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HomeMy WebLinkAbout07-6653GOLDBECK 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 DOMINIC J. OLIVERI vs. Plaintiff Mortgagor SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor and Real Owner 235 Bobcat Road Carlisle, PA 17013 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 61 - (o(A&3 OFIVIL ACTION: MORTGAGE FORECLOSURE 0, 1 v; (Tenn I NOTICE 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 attomey 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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 LISTED, 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. 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 INFORMATION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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: 717-243- 9400 or. 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 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 homeretention(a),Poldbecklaw.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 57746FC. 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI, 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632. 2. The names and addresses of the Defendants are DOMINIC J. OLIVERI, 235 Bobcat Road, Carlisle, PA 17015, who is the mortgagor, and SONYA H. OLIVERI a/k/a SONYA OLIVERI, 235 Bobcat Road, Carlisle, PA 17015, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On January 26, 2004 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1854, Page 2943. The mortgage has been assigned to: WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 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 04, 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 ....................................................................................$83,077.76 Interest from 05/04/2007 through 10/12/2007 at 11.8400% .....................$4,364.28 Per Diem interest rate at $26.94 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,153.89 Late Charges from 06/04/2007 to 10/12/2007 .............................................$214.10 Monthly late charge amount at $42.82 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $190.12 $92,710.03 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 Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have 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 Defendants 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 Defendants 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 Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $92,710.03, together with interest at the rate of $26.94, 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: Y: JOSEPH A. GbLDBECK, JR., TTORNEY FOR PLAINTIFF VERIFICATION I, M.1&LY MK"F- , 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: QU 2 R ?7 1ILVA M. KELLY MK;, llosl? 235 Bobcat Road Carlisle, PA 17013 - DOMINIC J. OLIVERI and SONYA H. OLIVERI aWa SONYA OLIVERI Ex. hibitA 10/10/2007 20:31 TEL 7175997794 J CONRAD 10037 1.AWYl,1tS TMz Jg6URAMX GORPORATMN NABONAL IIICADQUA=W - Sid' MOND+ VUUM,UA CCU No. 651 All that Wtgin tract of laud wilt 20 WVWVCMM boon erected situate is L*m prm>tford Towohip, Cu d Comfy, peangdvmi i, botmded and dom0ed as EONowa. Bojinnia at a sp W in the =W of Tom Road MI at the comer of property of John IL Mope K thmm lW& me latter, lTm& 7 deems 26 Mid Weer 27190 fag 0 au km pm; *me aim& the name progeny of MOM D. Lea M, Jr.. North 73 dWM 29 mm+lea West 544.57 feet to an icon pbg 6=0 aloag property of EdW D. Dentin, Noah 9 des W 30 mioules Bast 573 abet to a stake; these a km do r,, No* 14 de?reea 38 mbodw 17 ra W 1310 tact to a stela,; tbeoce aloes pmpaty aecoods East 327.21 f* to a stale theuco 9M slo ft the same. Saudi 7 degrees 26 minatet East 1,039.16 Seel to a epNm in the cerder of the afomsaid red: tbenca akwS dta h OW, Saudi 19 degrees 45 mhoifts West 30 feet w a RXIM, the place of begieng. Bt f 854PG2917 E.xhifiit (B FWME LOANS P.O. Banc 9048 Temecula, CA 92589-9048 Send Payments To PO BOX 660694 Dallas, TX 75266-0694 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 Illlllllhlllll1 2204582270 Sonya Olived 735 BOBCAT RD CARLISLE, PA 17015-9539 070808-BLQPAt PRESORT First-Class Mail U.S. Postage and Fees Paid WSO ®CIyulwi 1r HOME LOAM P.O. Box 660694 Dallas, 7X 75266-0694 Sonya Olived 235 BOBCAT RD CARLISLE, PA 17015-9539 Seri! Payments to. PO Box 660694 Dalas, 7X 75266-0694 August 6, 2007 Account No.: 62898426 Property Address: 235 Bobcat Road Carlisle, PA 17013 Current Service: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortaaae on your home Is In default and the lender Intends to foreclose Spectiic Information about the nature of the default is provided In the attached paces. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see If HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you most with the Counselina Agency. The rmmes, addresses and phone numbers of Consumer Credit Counselirw Aaencies serving your Countv are listed at 1-800-342-2397. (Persons with Imnalred hearing can call 1-717-780-180) . - This Notice contains important legal information. H 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 And a lawyer. LA NOTIFICAci6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VMENDO EN SU CASA. SI NO COMPRENDE EL CONTEN11DO DE ESTA NOTIFICACION OBTENGA LIMA TRADUca6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGN3LE PARA UN PRr:STAM0 POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMN2 SU HIPOTECA. HOMEOWNER'S NAME(S): Sonya ONveri PROPERTY ADDRESS: 235 Bobcat Road Carlisle. PA 17013 LOAN ACCT. NO.: 62898426 ORIGINAL LENDER: CURRENT LENDERISERVICER: Countrywide Home Loans Servicina LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Please were your accourr number on all checks and correspombnoe. We may charge you a tee br arry payment rdumed or mieded by your hnencal uettdbn, subject to appicaUe W. Account Number. $2008128.2 • Make your check payable to Sonya Oliver] Balance Due for charges listed above: $2,493.50 as of 0810612007. Countrywide Home Loans • Write your account number on 235 Bobcat Road your check or money order Please u pdolee-mil nbraMm m to evarse sided M's mupm • Write in cry additional amoums i d d Add =1 you era n u ng (a total is more than $5000, please send Pmdpal cerfflW ctladk) BLCPAt • Dont arch your check to the l Adda payment coupon ae E • Dontindudecorrespondenoe e Dont send cash Countrywide .. PO BOX 660694 aher Dallas, TX 75266-0694 Check Trial 062898426200000249350000249350 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT" % YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face4o-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseang agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face4o-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 it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be noted 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.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 235 Bobcat Road Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 06104/2007 $3,139.38 Late Charges: 06/042007 $85.64 Other Late Charges Total Late Charges: $42.82 Uncollected Costs: ($774.34) Partial Payment Balance: ($0.00) TOTAL DUE: $2,493.50 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,493.50, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashiers check. certified check or money order made payable and sent to: E-mail use: Providing your e-mail address below will allow us to send you irtorrnabon on your eocourt Account Number. C1111111111141111 Sonya Ollved E-mail address How w pad pw M soooW pgarr . of pkropM acid if" ed be appal b tlw bnrat on I kriirrolt dw, a" 0lna L aapaa* PNNNW a Mod b kw. r ya ainI M ample! IN sddlw to ym adudl" waft aeotet, we WE ** ym paIraaAa • MW (116 wAftft =ft paynwrAa of pabo1 ed kinK as .rice datlolatolaa aq ble d mgaa and *aa aeaarb ya orra Ia Open,, w? yar I= and iM b N*m the oabt oft palloI I bolas of yoar I=. Raaaa apaoid r yea wed ar adoMad amowl liffm b M" 10 nwrlb, rahar In PlYlopalnduofon. Pbdddad o* I' I COUi""Is P" Y b not now pnibm cilleft 0111M waft* apwad blrya baameadw0rbdaddae. Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by takina the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not armlicabie) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY 1301 DAYS of the date of this Notice, the lender Intends to exercise Its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any adomey'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 (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (301 DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default In the manner set forth In this notice will restore your mortgage to the same position as N you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - it is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Nome Loans Servicing LP Address: P. O: Box 660694 Dallas, TX 75266--0694 Phone Number: 1800-669-0102 Fax Number: 1-805.577-3432 Contact Person: MS PTX-36 Attention: Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property alter the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your 2204562270 property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied andfor (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security Instrument. If you are unable to cure the default on or before September 5, 2007, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 1A of the amount necessary to bring the account current, and that the balance of the overdue mount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless d agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by September 5, 2007 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Acorn Housing Adams County interfaith CCCS of Western PA 14 S. 13th Street Housing Authodty 20DO Lingleslown Road Harrisburg, PA 17104 40 E High Street Harrisburg, PA 17102 717.213.0150 Gettysburg, PA 17325 888.511.2227 717.334.1518 Community Action Commissior Loveship, Inc. Maranalhe of Captial Region 2320 North 51h Street 43 Philadelphia Avenue 1514 Derry Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17104 717.232.2207 717.762.3285 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 HI ME LOANS P.O. Boot 9048 Temecula, CA 92589-9048 Send Payments To: PO Box 660694 Dallas, TX 752664M Send Correspondence to. PO Box 5170, MS SV314B Simi Valley, CA 93065 MISS in 'in 2204582268 Dominic J Oliveri 235 BOBCAT RD CARLISLE, PA 17015-9539 070806-BLQPAl PRESORT First-Class Mall U.S. Postage and Fees Pald WSO k ON NC HONE LOANS P.O. Box 660694 Dallas, TX 75266-0694 Dominic J ONved 235 BOBCAT RD CARLISLE, PA 17015-9539 Send Payments to., PO BOX 660694 Dallas, TX 75266-0694 August 6, 2007 Account No.: 62898426 Property Address: 235 Bobcat Road Carlisle, PA 17013 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortgage on your home Is In default and the lender Intends to foreclose Specific Information about the nature of the default Is provided in the attached panes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how the proaram works. To see H HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY VATFNN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with v when you meet with the ounselina Agency. This Notice contains important legal information. H 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 NOTIFICACIbN EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGOLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): DomlydGJ Ollved PROPERTY ADDRESS: 235 Bobcat Road Carlisle. PA 17013 LOAN ACCT. NO.: 62898426 ORIGINAL LENDER: CURRENT LENDERISERVICER: Countrywide Home Loans Servicing LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Pilaw wile your account nunber on all checks and ocnespondenoa We may cNiW you a be br any part retuned or rejected by youranancial insttlllDn, subject to applicable law. Account Number. 628084M • Make your &mck payable to Dominic J Oliveri Balance Due for charges listed above: $2,493.50 as of 0810612007. Count"cle Home Loans • Write you account number on 235 Bobcat Road your chedl or money order Please updaleeinai kdormaew on the revere side d the coupon. • Write in any additional amounts i d di r Addti l you pre n u ng ( total Is more than 55000, please send ona priuipel ca ied check) BLOPAI • Dont attach your chark to the Addti l payment coupon rna E • Dort indude correspandenoe • Dont send cash Countrywide w. PO BOX 660694 ache Dallas, TX 75266-0694 II???1,I?I???I?I?II,r?ll??ll????ll„Irlrrrlrrllrlrrrlrrlr,l,lll???l Check Tdel 062896426200000249350000249350 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT" % YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a 'ace-to face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of desianated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for spec information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies fisted at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision alter it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (if you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 235 Bobcat Road Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charaes: 06/04/2007 Late Charaes: 0610412007 Other Late Charaes Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) $3,139.38 $85.64 $42.82 ($774.34) ($0.00) $2,493.50 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (301 DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,493.50, PLUS 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: E-mail use: PrwldIng your e-mail address below will allow us to send you information on your account Ac court Number. (> DominicJ Olltied E-mall address How w pod ym 1 M novW pgnwrb of Plrr" WA Wnd wl be aPIMd b tip bred adoM ft Babb" dw. w" alrawia a F=* PdMd ar wbil by bar. gym ar" Mi .Road Y adMar by= adradiad raft L, " we we ** yar prUwMlb as bbwx to b addadb>0 -F" plganai of prbro5al and bi=K A .maw dMdalaba, A bib dwilp Mill dw mm* ya an In canaolw aitr ym km Mid fl) b adlwa tie aaMrbYO prboTld babrw of pr bm. Plows ape* r you wart Mi oim d .pall appbd b Idea pgarRa- raflar Ian yr. j 111dadoe. Pm -- - du'I ' parrbyrtdas poloy b b Rd awrpt parfdaMd dla I" oil- RNC&* apwad b by a bm ooaraalr a bdeidar. Countrywide at P.O. Box 660694, Dallas, TX 75266-0694 You can cure any other default by takina the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (301 DAYS of the date of this Notice, the lender intends to exercise Its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default In the manner set forth In this notice will restore your mortgage to the same position as If you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - it is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans Servicing LP Address: P. O. Box 660694 Dallas, TX 75266.0694 Phone Number: 14800-669-0102 Fax Number: 1-805-577,3432 Contact Person: AfS PTX-36 Attention. Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that 211 the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your 2204582268 r property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security Instrument. If you are unable to cure the default on or before September 5, 2007, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least'/ of the amount necessary to bring the acoount current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, untess it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by September 5, 2007 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Acorn Housing Adams County Interfaith CCCS of Western PA 14 S. 13th Street Housing Authority 2000 tinglestown Road Harrisburg, PA 17104 40 E High Street Harrisburg, PA 17102 717.213.0150 Gettysburg, PA 17325 888.511.2227 717.334.1518 CommunityActon Commissiar Loveship, Inc. Maranathe of Capital Region 2320 North 51h Street 43 Philadelphia Avenue 1514 Derry Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17104 717.232.2207 717.762.3285 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 - O -4 ; -n 00 Tl ?w r ?- e(VI 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 07-6653 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. 4301a1 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 235 Bobcat Road, Carlisle, PA, 17013, hereinafter, the "mortgaged premises". 2. Defendants, DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI, are the mortgagors and real owners of the mortgaged premises. 3. 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, Dominic J. Oliveri, has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant, Dominic J. Oliveri, to request his concurrence. 4. The last known address of Defendant, Dominic J. Oliveri, is 906 Indian Mound Road, Indian Mound, TN 37079. 5. The Sheriff has been unable to effect service of the Complaint upon Defendant, Dominic J. Oliveri, at the property, 235 Bobcat Road, Carlisle, PA, 17013. Per Sheriff, Co-Defendant, Sonya H. Oliveri a/k/a Sonya Oliveri, has not seen Defendant, Dominic J. Oliveri in 2 years and his whereabouts is unknown. Service was also attempted, without success, at the last known address, 906 Indian Mound Road, Indian Mound, TN 37079. Per Process Server, said premises does not exist according to the Montgomery County Fire Service. Per Postmaster, 906 Indian Mound Road, Indian Mound, TN 37079 is the last known address. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Dominic J. Oliveri. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant, Dominic J. Oliveri, by posting the premises and certified and regular mail to the Defendant's last known address. BY: Dave . Fein, Esq. Affidavit of Good Faith Investigation Client provided information: File Number: 57746FC Attorney Firm: Goldbeck, McCafferty & McKeever File Name: Oliveri Subject Name: Dominic J. Oliveri a/k/a Dominic James Oliveri a/k/a Doninic J. Oliveri a/k/a Dominic J. Lived Property Address: Street: 235 Bobcat Road City: Carlisle State: PA Zip: 17013 Skip Results: Date of Birth: 03/12/1944 ProVest File Number: 213165 Lost Known Dates: As of 10/19/2007 Street: 235 Bobcat Road T-451 Phone: City: Carlisle State: PA Zip: 17015 Death Records: As of 10/19/2007, the Social Security Administration has no death record on file for Dominic J. Oliveri a/k/a Dominic James Oliveri a/k/a Doninic J. Oliveri a/k/a Dominic J. Lived. Social Security Number search completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Dominic J. Oliveri a/k/a Dominic James Oliveri a/k/a Doninic J. Oliveri a/k/a Dominic J. Lived as 235 Bobcat Road T-451, Carlisle, PA 17015 Department of Motor Vehicle Records: The Pennsylvania Department of Motor Vehicles provided no change for Dominic J. Oliveri a/k/a Dominic James Olived a/k/a Doninic J. Oliveri a/k/a Dominic J. Lived from 235 Bobcat Road T-451, Carlisle, PA 17015 Public Licenses (Pilot, Real Estate, etc): Search performed provided no information. Voter Registration Information: The County Voters Registration Office has no listing for Dominic J. Oliveri a/k/a Dominic James Oliveri a/k/a Doninic J. Oliveri a/k/a Dominic J. Lived. National Postal Address Search: Has no change for Dominic J. Oliveri a/k/a Dominic James Oliveri a/k/a Doninic J. Oliveri a/k/a Dominic J. Lived from 235 Bobcat Road T-451, Carlisle, PA 17015 Comments: 717-243-1220: Called possible neighbor, William and Vicki Manning, answering machine answered, no message left. 717-243-7735: Called possible neighbor, Ryan Keesman, answering machine answered, no message left. 717-243-7735: Called possible neighbor, Jerome Townsend, there was no answer. On 10/19/2007, I, Tonya Hardin 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 investigation. Affi,nt N,' . Tony, tl,fdin Subscribed and sworn to before me 5 Notary Public 3ABr7fftllliBw M%L pE opm J??l,R1S Date: 10/19/2007 SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06653 P CQMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NA Vs OLIVERI DOMINIC J ET AL 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 OLIVERI DOMINIC J but was unable to locate Him in his bailiwick. He therefore returns the t1n?,,TnT T TTTT _ "nom vnvv NOT FOUND , as to the within named DEFENDANT OLIVERI DOMINIC J 235 BOBCAT ROAD CARLISLE, PA 17015 SONYA HAS NOT SEEN OR HEARD OF DEFENDANT IN 2 YEARS. WHEREABOUTS UNKNOWN. Sheriff's Costs: So answers: Docketing 18.00 2? f Service 8.64 Not Found 5.00 R. Thomas I(-1-ine Surcharge 10.00 Sheriff of Cumberland County .00 41.64 GOLDBECK MCCAFFERTY MCKEEVER 11/07/2007 Sworn and Subscribed to before me this day of A.D. PROVEST, LLC P.Q. Box 1180 Bay Shore, New York 11706 (631) 666-6168 GOLDBECK, MCCAFFERTY & MCKEEVER MELLON INDEPENDENCE CENTER 701 MARKET STREET, SUITE 5000 PHILADELPHIA, PA 19106 IN THE COURT OF COMMON PLEAS OF CUMBERLAND CIVIL ACTION- LAW WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01, Plaintiff, Against DOMINIC J. OLIVERI, SONYA H. OLIVERI AIK/A SONYA OLIVERI, ET AL Defendants STATE O TENNESSEE COUNTY OF STEWART . , ?. tieing duly sworn, deposes and says that deponent is not a party to this action, is over 18 years of age and resides in the State of TN. That on / 2 ` 1-6%t ?;64014611 went to the address at 906 INDIAN MOUND ROAD, INDIAN MOUND, TN 37079. The defendant, DOMINIC J. OLIVERI does not reside at this address as per jQkr M0f0-g00A'& kf e-e0n11,( C we S.r?i,c?c Qo4 nd?fln Mso?tid Ka 'ba'ts t".,)+ 406+ SWORN TO BEFORE ME ON e4 PLY NOTARY PUBLIC AT ` L it COURT CASE NO.: 07-6653 AFFIDAVIT OF NON-SERVICE LICENn57746FCC FIL CASE 37877 GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 (215) 627-1322 FAX (215) 627-7734 www_R0Idheckl2w.c0m November 19, 2007 PLEASE REPLY ASAP THANKS( To: POSTMASTER CARLISLE, PA 17013 Request for Change of Address or Boxholder Information needed for Service of Legal Processor. Please furnish the new address of the name and street address (if a boxholder) for the following; ! The name and last known address are required for change of address information, The name, if known. and post office box address are required for box holder information. The following information is provided in accordance with 39 CFR 256.6 (d) (6) (ii). There is no fee for providing the boxholder information. The fee for proving change of address information is waived in accordance with 39 CFR 256.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requestor (e.g) process server, attorney, party representing himse ft Attemev forT Plaint' 2. Statute or regulation that empowers me to serve process (not required when requestor is an attorney or party acting pro se - except a corporation acting pro se must cite statute): PA Rule civil Pro .ed ure Number 440 3. The names of all known parties to the litigation: WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01 4. The court in which the case has been or will be heard: Superior Court for Cumberland County 5. The docket or other identifying number if one has been issued: TERM 07.6653 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant, DOMINIC J. OLIVERI LAST KNOWN ADDRESS: 235 Bobcat Road, Carlisle, PA 17013 The submission of false info 3a on to obtaifl other than the service of legal ?, ;` _ 'a including a fine up to $1 or impris than 5 years, or both (Ti(i 8 U.S.C. Sectio >r 1. NEW ADDRESS OR BOXHOL614610i' -Mail is delivered to the address given. _No change of address order on file. -Not known at address given. -No such address. -Moved, left no forwarding address. Our file #: 57746FC WARNING use change of address information or boxhold information for any purpose nection with actual or prospective litigation Id result ' criminal penalties 2) to avoid payment of the fee for than a dress ' rmation of not re MI AEL T. Mc VER, ESQUIRE POST OFFICE USE POSTMARK ADDRESS 9?? rs?/ 1'Y1 VTR,' ??L? 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 VERIFICATION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 07-6653 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. BY: David 9. Fein, Esq. 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632" VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 07-6653 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant, Dominic J. Oliveri, which the Sheriff has been unable to personally serve upon Defendant, Dominic J. Oliveri. 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). For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, Dominic J. Oliveri, by posting the premises and certified mail and regular mail to the Defendant's last known address. Res ly submitte , B. Fein, Esq. 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS Of Cumberland County No. 07-6653 CERTIFICATE OF SERVICE 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, Dominic J. Oliveri, this 11th day of December, 2007, by first class mail, postage prepaid. BY: r PwAd B. em, Esq ._ a . ? t"7 ? .? --?. ?? ? ? ? ?? ?..u.) ?„?, ? . .. ?"'?' ?,• ? - r- WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURI TIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 07-6653 ORDER AND NOW, this r day of 2007, upon consideration of 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, Dominic J. Oliveri, have been unsuccessful, it is hereby ORDERED and DECREED that Plaintiffs Motion is Granted, and the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon defendant, Dominic J. Oliveri, by (i) posting a copy of the Complaint upon the mortgaged premises, 235 Bobcat Road, Carlisle, PA, 17013, and (ii) publication in Cumberland County, Pennsylvania pursuant to Pa. R.C.P. No. 430(b)(1); and, it is further ORDERED and DECREED that all future documents normally required to be personal served upon defendant, Dominic J. Oliveri, shall instead be served in the manner listed above. B WCOU T he Honorable Edward E. Guido Distribution list: David Fein, Esquire?e 5000, 701 Market Street, Philadelphia,. PA 19106-1532 Dominic J. Oliveri, 35 Bobcat Road Carlisle, PA 17015 Sonya H. Oliveri a/k/a Sonya Oliveri, 235 Bobcat Road Carlisle, PA 17015 L .fit f 3l ? p Lt aZ GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER 4?7 W( By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Tl Q '-V t7l i1.{ N Zyg D CO "? SHERIFF'S RETURN - REGULAR CASME NO: 2007-06653 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS OLIVERI DOMINIC J ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon OTJIMPT RnNVA H AKA SONYA OLIVERI the DEFENDANT , at 1925:00 HOURS, on the 6th day of November-, 2007 at 235 BOBCAT ROAD CARLISLE, PA 17015 SONYA OLIVERI by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharges ? j jyl - 1?1 .? Sworn and Subscibed to before me this of 6.00 .00 .00 10.00 day So Answers: ? =a R. Thomas Kline 11/07/2007 GOLDBECK MCCAFFERTY MCKEE:7 By: .I A, A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06653 P COMMONTWEALTH OF PENNSYLVANIA 'COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS OLIVERI DOMINIC J ET AL 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 OLIVERI DOMINIC J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT OLIVERI DOMINIC J 235 BOBCAT ROAD CARLISLE, PA 17015 SONYA HAS NOT SEEN OR HEARD OF DEFENDANT IN 2 YEARS. WHEREABOUTS UNKNOWN. Sheriff's Costs: So answers: Docketing 18.00 - " Service 8.64 Not Found 5.00 R. Thomas ine Surcharge 10.00 Sheriff of Cumberland County 00 ? 41.6 4 ;?o Sworn and Subscribed to before me this day of A. D. GOLDBECK MCCAFFERTY MCKEEVER 11/07/2007 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06653 P 'COMM?vNWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS OLIVERI DOMINIC J ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon OLIVERI DOMINIC J the DEFENDANT , at 1234:00 HOURS, on the 28th day of December-, 2007 at 235 BOBCAT ROAD CARLISLE, PA 17015 by handing to POSTED PROPERTY AT 235 BOBCAT ROAD CARLISLE 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 Service Posting Surcharge Y6,510 r q, So Answers: 18.00 7.68 6.00 '''? ? Er 10.00 R. Thomas Kline 00 41.68 12/28/2007 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to before me this By: day Deputy Sheriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-06653 P `COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS OLIVERI DOMINIC J ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon OLIVERI SONYA H AKA SONYA OLIVERI the DEFENDANT , at 1234:00 HOURS, on the 28th day of December-, 2007 at 235 BOBCAT ROAD CARLISLE, PA 17015 by handing to POSTED PROPERTY AT 235 BOBCAT ROAD CARLISLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service Posting 6.00 .00 6.00 Surcharge 10.00 R. Thomas Kline 00 22.00 12/28/2007 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: ?_` v"? before me this day Deputy Sheriff of A.D. ie . PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) December 24, 2007 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this 27th. day of December, 2007. Notary Pub My commission expires: 016 6 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Christina L. Wolfe, Notary Pubic Carlisle Bono, Cumberland County My Commission Expires SepL 1, 2008 Member, Pennsylvania Association Of Notaries COPY OF NOTICE OF PUBLICATION PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz December 28, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 7?`? LL# Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 28 day of December, 2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas Cumberland County Civil Action-Law secured on your property located, 235 Bobcat Road, Carlisle, PA 17013, whereupon your property will be sold by the Sheriff of Cumberland. NOTICE No. 