)) 478 Stonehouse Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 07-6095 AFFIDAVIT PURSUANT TO RULE 3129 LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE 1, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 478 Stonehouse Road Carlisle, PA 17015 I.Name and address of Owner(s) or Reputed Owner(s): DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 478 Stonehouse Road Carlisle, PA 17015 VIRGINIA R. ADAMS 917 West Luther Street Carlisle, PA 17013 LES ADAMS D/B/A BUDGET EXCAVATING AND CONTRACTING 23 Frey Lane Galeton, PA 16922 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 27, 2007 II?, 40B: BECK cCAFFERTY & McKEEVER 1 h A. Goldbeck, Jr., Esq. eph Attorney for Plaintiff 07-6095 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE1 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. DUSTIN L. HUNTER Mortgagor(s) and Record Owner(s) 478 Stonehouse Road Carlisle, PA 17015 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6095 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HUNTER, DUSTIN L. DUSTIN L. HUNTER 478 Stonehouse Road Carlisle, PA 17015 Your house at 478 Stonehouse Road, Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $149,489.93 obtained by LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HE 1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 and 07-6095 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6095 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_o_v for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-776-0100 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 57461FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. The land referred to in this Commitment is described as follows: ALL that certain tract of land situated in the Township of Dickinson, county of Cumberland and State of Pennsylvania, more fully described as follows, to wit: BEGINNING at a point in the Mount Rock Road leading from Walnut Bottom Road to the Ritner Highway at corner of lands now or formerly of Alice M. Moore known as the Stone House lot; thence by the Stone House lot South 70 degrees West 150 feet; thence by land now or formerly of J. Earl Weibley and wife, North 17 degrees 13 minutes West 110 feet; thence by the same North 70 degrees East 150 feet to the center of Mount Rock Road; thence by the center of said road south 17 degrees 13 minutes East 110 feet to the place of BEGINNING. MUNICIPALITY: TOWNSHIP OF DICKINSON PROPERTY ADDRESS: 478 STONEHOUSE ROAD, CARLISLE, PA 17015 TAX PARCEL #: 08-10-0626-015 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6095 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK N.A., as Trustee for MLMI TRUST SERIES 2007-HE1, Plaintiff (s) From DUSTIN L. HUNTER (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 $149,489.93 L.L.$ 0.50 Interest from 11/28/07 to Date of Sale at 8.5000% Atty's Comm % Atty Paid $179.52 Plaintiff Paid Date: 11/28/07 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs dt? ?. Prothogotary By: V i Deputy Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone : 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale #77 On November 30, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA Known and numbered as 478 Stonehouse Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 30, 2007 By: c Real Estallrgeant 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 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. Lis ane Coyne, E ' or SWORN TO AND SUBSCRIBED before me this day of Februar, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 RX" IWAT19 GMA 00. 77 Writ No. 2007-6095 Civil LaSalle Bank N.A., as Trustee for MLMI Trust Series 2007-HEl vs. Dustin L. Hunter Atty.: Joseph Goldbeck DESCRIPTION The land referred to in this Com- mitment is described as follows: ALL that certain tract of land situ- ated in the Township of Dickinson, county of Cumberland and State of Pennsylvania, more fully described as follows, to wit: BEGINNING at a point in the Mount Rock Road leading from Walnut Bottom Road to the Ritner Highway at comer of lands now or formerly of Alice M. Moore known as the Stone House lot; thence by the Stone House lot South 70 degrees West 150 feet; thence by land now or formerly of J. Earl Weibley and wife, North 17 degrees 13 minutes West 110 feet; thence by the same North 70 degrees East 150 feet to the center of Mount Rock Road; thence by the center of said road south 17 degrees 13 minutes East 110 feet to the place of BEGINNING. MUNICIPALITY: TOWNSHIP OF DICKINSON. PROPERTY ADDRESS: 478 STONEHOUSE ROAD, CARLISLE, PA 17015. TAX PARCEL #: 08-10-0626- 015. 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 ZhePahiot 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 Sworn to a sytascribed before rne? ?s of February, 2008 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kianer, Notary Public City Of He urg. Dauphin County My ConrrticW.,, "a Aires Nov. 26, 2011 Memtrer, Pennsylvania Association of Notaries REAL ESTATE SALE NO. 77 Writ No. 2007-6095 Civil Term LaSalle Bank N.A., as Trustee for MLMI Trust Series 2007-HEl VS Dustin L. Hunter Attorney Joseph Goldbeck DESCRIPTION The land referred to in this Commitment is described as follows: ALL that certain tract of land situated in the Township of Dickinson, county of Cumberland and State of Pennsylvania, more fully described as follows, to wit: BEGINNING at a point in the Mount Rock Road leading from Walnut Bottom Road to the Rimer Highway at comer of lands now or formerly of Alice M. Moore known as the Stone House lot; thence by the Stone House lot South 70 degrees West 150 feet; thence by land now or formerly of J. Earl Weibley and wife, North 17 degrees 13 minutes West 110 feet; thence by the same North 70 degrees East 150 feet to the center of Mount Rock Road; thence by the enter of said road south 17 degrees 13 minutes Fast 110 feet to. the place of BEGINNING. MUNICIPALITY: TOWNSHIP OF ! -`?KINSON PROPERTY ADDRESS: 478 STONEHOUSE ROAD, CARLISLE, PA 17015 TAX PARCEL #: 08-10-0626-015 Assignment of Bid NO. 07-6095 -HUNTER 478 Stonehouse Road Carlisle, PA 17015 I, Michael T. McKeever, Esquire, as attorney for the successful bidder, hereby assign my bid at the Sheriff Sale dated May 07, 2008 to: LASALLE BANK N.A., AS TRUSTEE FOR MLMI TRUST SERIES 2007-HEl 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 GOLDBECK MCCAFFERTY & MCKEEVER Date: May 9, 2008 MICHAEL T. MCKEEVER