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301, Plaintiff VS. DOMINIC J. OLIVERI & SONYA H. OLIVERI a/k/a SONYA OLIVERI, Mortgagors and Real Owners, Defendants TO: DOMINIC J. OLIVERI, MORT- GAGOR AND REAL OWNER, Defendants, whose last known address is 235 Bobcat Road, Car- lisle, PA 17013. THIS FIRM IS A DEBT COLLEC- TOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OB- TAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECT- ING THE DEBT. You are hereby notified that Plaintiff, WELLS FARGO BANK, NA- TIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFI- CATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1, has filed a Mortgage Fore- closure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cumber- land County, Pennsylvania, docketed to No. 07-6653, wherein Plaintiff seeks to foreclose on the mortgage 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 ap- pearance 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 PA- PER 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 RE- DUCED FEE OR NO FEE. LEGAL SERVICES INC. 401 E. Louther St. Ste. 103 Carlisle, PA 17013 (717) 243-9400 or CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 CUMBERLAND LAW JOURNAL JOSEPH A. GOLDBECK, JR. GOLDBECK McCAFFERTY & McKEEVER, P.C. Attorneys for Plaintff Suite 5000 Mellon Independence Center 701 Market St. Philadelphia, PA 19106-1532 (215) 825-6411 Dec. 28 10 . Y.a -77 ..?.,-{ r S In the Court of Common Pleas of Cumberland County WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVER] a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT No. 07-6653 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 DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI by default for want of an Answer. Assess damages as follows: $96,345.31 Debt \ Interest from 01/30/2008 to Date of Sale Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIF D A UNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN F COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered t t e p against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at leas t da s prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKee er Attorney for Plain ff I.D. #56129 AND NOW _ Jappa zo 0200$ , 9dgment is entered in favor of WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 and against DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI by default for want of an Answer and damages assessed in the sum of $96,345.31,ta per the above 901ification. Prothonotary ?' ` WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF- COMMON PLEAS OF CUMBERLAND COUNTY 07-6653 ORDER AND NOW, this / O -z'506 day of 2007, upon consideration of Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a), and it appearing to the Court that Plaintiff s good faith efforts to ascertain the present whereabouts of defendant, Dominic'J. Oliveri, have been unsuccessful, `it is hereby ORDERED and DECREED that Plaintiffs Motion is Granted, and the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon defendant, Dominic J. Oliveri, by (i) posting a copy of the Complaint upon the mortgaged premises, 235 Bobcat Road, Carlisle, PA, 17013, and (ii) publication in Cumberland County, Pennsylvania pursuant to Pa. R.C.P. No. 430(b)(1); and, it is further ORDERED and DECREED that all future documents normally required to be personal served upon defendant, Dominic J. Oliveri, shall instead be served in the manner listed above. BY E COU T: The Honorable Edward E. Guido Distribution list: David Fein, Esquire, Suite 5000, 701 Market Street, Philadelphia,.PA 19106-1532 Dominic J. Oliveri, 235 Bobcat Road Carlisle, PA 17015 ; Sonya H. Oliveri a/k/a Sonya Oliveri, 235 Bobcat Road Carlisle, PA 17015 57746FC 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: January 18, 2008 TO: DOMINIC J OLIVERI 906 Indian Mound Road Indian Mound, TN 37079 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) TO: DOMINIC J OLIVERI 906 Indian Mound Road Indian Mound, TN 37079 IMPORTANT NOTICE In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-6653 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Josevh 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 57746FC 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: January 18, 2008 TO DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. DOMINIC J. OLIVERI SONYA H. OLIVERI aIkla SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 TO: DOMINIC J. OLIVERI 235 Bobcat 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. 07-6653 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Josevh 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 57746FC 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: January 18, 2008 TO: SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) TO: SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 07-6653 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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, DOMINIC J. OLIVERI, is about unknown years of age, that Defendant's last known residence is 235 Bobcat 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 o rwise within the provisions of the Soldiers' and Sailors' C it Relief Action of Congress of 1940 and its Amendments. Date: 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, SONYA H. OLIVERI a/k/a SONYA OLIVERI, is about unknown years of age, that Defendant's last known residence is 235 Bobcat 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 oth wise within the provisions of the Soldiers' and Sailors' vi Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McK_ EEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) No. 07-6653 ORDER FOR JUDGMENT Please enter Judgment in favor of WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DOI, MORTGAGE PASS THROUG E TIFICATES SERIES 2004- DO1, and against DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a A OLIVERI for failure to file an Answer in the above action within (20) days (or sixty (60) days if defen a t the United States of America) from the date of service of the Complaint, in the sum of $96,345.31. Michael T.1` Attorney for I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRU TEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECE LE LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 710 orp ate Drive PTX B-35 Plano, TX 75024-3632 and that the name(s) and last known address(es) of the De n ant is/are DOMINIC J. OLIVERI, 235 Bobcat Road Carlisle, PA 17015 and SONYA H. OLIVER a/ a NYA OLIVERI, 235 Bobcat Road Carlisle, PA 17015; GOLDBECK McC FJR?Y & McKEEVER BY: Michael T. Mc ever Attorney for Plaintif ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $83,077.76 Interest from 05/04/2007 through $7,300.74 01/29/2008 Reasonable Attorney's Fee $4,153.89 Late Charges $342.56 Costs of Suit and Title Search $900.00 Escrow Payments Due 3 X $190.12 $570.36 $96,345.31 GOLDBECKTV BY: Michael T. Attorney for Ply TY & McKEEVER AND NOW, this 30 day of Qanouy , 2008 damages are assessed as above. Pro P othy ' 9s -` cil D Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff No. 07-6653 vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagors and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: If you have any questions concerning the above, please contact: //30/ 0$ Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 V PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.RCP 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff vv -- 1 -l V 1 Al N11, IN Cl l 1111 V t1L t13 JVl.1t1111J1-4 AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-6653 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 01/30/2008 to Date of Sale at 11.8400% (Costs to be added) $96,345.31 GOLDBECK McCAF ERN & BY: Michael T. McK ver Attorney for Plaintiff d w a a z 0 K1 O 1 H°O x a O U W x F z C/? U ¢Wa oQw? ¢w?? Q Q w U o H?¢o ¢wQW? OWUd? h x ¢ ? ? zow°? ?QdoU ? .?" Q Q iwr O?Wv? QO??U w ?O qR J -606- 8 f ? O O > ?°?? O ` U 0 0 l W W Z ? o U ? > w w o ? U V] ¢ ,Mi a +?i c? h ? ? at N ? T Ro??? cC' ? ' U ? 4J y (21 ? b 0 CZ D z Q) 79 -r- Sb O - W " t ' rt V? O Q 00 0 b 0000000 ~ ? - c, o a _ x n b k O D 4 1 (lp l? Commitment No. 551 All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 3C feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383-062 r? .h. Goldbeck McCafferty & McKeever BY: Michael-T. McKeever - Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301, 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: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat 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: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 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 235 Bobcat Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to information and belief. I understand that false statements herein are made subjec relating to unsworn falsification to authorities. DATED: January 28, 2008 my personal knowledge or alties of 18 Pa. C.S. Section 4904 GOLDBECK McC BY: Michael T. Mc Attorney for Plainti n PIA ??? N r GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, DOMINIC J. DOMINIC J OLIVERI 906 Indian Mound Road Indian Mound, TN 37079 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm. 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311 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 07-6653 8 Irvine Row Carlisle, PA 17013 717-243-9400 - .. - 07-6653 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 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 Judy 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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-6653 I 07-6653 GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, DOMINIC J. DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 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 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 07-6653 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6653 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_ov_ for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 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 homeretentionggoldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-6653 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, SONYA H. a/k/a SONYA OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. IN THE COURT OF COMMON PLEAS NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 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 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 Sheriff s 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 07-6653 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6653 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 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 homeretentionggoldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 07-6653 I, Michael T. McKeever, Esquire hereby certify that I am the attorne of r ord for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 a he Vintiff has complied with all the provisions of the Act. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Michael T. Attorney fc cs ? T] f .?P f` "?"` ? ?? ? ??'' ?? '. ? ? ? . ry ? =. "C <µ.? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6653 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee on behalf of THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1, Plaintiff (s) From DOMINIC J. OLIVERI, SONYA H. OLIVERI a/k/a SONYA OLIVERI (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 $96,345.31 L.L.$ 0.50 Interest from 1/30/08 to Date of Sale at 11.8400% Atty's Comm % Due Prothy $2.00 Arty Paid $250.32 Other Costs to be added Plaintiff Paid Date: 1/30/08 / i Pr thonotary (Seal) By: REQUESTING PARTY: Name MICHAEL T. MCKEEVER, 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. 56129 Deputy 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 57746FC CF: 11/01/2007 SD: 06/11/2008 $96,345.31 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 CERTIFICATE OF SERVICE PURSUANT TO PaR.C.P. 3129.2 (c) (2) 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 Office4cmpatsa ad" (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 Sheriffs Officekmp*WM adek{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). o.;?e>? %,s.w,otirery %- %.- Published p} Published in accordance with court order . Gvur• .she sQW"y"'4L% Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been ?z- sr _,Cp 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 IS P.S. Section 4904. Respectfully submitted, -'3 BY: Michael T. McKeever Attorney for Plaintiff -ol 0 p I 44r r , • ILl t IL / ` _ fit. ` ' .J? C C • C4 0 :(1 O O Z s ? m N d t d o c • • O log m a U Z_ W Q z O U E d J N W . 0. m WF- o e 3 OE ;O w ?OO? m ? o w u i ? ? ? LL ? m O W ? cq q O E O WU) W cj gym,, O 2J? 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O c m c 0 IL m 0 c ame W m > CL J co O N } Z O W U) > J 6 O O Q rn U Z a 0 o co N 2 > > ?- U O ti U c? U LL Z ` 0 ? ti O a L D WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D61, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI 7105 Corporate Drive PTX B-3 5 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT Of. COMMON PLEAS OF CUMBERLAND COUNTY 07-6653 ORDER AND NOW, this day of ,'6rC&4K , 2007, upon consideration of 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; Dominic l Oliveri, have been -dt=ccesdful, `it is hereby ORDERED and DECREED that Plaintiffs Motion is Granted, and the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon defendant, Dominic J. Oliveri, by (i) posting a copy of the Complaint upon the mortgaged premises, 235 Bobcat Road, Carlisle, PA, 17013, and (ii) publication in Cumberland County, Pennsylvania pursuant to Pa. R.C.P. No. 430(b)(1); and, it is further ORDERED and DECREED that all future documents normally required to be personal served upon defendant, Dominic J. Oliveri, shall instead be served in the manner listed above. B E CO The Honorable Edward E. Guido Distribution list: David Fein, Esquire, Suite 5000, 701 Market Street, Philadelphia,. PA- 19106-1532 Dominic J. Oliveri, 235 Bobcat Road Carlisle, PA 17015 ' Sonya H. Oliveri aAda Sonya Oliveri, 235 Bobcat Road Carlisle, PA 17015 Wells Fargo Bank, National Association, as In the Court of Common Pleas of Trustee on Behalf of the Certificateholders of Cumberland County, Pennsylvania Securitized Asset-Backed Receivables, LLC Writ No. 2007-6653 Civil Term Trust 2004-DO I, Mortgage Pass Through Certificates Series 2004-DO1 VS T??V Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on February 28, 2008 at 1514 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Dominic J. Oliveri, by posting the premises located at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania pursuant to order of court, according to law with a true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on February 28, 2008 at 1514 hours, he served a true copy of the within Real Estate Writ, Notice and Description in the above entitled action, upon the within named defendant, to wit: Sonya H. Oliveri a/k/a Sonya Oliveri, by making known unto Valerie Kerseman, adult daughter of Sonya H. O lilveri, at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 01, 2008 at 1430 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 Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri located at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri by regular mail to their last known address of 235 Bobcat Road, Carlisle, PA 17015. These letters were mailed under the date of March 31, 2008 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff BJ?? r Real Estate rgeant 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) Term No. 07-6653 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 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: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL, ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat 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: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 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. PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 TENANTS/OCCUPANTS 235 Bobcat Road Carlisle, PA 17013 (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 unworn falsification to authorities. DATED: May 1, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff c. = Z3 1. Wells Fargo Bank, National Association, as In the Court of Common Pleas of Trustee on Behalf of the Certificateholders of Cumberland County, Pennsylvania Securitized Asset-Backed Receivables, LLC Writ No. 2007-6653 Civil Term Trust 2004-DO I, Mortgage Pass Through Certificates Series 2004-DO1 VS Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on February 28, 2008 at 1514 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Dominic J. Oliveri, by posting the premises located at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania pursuant to order of court, according to law with a true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on February 28, 2008 at 1514 hours, he served a true copy of the within Real Estate Writ, Notice and Description in the above entitled action, upon the within named defendant, to wit: Sonya H. Oliveri a/k/a Sonya Oliveri, by making known unto Valerie Kerseman, adult daughter of Sonya H. O lilveri, at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 01, 2008 at 1430 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 Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri located at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri by regular mail to their last known address of 235 Bobcat Road, Carlisle, PA 17015. These letters were mailed under the date of March 31, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Michael McKeever. Sheriffs Costs: Docketing 30.00 Poundage 17.38 Advertising 15.00 Posting Handbills 15.00 Law Library .50 Prothonotary 2.00 Mileage 17.28 Levy 15.00 Surcharge 30.00 Posting 6.00 Postpone Sale 40.00 Law Journal 355.00 Patriot News 328.46 Share of Bills 14.73 CIO $ 886 35 . I So S, R. Thomas Kline, Sheriff BY v U'?(.v1 Real Estate S eant a Goldbeck McCafferty & McKeever BY: Michael-T. McKeever - Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) No. 07-6653 AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1, 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: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI .235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 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 235 Bobcat Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to be f my personal knowledge or information and belief. I understand that false statements herein are made subjec to a nalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: January 28, 2008 GOLDBECK McC FE Y cKEEVER BY: Michael T. Mc eev q. Attorney for Plaintif - w GOLDBECK McCAFFERTY & McKEEVER 07-6653 BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DOI, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 I IN THE COURT OF COMMON PLEAS Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(sA of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, DOMINICJ. DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE r. 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01, 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 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 STELL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid 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 07-6653 07-6653. 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 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 homeretention@goldbecklaw.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 57746FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. 07-6653 GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVER] Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVER[, SONYA H. a/k/a SONYA OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO] against you. IN THE COURT OF COMMON PLEAS NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 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 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 Sheriff s 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 07-6653 07-6653 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 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 homeretentionCa,goldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. Commitment No. 551 All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383-062 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-6653 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee on behalf of THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1, Plaintiff (s) From DOMINIC J. OLIVERI, SONYA H. OLIVERI a/k/a SONYA OLIVERI (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 $96,345.31 L.L.$ 0.50 Interest from 1/30/08 to Date of Sale at 11.8400% Atty's Comm % Atty Paid $250.32 Plaintiff Paid Date: 1/30/08 Due Prothy $2.00 Other Costs to be added Prothonotary (Seal) REQUESTING PARTY: By: Deputy Name MICHAEL, T. MCKEEVER, 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. 56129 Real Estate Sale # 15 On February 15, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA Known and numbered as 235 Bobcat Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 15, 2008 Real Estate Sergeant bZ a V h - 9318001 -4 83HS 3H1'`Jo ]J?JJOJ 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: May 2, May 9, and May 16, 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. r L' Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 16 day of May, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSion Expires Apr 28, 2010 WAR" ft" NO. 15 Writ No. 2007-6653 Civil Wells Fargo Bank, National Association, as Trustee on Behalf of the Certificateholders of Securitized Asset-Backed Receivables, LLC Trust 2004- DO 1, Mortgage Pass Through Certificates Series 2004-DO 1 vs. Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri Atty.: Joseph Goldbeck Commitment No. 551 All that certain tract of land with the improvements thereon erected situate in Lower Franldord Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harvitl D. Lindsey, Jr., North 73 dagses 29 minutes West 544.57 feet to epee iron pin; thence along, property of Xftw D. Bartels, North 9 dqpvm 30 asioutes, Eeat 573 feet to a stain; thence olong the same, North 14 de- grees 38 minutes East 133 feet to a stake; thence along property of Rich- ard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383- 062. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE t4tPatriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/23/08 04/30/08 05/07/08 .. ............. Sworn to nd bscribed before me this 27 day of May, 2008 A.D. Notary•Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Chyrie L. Sheppard, Notary Public City Of Harrisburg, Dauphin County My Commission Expires May 29.2010 Member, Pennsylvania Association of Notaries Real Estate Sale #15 Writ No. 2007-6653 Civil Term Wells Fargo Bank, National Association, as Trustee on Behalf of the Certificateholders of Securitized Asset-Backed Receivables, LLC Trust 2004- D01, Mortgage Pass Through Certificates Series 2004-D01 VS Dominic J. Oliveri and Sonya H. Oliveri a/kla Sonya Oliveri Attorney: Joseph Goldbeck DESCRIPTION Commitment No. 551 All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the comer of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 teet to a spike in the center of the aforesaid road; thence along the latter. South 79 degrees 45 minutes West 30 feet to a spike, the place of h°ginning. TAX PARCEL N0: 14-04-0383-062 R PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOT41NIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-6653 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 01/30/08 to Date of Sale per diem at $26.94 (Costs to be added) Y d ? y U ?a M .y y ? d? G d? ? W U ? a d w? U r!i d' a 'o Q '' M W e W ` u° J a V I o ?wWd dH ? a ?' ?o W ° Q °? ? a o X., o c ° ? d W W ? """ .-a ?` w' U G? r l ? 07 c1 d` U O r G tn P4 V')Q Q?y1U? cWi ? HH ? _ ° W ? .. tx O o ?o a o ? ol ??W c w U ? ` U C7 ? W ? dd`t' ? Q? o W p O WN°oW U '.? O o+ H dO ?? ? w ? Y Cty N v _ r LR C3 __? C v m a C-4 v 0 All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383-062 BEING KNOWN AS 235 BOBCAT ROAD, CARLISLE PA 17013 r 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I, 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: 235 Bobcat Road Carlisle, PA 17013 I.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI aWa SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 4. Name and address of the last recorded holder of every mortgage of record: ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. AKA ASSOCIATES FINANCIAL 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 5. Name and address of every other person who has any record interest in or record lien oil 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. PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 TENANTS/OCCUPANTS 235 Bobcat Road N Carlisle, PA 17013 (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 y ersonal knowledge or information and belief. I understand that false statements herein are made subject to the s of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. 741 / DATED: February ? 0, 2009 GOLDBECK M AFFERT l & BY: Michael . McKeever, Es Attorney for laintiff r C\j. LLJ -- C) LI1 L~i LA- ?y N ( ) - GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s; 07-6653 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVER[, DOMINIC J. DOMINIC J OLIVERI 906 Indian Mound Road Indian Mound, TN 37079 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 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 4. 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 07-6653 2 Liberty Avenue Carlisle, PA 17013 07-6653 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: 717-243-9400 or. 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: bttp://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretentiong oldbecklaw.com. Call Judy 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 5774617C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ll_1 CY_ - LU W Lt_ C) c-) U N 07-6653 GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, SONYA H. a/k/a SONYA OLIVER] SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 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. 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 4. 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. 8. You may contact the Foreclosure Resource Center: http://www.12hiladelphiafed.org/foreclosure/ 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-6653 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 C`J Ll! ?? C,d ?j4? Lo LA- L3,. cry C N U Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has co Act. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 07-6653 06 Plaintiff in this action, and with all the provisions of the Michael T. KeeA Attorney f plaintiff cJ C7 U? Ls t LLi Z Ln Lu _ LA._ { L„ LL- 0 (71 _ C) U Clq SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 235 Bobcat Road Carlisle, PA 17013 SOLD as the property of DOMINIC J. OLIVERI and SONYA H. OLIVERI aWa SONYA OLIVERI TAX PARCEL #14-04-0383-062 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-6653 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK ASSOCIATION Plaintiff (s) From DOMINIC J. OLIVERI AND SONYA H. OLIVERI A/K/A SONYA A. OLIVERI (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$ 96345.31 L.L. Interest FROM 01/30/08 TO DATE OF SALE PER DIEM AT $26.94 Atty's Comm % Atty Paid $1158.17 Plaintiff Paid Due Prothy $2.00 Other Costs Date: FEBRUARY 11, 2009 (Seal) 061s R. Lon o ota By: Deputy REQUESTING PARTY: Name MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER, SUITE 5000 - MELLON INDEPENDENCE CENTER, 701 MARKDET STREET, PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 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 57746FC CF: 11/01/2007 SD: 06/10/2009 $96,345.31 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURTTIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. Plaintiff DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 07-6653 Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: bQ Personal Service by the Sheriffs Officeio@wpoiwA-a"t (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. ?C) Premises was posted by Sheriffs Offic%*WW a (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, ,gyp:122? i BY: Michael T. McKeever, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OQ C .r- N ?yy,?? ag ? ?SLL? N N U 8 t ENO Tv ? o? r` cro? q?? n o ,TAI ss Q ? 7 ?7 • ? °i,iLl $ Z Wr ? to ?O s Vr Al, sn o.5 m rpj I to xy$ zs G a- O p_ Z w w cl) Q?O T U ? ? a - L U alf g c y ? to tic o fer- ?c x N Via. Val P T 4 Aa J uJ s N o Cf) T r' u i t y v T NV OG W ? a¢ F.,. cn to ? OC ? N ? J Y 173 :? ? C! OtL W W ?? a? N rsr z U Z O % ZN 0 O Q? W ? W NN y?? Ob w Q t7 rA'? W .4~ N d Uy 4 UJciumi? ? ? rU Nc? per. ZZ¢ F11 cw tai- O p 10- ?? cs +Q tl) u! 7' 4 W a m pG of t ck Cl. 61 m tp-Ou`?3 aGca°o u 4? a? o ? O1r?g 0O OG. 0 c RL 7l a c m O c a i t 1 W O? Q Z O ? Q c`n > Q c w J " o to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF. COMMON PLEAS OF CUMBERLAND COUNTY 07-6653 ORDER AND NOW, this day of Zc 2007, upon S consideration of 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; DominicI Oliveri, have been unsuccessful,' it is hereby ORDERED and DECREED that Plaintiffs Motion is Granted, and the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon defendant, Dominic J. Oliveri, by (i) posting a copy of the Complaint upon the mortgaged premises, 235 Bobcat Road, Carlisle, PA, 17013, and (ii) publication in Cumberland County, Pennsylvania pursuant to Pa. R.C.P. No. 430(b)(1); and, it is further ORDERED and DECREED that all future documents normally required to be personal served upon defendant, Dominic J. Oliveri, shall instead be served in the manner listed above. B E CO The Honorable Edward E. Guido Distribution list: David Fein, Esquire, Suite 5000, 701 Market Street, Philadelphia,.PA 19106-1532 Dominic J. Oliveri, 235 Bobcat Road Carlisle, PA 17015 ` Sonya H. Oliveri a/k/a Sonya Oliveri, 235 Bobcat Road Carlisle, PA 17015 Form 3877 Domestic USPS Firm Mailing Book Name and Address of Sender: Permit Number Sequence Number JOSEPH A GOLDBECK JR 1443A MELLON INDEPENDENCE CE NT 701 MAWT ST STE 5000 Ascent - MAC v7.50.7.51.J PHILADELPHIA, PA 19106 ------------------- -------- --------- ---------------------- --------------------------- ------------------------------------- Piece ID Article / -------- Delivery Address SS Fee Postage value Sender Charges Addressee Name Type Insur./Register Due Total - ------------------------------- ------------------------------------- 73234JV5-15 71114342363000525085 --------------------------- VANDEVERE, JENNIFER -------- C --------- 2.70 ---------------- - 0.42 4.12 213 Fawnhill Road ERR 1.00 Broomall, PA 19008 75322RT5-8 71114342363000525092 TERRY, ROBERT C. a/k/a ROBERT T C 2.70 0.42 4.12 140 New Road ERR 1.00 Southampton, PA 18966 73714JA6-10 71114342363000525108 ARNOLD, JASON A. C 2.70 0.42 4.12 220 York Road ERR 1.00 Carlisle, PA 170.13 57746SO6-10 71114342363000525115 OLIVERI, SONYA H. a/k/a SONYA O C 2.70 0.42 4.,12 - - .. 2.35 Bebeat Read ERR 1.00 - ,- Carlisle, PA 17015 746DO6-10 71114342363000525122 OLIVERI, DOMINIC J. C 2.70 0.42 4.12 235 Bobcat Road ERR 1.00 17015 57746DO6-10.0171114342363000525139 OLIVERI, DOMINIC J. C 2.70 0.42 4.12 906 Indian Mound Road ERR 1.00 Indian Mound, TN 37079 75644JC5-22 71114342363000525146 CORCORAN, JOSEPH J. C 2.70 0.42 4.12 2343 South Fifth Street ERR 1.00 Allentown, PA 18103 70536AM5-12 71114342363000525153 MORDAN, ANGELA M. C 2.70 0.42 4.12 462 Duke Street ERR 1.00 Northumberland, PA 17857 ------------------------------------- Page Totals: 8 --------------------------- --------- -------- 29.60 ---------------------- 3.36 -------------------------- 32.96 Cumulative Totals: 32 118.40 13.44 131.84 Page 4 ?µd? 1- 3• C^ y? /D+ , \? S will In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-6653 Civil Term Wells Fargo Bank, National Association as Trustee on behalf of the Certificateholders of Soeuri&ed Amot-Beeked Recei Y ables EW Trust 2004 DO!, Mortgage Pass 9FInotigh Certificates Series 2004-DOI Vs Dominic J. Oliveri and Sonya H. Oliveri, a/k/a Sonya Oliveri williarn Cline; Deputy SheriM, who-being duty swom arzakthig to I P sums MR 6n February 21, 2009 at 1012 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Dominic J. Oliveri, by Posting Property Pursuant to Court Order, at, 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania its contents. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 21, 2009 at 1012 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sonya H. Oliveri, a/k/a Sonya Oliveri , by making known unto Sonya H. Oliveri, a/lr/a Sonya Oliveri , personally, at, 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2009 at 1444 hours,she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dominic J. Oliveri and Sonya H. Oliveri, a/k/a Sonya Oliveri , located at, 235 Bobcat Road, Carlisle, Cumberland County Pennsylvania, according to law. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Dominic J. Oliveri and Sonya H. Oliveri, a/k/a Sonya Oliveri by regular mail to their last known address of, 235 Bobcat Road, Carlisle, PA 17015. This letter was mailed under the date of April 1, 2009 and returned to the Sheriffs Office on April 8, 2009 for Dominic J. Oliveri, forwarding time expired. R. Thomas Kline, Sheriff GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) Term No. 07-6653 AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1, 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: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL, ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat 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: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. AKA ASSOCIATES FINANCIAL 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 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. PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 TENANTS/OCCUPANTS 235 Bobcat Road Carlisle, PA 17013 (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: May 27, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff A i' 21 C 0, -; r•r OF THE: In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-6653 Civil Term 20U9 JUL 35 0 'i 1 C v Wells Fargo Bank, National Association as Trustee on behalf of the Certificateholders of Securitized Asset-Backed Receivables LLC Trust 2004-DO1, Mortgage Pass Through Certificates Series 2004-DO1 Vs Dominic J. Oliveri and Sonya H. Oliveri, a/k/a Sonya Oliveri William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 21, 2009 at 1012 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Dominic J. Oliveri, by Posting Property Pursuant to Court Order, at, 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania its contents. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 21, 2009 at 1012 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sonya H. Oliveri, a/k/a Sonya Oliveri , by making known unto Sonya H. Oliveri, a/k/a Sonya Oliveri , personally, at, 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2009 at 1444 hours,she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dominic J. Oliveri and Sonya H. Oliveri, a/k/a Sonya Oliveri , located at, 235 Bobcat Road, Carlisle, Cumberland County Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Dominic J. Oliveri and Sonya H. Oliveri, a/k/a Sonya Oliveri by regular mail to their last known address of, 235 Bobcat Road, Carlisle, PA 17015. This letter was mailed under the date of April 1, 2009 and returned to the Sheriffs Office on April 8, 2009 for Dominic J. Oliveri, forwarding time expired. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per Attorney McKeever on July 28, 2009. Sheriff's Costs: Docketing 30.00 Poundage 15.85 Posting Bills 15.00 Advertising Prothonotary Milage Levy Surcharge Law Journal Patriot News Share of Bills So Answers, _ R. Thomas Klme, Sh nff Rea s15.00 By 2.00 18.00 15.00 30.00 355.00 276.92 15.43 808.20 ?"So.0 g9L S 'Yu 3' 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 No. 07-6653 AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301, 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: Plaintiff Defendant(s) 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 4. Name and address of the last recorded holder of every mortgage of record: ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. AKA ASSOCIATES FINANCIAL 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL, INC. I Valley Street, Suite 103 Carlisle, PA 17013 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. PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 TENANTS/OCCUPANTS 235 Bobcat Road Carlisle, PA 17013 (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 y ersonal knowledge or information and belief. I understand that false statements herein are made subject to the pea es of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. / DATED: February 10, 2009 GOLDBECK M AFFERT4& BY: Michael . McKeever, Es Attorney for/, aintiff 07-6653 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s Term No. 07-6653 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: OLIVERI, DOMINIC J. DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301, 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. 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 4. 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. I . 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. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 07-6653 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-6653 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: 717--243-9400 or. 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretention@g_oldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. A. GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. Plaintiff DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, SONYA H. a/kh SONYA OLIVER] SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. 07-6653 IN THE COURT OF COMMON PLEAS NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01, 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. 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. 4. 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. 1 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. / 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 i 07-6653 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 t 07-6653 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: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HOD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/con,,3umers/homeowners/real.asax. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretention(2goldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383-062 BEING KNOWN AS 235 BOBCAT ROAD, CARLISLE PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N007-6653 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK ASSOCIATION Plaintiff (s) From DOMINIC J. OLIVERI AND SONYA H. OLIVERI A/K/A SONYA A. OLIVERI (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$ 96345.31 L.L. Interest FROM 01/30/08 TO DATE OF SALE PER DIEM AT $26.94 Atty's Comm % Due Prothy $2.00 Atty Paid $1158.17 Other Costs Plaintiff Paid Date: FEBRUARY 11, 2009 A-11606A-0.A C is R. Long, P no ry (Seal) By: Deputy REQUESTING PARTY: Name MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER, SUITE 5000 - MELLON INDEPENDENCE CENTER, 701 MARKDET STREET, PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale # 39 On February 13, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA Known and numbered as 235 Bobcat Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 13, 2009 BY: QP90 F - P, 7 7?,, V??3 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: May 1, May 8, and May 15, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 71, at,__ a a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this day of Mme. 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 FA" DWAM IM" 114. 33 Writ No. 2007-6653 Civil Wells Fargo Bank, National Association as Trustee on behalf of the Certificateholders of Securitized Asset-Backed Receivables LLC Trust 2004-DO1, Mortgage Pass-Through Certificates Series 2004-DO1 vs. Dominic J. Oliveri and Sonya H. Oliveri a/k/a Sonya Oliveri Atty.: Michael T. McKeever All that certain tract of land with the improvements thereon erected situate in Lower Franldord Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 de- grees 38 minutes East 133 feet to a stake; thence along property of Rich- ard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383- 062. BEING KNOWN AS 2335 BOBCAT ROAD, CARLISLE, pA 170I3. ..The Patriot-News Co. 812 Market'St. Harrisburg, PA 17101 Inquiries - 717-.255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ?tatriot•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: 04/24/09 05/01109 05/08109 ll.-l`1.771t j- ........... Sworn to ahd subscribed before me this 12 day of May, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seas Sherrie L. Kisrer, Notary Public City Of Harrisburg, t3a,uphirr Courrty h'?Y lion Expires Nov. 2t3, 2011 Member, Pennsylvania Association of Notaries Real Estate Sale No. 39 Writ No. 2007-M3 Civil Term Wells Fargo Bank, National Association as Trustee on behalf of the Certftlcateholders of Securitized Asset-Backed Receivables LLC Trust 2004- D01, Mortgage Pass-Through Certificates Series 2004-D01 VS Dominic J. Ollverl and Sonya H. Oliveri, slide Sonya Oilveri Attorney Michael T. Mckeever LEGAL DESCRIPTION All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the comer of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL N0; 14-04-0383-062 BEING KNOWN AS 235 BOBCAT ROAD, CARLISLE PA 17013 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-6653 Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 1/30/08 to Date of Sale per diem at $26.94 (Costs to be added) $96,345.31 mmc?? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff Y' C6 00 1L) O 0-70 9 C8 In. c=am cfY U W O zA wo ?' N 0, O W UH?,??A 'ad ? W ??? M ? ?? O OGo O O o4AWW ?,?gydw w d Ems"' dWt R4 W U a` ?,Qo ?'ow0Q a GNU ?'? ?doA? Cax a U W ?mW oW ?? H o H U oG 3?0 N vu4 i d a?i y U M U ? Cj Q N .c cd r+ P+ N a t? 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I, 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: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat 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: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC C/O Phelan Hallinan & Schmieg, LLP -SUITE 1400 One Penn Center at Suburban Station -1617 John F. Kennedy Boulevard Philadelphia, PA 19103 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL MORTGAGE CO. INC. AKA ASSOCIATES FINANCIAL 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 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. PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 TENANTS/OCCUPANTS 235 Bobcat Road Carlisle, PA 17013 (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 unworn falsification to authorities. DATED: August 4, 2009 GOLDBE 'm 'fl ??? CK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff a- IIIRY L(+i11 !'t .J -J 1 `7 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 07-6653 I, Michael T. McKeever, 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. /Y) a\40,", Michael T. McKeever Attorney for plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE {A i... u F kl? l?/ :. .. wi 1 07-6653 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s, IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, DOMINIC J. DOMMIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 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 1-866413-2311. 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. 4. 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 B& 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. 8. You may contact the Foreclosure Resource Center: ho://www.& adelphiafed.org[foreclosure/ 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 07-6653 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6653 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hn://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretention@goldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-6653 GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, SONYA H. a/k/a SONYA OLIVEM SONYA H. OLIVERI alk/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. IN THE COURT OF COMMON PLEAS NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01, 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 1-866413-2311. 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. 4. 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 fmd 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. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.ore/foreclosure/ 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 Y 07-6653 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 P 07-6653 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website ht!p://www.phfa.orp-/consumers/homeowners/real.gWx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretention(a`,goldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. At 07-6653 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIWFJ, DOMINIC J. DOMINIC J OLIVERI 906 Indian Mound Road Indian Mound, TN 37079 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 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 4. 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 STELL 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 07-6653 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6653 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: htip://www.phfa.orp-/conswners/homeowners/real.Upx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretentionna,goldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6653 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee on behalf of the CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1, Plaintiff (s) From DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVER] (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 $96,345.31 L.L. Interest from 1/30/08 to Date of Sale per diem at $26.94 - to be Determined Atty's Comm % Atty Paid $1,839.87 Plaintiff Paid Date: 8/06/09 Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET ST PHH,ADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF -F-.y Telephone: 215-627-1322 Supreme Court ID No. 56129 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 57746FC CF: 11/01/2007 SD: 12/09/2009 $96,345.31 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-3 5 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (yl) Personal Service by the Sheriffs Office/oompetem (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. (y?j Premises was posted by Sheriffs Office eten!- I *(copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). 4L) 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, BY: Michael T. McKeever, Esquire Attorney for Plaintiff 90 W 3000dtZ WOMd OMIVV# y $ soot ztonv Lssssztiooo oft-got we zo u ?6 ? ?++u I CO U- a sr. C ?, Z d Le o w 0 J CC Z (/1 ? O U > = 0 ?. U ? w W z to _ .0 r a) 0 ca 0. + ? a v (? = U tY > T U m U w ? °``? K! M 9 o -? Q at?i a a=?ti m yo L ???r !L+• m p?? ?M NO P. m LL .Z O r u°? r d 7 39 ty1 13r x o?_ o ° L ma a i? $ CL a V 1 1 3: a o ?Z g' N r ? m ?? ~73 o ! U Z - ? e c d a f - 7 UQ.-m C.)rC) (/? o QwU U D. m .- G NU O a C ???? ? Q S F O 1 h s z ?n z C g - 11, ?d ? as .` ' n 21 r- wDw z L 5 I G 00 EIEIO $$ ? d 3 a vie c? a gin M on S z N ? d a beOY $ JN ?m$OC W ap W M gE Z 0 5 O=? en.wp..._ ? N c7 lf1 t0 t? 00 oI. Q a CL m 0 m N ?,N U m N U U e+f ? m U- a 1C R J O Z O J 0 } Z O co G5 O _Z in WELLS FARGO BANK, NATIONAL . ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF. COMMON PLEAS OF CUMBERLAND COUNTY 07-6653 ORDER AND NOW, this / ? . day of LlCC,4K , 2007, upon ` ° consideration of Plaintiff s 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, Dominic'J. Oliveri, have been unsuccessfuIjt is hereby ORDERED and DECREED that Plaintiffs Motion is Granted, and the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon defendant, Dominic J. Oliveri, by (i) posting a copy of the Complaint upon the mortgaged premises, 235 Bobcat Road, Carlisle, PA, 17013, and (ii) publication in Cumberland County, Pennsylvania pursuant to Pa. R.C.P. No. 430(b)(1); and, it is further ORDERED and DECREED that all future documents normally required to be personal served upon defendant, Dominic J. Oliveri, shall instead be served in the manner listed above. B E CO The Honorable Edward E. Guido Distribution list: David Fein, Esquire, Suite 5000, 701 Market Street, Philadelphia,. PA- 19106-1532 Dominic J. Oliveri, 235 Bobcat Road Carlisle, PA 17015 ' Sonya H. Oliveri a/k/a Sonya Oliveri, 235 Bobcat Road Carlisle, PA 17045 Form 3877 Domestic USPS Firm Mailing Book Name and Address of Sender: Permit Number Sequence Number JOSEPH A GOLDBECK JR. 2460A MELLON INDEPENDENCE-CENT 701 MARKET ST STE 5000 Ascent - MAC v7.50.7.70.J PHILADELPHIA, PA 19106 ---------------------------------------------------------------------------------------------------------------------------------- Piece ID Article # Delivery Address SS Fee Postage Value Sender Cbarges Addressee Name Type Insur./Register Due Total ---------------------------------------------------------------------------------------------------------------------------------- 81906MM12-04.071114342363000669383 MORENO, MANNY C 2.80 0.44 4.34 1595 Helffricb Road ERR 1.10 Kutztown, PA 19530 81238SF10-19 71114342363000669390 FITZGERALD, SHANNON C 2.80 0.44 4.34 411 Beaver Street ERR 1.10 Leetsdale, PA 15056 81238JF10-19 71114342363000669406 FITZGERALD, JONATHAN C 2.80 0.44 4.34 411 Beaver Street ERR 1.10 Leetsdale, PA 15056 83298MK10-19 71114342363000669413 MORRIS, MARY J. C 2.80 0-44 4.34 112 Bennett Boulevard ERR 1.10 Aliquippa, PA 15001 83298KM10-19 71114342363000669420 MORRIS, KENNY R. C 2.80 0.44 4.34 112 Bennett Boulevard ERR 1.10 Aliquippa, PA 15001 57746DO12-09 71114342363000669437 OLIVERI, DOMINIC J. C 2.80 0.44 4.34 906 Indian Mound Road ERR 1.10 Indian Mound, TN 37079 57746DO12-09.071114342363000669444 OLIVERI, DOMINIC J. C 2.80 0.44 4,34 235 Bobcat Road ERR 1.10 Carlisle, PA 17015 NTA, S 57746SO12-09 71114342363000669451 OLIVERI, SONYA H. a/k/a SONYA O C 2.80 0.49 ?•a ?' %iti? Z ii 4.34 235 Bobcat Road ERR 1.10 i ?ltti ` o i ? p Carlisle, PA 17015 ^ -----------------------------------fD'IPHt??r. ------------------------------------------------------------------- _ -------------- Page Totals: 8 31.20 3.52 34.72 Cumulative Totals: 16 62.40 7.04 69.44 Page 2 Y. ,? N,??,,. _ .,,?t K ,? Sheriffs Office of Cumberland County R Thomas Kline Sheri at ?rmbr Ronny R Anderson Chief Deputy. Jody S Smith j` Civil Process Sergeant OFFICE OF THE V46MFF Edward L Schorpp Solicitor Wells Fargo Bank vs. Case Number Dominic J Oliveri 2007-6653 SHERIFF'S RETURN OF SERVICE 10/02/2009 07:07 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 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 Dominic J. Olived & Sonya H. Olived, located at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania according to law. 10/02/2009 07:07 PM - Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on 10-02-09 at 1900 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dominic J. Oliveri, located at 23E Bobcat Road, Carlisle, Cumberland County, Pennsylvania according to law. 101022009 07:07 PM - Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on 10-02-09 at 19W hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sonya H. Oliveri, by making known unto, Sonya H. Olived, personally, at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same tune handing to her personally the said true and correct copy of the same. PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tames Kleinklaus, Advertising Operations Director of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): November 6, 2009 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are Sworn to and subscribed before me this oaq Notary Public My commission expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SAMBI ANN HECKENDORK Notmy Public Camp Hill Boro., Cumbe W Commission Expia Janueg, 27, 7?b10 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland James Kleinklaus, Advertising Operations Director of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13w,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): November 6. 2009 COPY OF NOTICE OF PUBLICATION IN THE CQQ. j1 OF COMMON PLEAS OF 1 110SEHL.AND COUNTY ores that he/she is not CrAL ACTION - LAW :TION OF flORTGAdF FORECLOSURE ?blect matter of the It.. Mo.07400 = - AAS TR()g7?E ON BEHALF OF THE IFIC/l C ` advertisement, and that . 'r+Ft t` ftLkc - USr2oo4-nod, MoRT? E+ 71 05 Corporate Dike. PTX 8-3k PhM. TX qA$$ H "SONYA;OL1YER',MOMR'O?sandRecotdQrmwa?, gNlc ? a foregoing statement as -characterof publication ARE ATTEMPTING TO COLLECT DCOLLR AND WE FWM ANY INFORMATION OBTAIA S ? ? ;OFQA&EQE9EALpgg? thole IaBt krrUWa 8ddreee Is 236 Bobcat Road- Chiu PA i7Q ?5 ` r_PA 470I?; i?_idMdWed ID be sold at 3berlrs s6. ti.. w wsr?: scribed before me this L F... Y) .rY Notary Public PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz November 13, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 13 day of November, 2009 Notary NOTARKL SEAL DEBORAH A COWNS Notary Public CARLISLE BORO, CUMBERLAND COUNTy My Commission Exptrea Apr 28.2010 CUMBERLAND LAW JOURNAL ACTIOR OF 19OATOAp$ FORECLOSURE In the Court of Common Pleas of Cumberland County Civil Action-Law No. 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIRCATEHOLDERS OF SECUR17MD ASSET-BACKED RECEIVABLES LLC TRUST 2004- DOl, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I, 7105 Corporate Drive, PTX B-35, Plano, TX 75024-3632, Plaintiff VS. DOMINIC J. OLWERI, SONYA H. OLiVERI a/k/a SONYA OLIVERI, Mortgagors and Record Owners, 235 Bobcat Road, Carlisle, PA 17013, Defendants THIS LAW FIRM IS A DEBT COL- LECTOR AND WE ARE ATIEMPMG TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMA- TION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DOMINIC J. OLIVERI, Defen- dant, whose last known address is 235 Bobcat Road, Carlisle, PA 17015. Your house at 235 Bobcat Road, Carlisle, PA 17013, is acheduled to be sold at Sherffs Sale on Wednesday, December 9, 2009, at 10:00 A.M., in Commissioners Hearing Room, 2nd FL, Courthouse, to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATE- HOLDERS OF SECURITIZED AS- SET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1)0 1 against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sole will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATE- HOLDERS OF SECURITIZED AS- SET-BACKED RECEIVABLES LLC TRUST 2004-DOI, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI, the back payments, late charges, costs and reasonable at- torney's fees due. To find out how much you must pay call our office at (215) 825-6329 or 1-866-413-2311. 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 post- pone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. 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 SHERIFFS SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be said to the highest bidder. You may find out the price bid price by calling the Sheriff of (717) 240-6390.2. You may be ableto peti- tion the Court to set aside the sale if the bid price was grossly inadequate compared to, the value of your prop- CUMBERLAND LAW JOURNAL erty. 3. The sale will go through only if the buyer pays the Sheriff the fall 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 We 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 Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (rea- sons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the sched- ule of distribution is Sled 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center. http://www.phila- delphiafed.org/fmwlom?/ 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 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 or MidPenn Legal Services 401 E. Louther Street Ste. 103 Carlisle, PA 17013 (717) 243-9400 MICHAEL T. McKEEVER, ESQUIRE GOLDBECK MCCAFFERTY & MCEEEVER, P.C. Attorneys for Plaintiff Suite 5000 Mellon Independence Center 701 Madoet St. Philadelphia, PA 19106 (215) 825-6318 Nov. 13 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) Term No. 07-6653 AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301, 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: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat 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: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC C/O Phelan Hallinan & Schmieg, LLP -SUITE 1400 One Penn Center at Suburban Station -1617 John F. Kennedy Boulevard Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL MORTGAGE CO. INC. AKA ASSOCIATES FINANCIAL 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1 I 1 I Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 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 235 Bobcat Road Carlisle, PA 17013 PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 (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 24, 2009 WA JJ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff FLUE . ?; nc Tr? , . Tl?Y 1009 OLE C -2 A,H : - 2 r ?? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy 7: 7,V "',! I.: L:,li, ?? ,I L%. I d i Edward L Schorpp Solicitor Wells Fargo Bank vs. Dominic J Oliveri Case Number 2007-6653 SHERIFF'S RETURN OF SERVICE 10/02/2009 07:07 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 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 Dominic J. Oliveri & Sonya H. Oliveri, located at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania according to law. 10/02/2009 07:07 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1900 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dominic J. Oliveri, located at 23E Bobcat Road, Carlisle, Cumberland County, Pennsylvania according to law. 10/02/2009 07:07 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1900 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sonya H. Oliveri, by making known unto, Sonya H. Oliveri, personally, at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/04/2009 Property sale postponed to 1/6/2010. 01/06/2010 Property sale postponed to 2/3/2010. 01/20/2010 Property sale cancelled on 1/20/2010 01/20/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney McKeever SHERIFF COST: $746.74 SO A, January 21, 2010 ZNY ANDERSON, SHERIFF 3? ?? CO ?yu3? 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 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I, 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: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat 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: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC C/O Phelan Hallinan & Schmieg, LLP -SUITE 1400 One Penn Center at Suburban Station -1617 John F. Kennedy Boulevard Philadelphia, PA 19103 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL MORTGAGE CO. INC. AKA ASSOCIATES FINANCIAL 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1 I I I Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 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. PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 TENANTS/OCCUPANTS 235 Bobcat Road Carlisle, PA 17013 (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: August 4, 2009 a M ( 6 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 07-6653 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, DOMINIC J. DOMINIC J OLIVERI 906 Indian Mound Road Indian Mound, TN 37079 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 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 4. 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 07-6653 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6653 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretentionggoldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-6653 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 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: OLIVERI, SONYA H. a/k/a SONYA OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. IN THE COURT OF COMMON PLEAS NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 07-6653 To prevent this Sheriffs Sale you must take immediate action I . The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO 1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 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. 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 4. 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. 8. You may contact the Foreclosure Resource Center: http•//www philadelphiafed orp-/foreclosure/ 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 07-6653 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 07-6653 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretention(cry_goldbecklaw.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383-062 BEING KNOWN AS 235 BOBCAT ROAD, CARLISLE PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-6653 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee on behalf of the CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1, Plaintiff (s) From DOMINIC J. OLIVERI and SONYA H. OLIVERI a/k/a SONYA OLIVERI (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 $96,345.31 L.L. Interest from 1/30/08 to Date of Sale per diem at $26.94 -- to be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $1,839.87 Other Costs Plaintiff Paid Date: 81'06/09 (Seal) REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET ST PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 - -r -v Supreme Court ID No. 56129 Real Estate Sale # On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA Known and numbered as, 235 Bobcat Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 By: Rea Estate Coordinator V The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 the Pd triot News Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Leslie Kramer, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 she 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 she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/23/09 A Sworn to anj subscribed before me ?his,;146' da N ember, 2009 A.D. i !• K Notary Public COMMONWEALTH OF PENNSYLVANIA I- Notaral Seal a Sherry L. Kisner, Notary Public City Of Harrisburg, Dauphin County My Commission Expires Nov. 26, 2011 10/30/09 11106/09 Member, Pennsylvania Association of Notaries Writ No. 20074453 CWN Writ Wdb Fargo Dank, National AGeociatlon asyrustes on L,06611 of the molders of Securltzled Asset-Backed Receivables LLC Trust 2004- 601, Mortgage Pass-Through Certificates $erles,2004-D01 Vat Domink:'J. Oliveri Sonya H. OlivedIUWe Sonya Oliveri Atty: Michael T. McKeever All that certain tract of land with the improvements thereon erected situate in lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road, #451 at the comer of properly of John H. Wingert: thence along the lower, North 7 degrees. 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, k., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake;: thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.2t feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the canter of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL. NO. 14-04.0383.862 BUNG KNOWN AS 235 BOBCAT ROAD, CARLISLE FA 17013 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: October 23, October 30 and November 6, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 6 day of November, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 Writ No. 2007-6653 Civil Wells Fargo Bank, National Association as Trustee on Behalf of the Certificateholders of Securitzied Asset-Backed Receivables LLC Trust 2004- D01, Mortgage Pass-Through Certificates Series 2004-DO1 VS. Dominic J. Oliveri, Sonya H. Oliveri a/k/a Sonya Oliveri Atty: Michael T. McKeever All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 de- grees 38 minutes East 133 feet to a stake; thence along property of Rich- ard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383- 062. BEING KNOWN AS 235 BOBCAT ROAD, CARLISLE PA 17013. CiOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 FILE" 17-OFFICE OF' THE PROTHMOTt f'. n 10 NOV 3 WELLS FARGO BANK, NATIONAL Yi?MM ASSOCIATION AS TRUSTEE ON BEHALI pr THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) 57746FC CF: 11/01/2007 SD: 12/08/2010 $96,345.31 IN THE COURT OF COMMON PLEAS AND COUNTY YLVA NJ A of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 07-6653 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Keith C. Halili, an employee of Goldbeck McCafferty & McKeever, counsel for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: P45R Ci 50 ? doi-1vA - (o 1 is /Z,ate) (fie) Personal Service by the Sheriffs Office/c ). ( ) 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 (x) Premises was posted by Sheriffs Office/ ). PM cj- N 4 P-5 o ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). (a6M'0J'c. - 101 is /z 0, C ? 00 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 ssubmritted, BY: Keith C. Halili Legal Secretary ? LL ?o ? U O N 7 A ro _> a L 0 av a m g t" ? C3 m? Cs SA c l4 _°??p NG ? < .? m ? ra" p f4 ? Q`? 05 lla n Ln s Y- ti O CO, a E w 4 w ? j c1 Q Y' IZ o U W _ CC7 m Z? °? Z m 7a U .7M Z03 ZO r 'cno m EZ C) u c Q p rr' 03 UU T - W p.? 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CL U c) O N } co z o CV 0 12 ca ? 0 a? oC -ca LU J 0 p O 7 cri U Z ro N co Q L 06 VN Q) 3 > U J w O M V U € w z 0 a cn a WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. DOMINIC J. OLIVERI and SONYA H. OLIVERI a/ J- a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17013 IN THE COURT OF. COMMON PLEAS OF CUMBERLAND COUNTY 07-6653 ORDER ,6e4K , 2007, upon AND NOW, this day ofC consideration of Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a), and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of defendant; Dommicl Oliveri, have been unsuccessful, it is hereby ORDERED and DECREED that Plaintiff's Motion is Granted, and the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage Foreclosure upon defendant, Dominic J. Oliveri, by (i) posting a copy of the Complaint upon the mortgaged premises, 235 Bobcat Road, Carlisle, PA, 17013, and (ii) publication in Cumberland County, Pennsylvania pursuant to Pa. R.C.P. No. 430(b)(1); and, it is further ORDERED and DECREED that all future documents normally required to be personal served upon defendant, Dominic J. Oliveri, shall instead be served in the manner listed above. B E CO The Honorable Edward E. Guido Distribution list: David Fein, Esquire, Suite 5000, 701 Market Street, Philadelphia,. PA 19106-1532 Dominic J. Oliveri, 235 Bobcat Road Carlisle, PA 17015 ` Sonya H. Oliveri a/k/a Sonya Oliveri, 235 Bobcat Road Carlisle, PA 170.15 Pc ID 91 Addressee Name Postage ES ES Insured Due Total Article # Delivery Address Type Fee Value Sender Charge 57746DO12-8 OLIVER], DOMINIC J. 0.440 C 02.800 0.00 4.340 9171082133393867623523 906 Indian Mound Road ERR 01.100 Indian Mound, TN 37079 57746DOt2-8.2 OLIVERI, DOMINIC J. 0.440 C 02.800 0.00 4.340 9171082133393667623530 235 Bobcat Road ERR 01.100 Carlisle, PA 17015 57746SO12-8 OLIVERI, SONYA H. a/k/a SONYA 0.440 C 02.800 0.00 4.340 9171082133393867623547 235 Bobcat Road ERR 01.100 Carlisle, PA 17045 57969RF10-8 FISCHER, RAYMOND O. aWa 0.440 C 02.800 0.00 4.340 9171082133393867623660 RAYM ERR 01.100 700 Ferry Street Easton, PA 18042 74161ABB-25 BURKE, ANGELLA A. 0.440 C 02.800 0.00 4.340 9171082133393867623615 2133 Fort Bevon Road ERR 01.100 Harleysville, PA 19438 74161CB8-25 BURKE, CARL B. 0.440 C 02.800 0.00 4.340 9171082133393867623677 3188 Main Street ERR 01.100 Surnneytovm Hotel Green Lane, PA 18054 77061 HE10-5 ENGEL, HERSCHEL 0.440 C 02.800 0.00 4.340 9171082133393867623622 6 Premistiran Way, Unit 102 ERR 01.100 Monroe, NY 16950 77061 HE 10-5.2 ENGEL, HERSCHEL 0.440 C n2.800 0.00 4.340 9171082133393867623639 515 Alder Street ERR 01.100 Scranton, PA 18505 77061HE10-5.3 ENGEL, HERSCHEL 0.440 C 02.800 V 0.00 4.340 9171082133393867623646 3 Miele Road ERR -11.100 Monsey, NY 10952 77061LE10-5 ENGEL, LIPA 0.440 C 02.800 0.00 4.340 9171082133393867623554 1024 Catpouse Avenue ERR 01.100 Scranton, PA 18509 77061 LE10-5.2 ENGEL, LIPA 0.440 C P2.800 0.00 4.340 9171082133393867623585 515 Alder Street ERR 01.100 Scranton, PA 18505 77061LE10-5.3 ENGEL, LIPA 0.440 C 02.800 0.00 4.340 9171082133393867623592 6 Premishian Way, Unit 102 ERR 01.100 Monroe, NY 10950 77061LE10-5.4 ENGEL, LIPA 0.440 C (]2.800 0.00 4.340 9171082133393867623653 3 Miele Road ERR 01.100 Money, NY 10952 88987AS9-10 SCIUKAS, ANATOLIJUS LA Q?? P 0.440 C 02.800 0.00 4.340 9171082133393867535505 ? 15 Lancaster Road P i ERR 0.1.100 Colonic, NJ 07067 y p ? 88987VS9 10 SCfUKAS, VIOLE T" I . .440 C 02.800 0.00 4.340 9171082133393867623516 15 Lancaster Road ERR 01.100 Colonia, NJ 07067 Page Totals: 15 Ed n 6.600 58.500 65.100 Cum Totals: 26 11.440 101 AW 112.940 i Form 3877 (Facsimile) SendSuite - MAC v6.00.6.01.J GOLDBECK WCAFFERTY & MCKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) Term No. 07-6653 AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 23 5 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVER! 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 3. Name a w W address of every judgment creditor whose judgment is a record lien on the property to be sold: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC CIO Phelan Hallinan & Schmieg, LLP -SUITE 1400 One Penn Center at Suburban Station -1617 John F. Kennedy Boulevard Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL MORTGAGE CO. INC. AKA ASSOCIATES FINANCIAL 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 ASSOCIATES FINANCIAL SERVICES CO. INC. f/k/a FORD CONSUMER DISCOUNT COMPANY 1111 Northpoint Drive, Bldg 4, Ste. 100 Coppell, TX 75019-3931 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 235 Bobcat Road Carlisle, PA 17013 PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 (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 24, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) 140 07-6653 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DOI, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 Plaintiff (s) From DOMINIC J. OLIVERI AND SONYA H. OLIVERI A/K/A SONYA OLIVERI (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 r otify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying my 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: $96,345.31 L.L.: Interest from 1/31/2008 To Date of Sale per diem at $26.94 Atty's Comm: % Due Prothy: 2.25 Atty Paid: $3,572.26 Plaintiff' Paid: Date: 1 '26/12 (Seal) REQUEST NG PARTY: Other Costs: David D. Bu 1, Prothonotary By: Name: KRISTINA MURTHA, ESQUIRE Address KML LAW GROUP, P.C. SUITE 5000- BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Deputy Supreme Court ID No. 61858 t ` PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECL.OSUI?? P.R.C.P 3180-3183 "°? rnw KML Law Group, P.C. c?n?y Suite 5000 - BNY Independence Center 701 Market Street < Philadelphia, PA 19106-1532 =,p 215-627-1322 y* Attornev for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-?632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI aWa SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle. PA 17013 Defendant(s) CM F? N O'N Ei C 11 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW -t ACTION OF MORTGAGE FORECLOSURE No 07-6653 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 1/31/2008 to Date of Sale per diem at $26.94 (Costs to be added) $96,345.31 >3 a& Sa ?d Ck N)• b 4 0(3F I6.CD «(. 4/. ( S' 4 07.). 00 <<v sa &D. 3S «<, a0 uu -7 y? 7 8p?. & S ?O. SO- 4 OpK 1N. 004+ o9 ?/ . 0 C) C-4 By: ' KML L GR U rVa.5 L1. OQMichael M6129 L(. Op <<t Jay E. Kivitz Pa. IDS 9(4. O? a Lisa Lee Pa. ID 78020 Kristine Murtha Pa. ID 61858 3,5 9 QV,4 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Ann E. Swartz Pa. 10 201926 Jill P. Jenkins Pa. ID 306588 a. aS !?w Ce. Attornevs for Plaintiff 6)c 0 -?o S'1(/3 (2-H a -?o 9 SO I Utj 0 r e F J-'?; s(,* d Lv OWa c O PEA U s ? as d UHx p W d c ? W o a OU U, ap??' :a c w m r; c O?N W 1 0 o W '?, as ?, N. N U Z O • a to ? 3?0 ado o..N f All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 1.4 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383-062 BEING KNOWN AS 235 BOBCAT ROAD, CARLISLE PA 17013 Being the same premises which Sonya H. Oliveri and Dominic J. Oliveri, her husband, acting through his attorney in fact Sonya H. Oliveri by deed dated 03/27/07 and recorded 03/28/07 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 279 Page 1544, granted and conveyed unto Sonya H. Oliveri. AW KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff f, j 3 9 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI 7105 Corporate: Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLNERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 07-6653 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DOI. MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DOI, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 PF?LVAWF` IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERJ 235 Bobcat Road Carlisle, PA 17015 r • 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.. ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 49501-2026 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE. SUITE 101 OCALA, FL 34474 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC C/O Phelan Hallman & Schmieg, LLP -SUITE 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 5. Name and addres; 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 addres, 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 235 Bobcat Road Carlisle, PA 17013 PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 I verify that the statements made in this affidavit are true and correct to the best of my 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 falsificat?)q to authorities. DATED: f/z 3l j '?t_ By: --- AWG t1C. -Michael McKeeve Pa 56129 Jay E. Kivitz Pa. 6769 Lisa Lee Pa. ID 78020 X'Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 _Thomas Puleo Pa. ID 27615 _Ann E. Swartz Pa. ID 201926 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 07-6653 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-F25-6318 Attorwy for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSE'i -BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE, PASS THROUGH CERTIFICATES SERIFS 2004-DOI 7105 Corporate Drive PTX B.35 Plano, IN. 75024-3632 i..L4J-'J FFIl., ., ?_ i'ROTHQ OTA" N12 JAH 26 Ali 10'- 39 CL1M6ERLAN0 COUNTi IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) Docket No. 07-6653 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: OLIVERI, DOMINIC J. DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 06, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE. ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 07-6653 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-D01, 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 I-866-413-231 1. 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. 4. 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. 1 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 gwes 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 b:y 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. ?. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: ham://www.philadelphiafed.org/foreclosure/ 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-6653 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: 717-243-9400 or. 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretention@kmllawgroup.com.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 57746FC. Para informacion en espanol puede con rnunicarse con Loretta al 215-825-6344. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITiZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 Plaintiff VS. DOMINIC J. OLIVERI SONYA 14. OLIVERI a/k/a SONYA OLIVERI Defendant(s) NO. 07-6653 F c-_ ? -... M ? ~7 fr . Gp aN -?r T'C7 ? 6 ?C7 4% = p c ?t VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, DOMINIC J. OLIVERI, has a last known residence of 235 Bobcat Road, Carlisle, PA 17015. 3. That inquiry has been made with the Department of Defense as to the military status of each of tree Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date_a? By: KML LAW GROUP, .C. Michael McKeeve . ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Ann E. Swartz Pa. ID 201926 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Request for Military Status Department of Defense Manpower Data Center 46 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jan-23-2012 07:00:31 -11 Last Service Name First/Middle Begin Date Active Duty Status Active Duty End Date Agency DOMINIC Based on the information you have furnished, the DMDC does not possess OLIVERI J. any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). W6* In- )10044206j- 4??_ A 14 - Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defense] ink.Irnil" URL http://www.defenselink.mil/faq/Xi.s/PC'09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.i lmdc.osd.miVappj/scra/popreport.do 1/23/2012 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days.. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:E40C5M3499 https://www.,irridc.osd.mil/appj/scra/popreport.do 1/23/2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CE?RTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-1301, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO l Plaintiff vs.. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVER] Defendant(s) NO. 07-6653 C -v n TJ r -?, , cr- Cz 0 2p' C) C) © r c VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, =P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, SONYA H. OLIVERI a/k/a SONYA OLIVERI, has a last known residence of 235 Bobcat Road, Carlisle, PA 17015. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date ?_?' ?? By: - KML LAW OUP, Ac. Michael McKeever P I _ 6129 Lisa Lee Pa. ID 78020 4?Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Ann E. Swartz Pa. ID 201926 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jan-23-2012 07:03:09 Last Nacre First/Middle Begin Date Active Duty Status Active Duty End Date Service S Agency OLIVERI SONYA Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force. NOAA, Public Health, and Coast Guard). III Mary M. Snavely-Dixon, Director Department of :Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/Tis/PC09S],DR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.clrndc.osd.mil/appj/scra/popreport.do 1/23/2012 Request for %I fl itary Status Page 2of2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs.,Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:HDQ4906J I M https://www.(imdc.osd.mil/appj/scra/popreport.do 1/23/2012 Request for N1 i I Itary Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jan-23-2012 07:01:26 Last Service S Name I' irst/Middle Begin Date Active Duty Status Active Duty End Date Agency OLIVERI SONYA H. Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 4124411" Ira Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.inil" URL http://www.defenselink.mil/faq/pis/PC09S1_DR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name). you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.clmdc.osd.mil/appj/scra/popreport.do 1/23/2012 Request for ",A litary Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps AR.s and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps) for a period of mote than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:N9S9BS 1 VBV https://www.d andc.osd.mil/appj/scra/popreport.do 1/23/2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ',AJ' 4BCP,Li-'??%'J C1 l,r s ; , PPMSYLVANIk. Wells Fargo Bank NA Case Number vs. 2007-6653 Dominic J Oliveri (et al.) SHERIFF'S RETURN OF SERVICE 03/20/2012 07:46 PM - Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 235 Bobcat Road, Lower Frankford Township, Carlisle, PA 17013, Cumberland County. 03/20/2012 07:46 P'M - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Dominic J Oliver, pursuant to Order of Court by "Posting" the premises located at 235 Bobcat Road, Lower Frankford Township, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 03/20/2012 07:46 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be valerie keeseman - daughter, who accepted as "Adult Person in Charge" for Sonya H Oliveri at 235 Bobcat Road, Lower Frankford Township, Carlisle, PA 17013, Cumberland County. 04/12/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $122.61 SO ANSWERS, 4rz ? May 25, 2012 RON R ANDERSON, SHERIFF jz ? - KML Law Group, P.C. Suite 5000 -- BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for. Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-D01, MORTGAGE, PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 7.5024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) 235 Bobcat Road Carlisle, PA 17013 No. 07-6653 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEBOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 235 Bobcat Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 1 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ITS SUCCESSORS AND ASSIGNS, AS NOMINEE FOR DEL NORTE REF. LLC, ITS SUCCESSORS AND ASSIGNS P.O. BOX 2026 Flint, MI 48501-2026 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE 350 MCLEAN, VA 22102 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC C/O Phelan Hallman & Schmieg, LLP -SUITE 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 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 235 Bobcat Road Carlisle, PA 17013 PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsificatj.op to authorities. DATED: ?/Z 3) 1 ?X- KAHAAW G , P C. -Michael McKeeve Pa 56129 -Jay E. Kivitz Pa. 6769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 _David Fein Pa. ID 82628 .-Thomas Puleo Pa. ID 27615 _Ann E. Swartz Pa. ID 201926 -Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 07-6653 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFTCATEHOLDERS OF SECURTTIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DOI, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO I 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLTVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) Docket No. 07-6653 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: OLP?ERI, SONYA H. a/k/a SONYA OLIVERI SONYA H. OLIVERI alkla SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 06, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUS'T'EE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 07-6653 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301, 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. 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. 4. 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). 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. 8. You may contact the Foreclosure Resource Center: http://www.12hiladelphiafed.org/foreclosure/ 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-6653 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: 717-243-9400 or. 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www Rhfa ors/consumers/homeowners/real.awx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeretention@kmllawgroup.com.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-6653 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DOL MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-1301 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI &Wa SONYA OLIVERI Mortgagor(s) and Record Owner(s) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) Docket No. 07-6653 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: OLIVERI, DOMINIC J. DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 Your house at 235 Bobcat Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 06, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $96,345.31 obtained by WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 07-6653 1. The sale will be cancelled if you pay to WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-13011, 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. 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. 4. 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). 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. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.or0foreclosure/ 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 07-6653 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: 717-243-9400 or. 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.or2/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). 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 homeKgtention@kmllawgroup.com.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 57746FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain tract of land with the improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a spike in the center of Township Road #451 at the corner of property of John H. Wingert: thence along the lower, North 7 degrees 26 minutes West 250 feet to an iron pin; thence along the same property of Harold D. Lindsey, Jr., North 73 degrees 29 minutes West 544.57 feet to an iron pin; thence along property of Edgar D. Bartels, North 9 degrees 30 minutes East 573 feet to a stake; thence along the same, North 14 degrees 38 minutes East 133 feet to a stake; thence along property of Richard C. Park, et ux, South 79 degrees 17 minutes 10 seconds East 327.21 feet to a stake; thence still along the same, South 7 degrees 26 minutes East 1,039.16 feet to a spike in the center of the aforesaid road; thence along the latter, South 79 degrees 45 minutes West 30 feet to a spike, the place of beginning. TAX PARCEL NO: 14-04-0383-062 BEING KNOWN AS 235 BOBCAT ROAD, CARLISLE PA 17013 Being the same premises which Sonya H. Oliveri and Dominic J. Oliveri, her husband, acting through his attorney in fact Sonya H. Oliveri by deed dated 03/27/07 and recorded 03/28/07 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 279 Page ] 544, granted and conveyed unto Sonya H. Oliveri. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6653 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET- BACKED RECEIVABLES LLC TRUST 2004-DO1, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 Plaintiff (s) From DOMINIC J. OLIVERI AND SONYA H. OLIVERI A/K/A SONYA OLIVERI (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: $96,345.31 L.L.: Interest from 1/31/2008 To Date of Sale per diem at $26.94 Atty's Comm: % Due Prothy: 2.25 Atty Paidl: $3,572.26 Plaintiff Paid: Date: 1/26/12 (Seal) REQUESTING PARTY: Name: KRISTINA MURTHA, ESQUIRE Address:'KML LAW GROUP, P.C. Other Costs: SUITE 5000- BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 61858 TRUE COPY FROM RECORD In Testimony whereof, l here unto set my hand and the seal of said Court at Csdisle, Pa. .day of, AA^ 20-J2- This _„a (L Protluxiotmy 400 0, Hmao Z p ?r Joleu'pJoo0 alels3le9H 'aajegmaas eipne10 jo3 :A8 ZZOZ 'SZ Aaenue f :aiea •uiaaay pale todao:)u! a:uaialai s!yi Aq pue jpm s141 OM pal!j „d„ I!q!4X3 uo paq!aasap Allnj ajow 'EZOLZ `dd `als!lieD 'peoU jeogo8 SZZ se paaaquunu pue umoul ,V,d Alu o puel.aagwn:) 'd!Wsumol popuea j aamol ?....,.HO;-err-w??d aurla auk u! Isaaaui s,lUepuaap ayl UddiYoa!nal 4094S aql ZtiOZ `LZ Aaenuef uo KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attornev for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DO I, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO 1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record owner(s)) 235 Bobcat Road Carlisle, PA 17013 Defendant(s) COIJ NT? YLIVAt4jA NO Ti? t'!I74 ?3 as a 9: IN THE COURT OF COMMON PLEAS of Cumberland County No. 07-6653 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. By: LAW GROUP, P.C. ?fichael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff a o /17.>?I Vk?-1-71 33 KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DOI, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and 235 Bobcat Road Carlisle, PA 17013 Record owner(s)) Aq 10: VANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 07-6653 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A,GQLDBECK McCAFFERTY & McKEEVER Michael McKeever Pa. ID 56129 ay E. Kivitz Pa. ID 26769 13i sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 _Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff WELLS FARGO BANK, NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF THE CERTIFICATEHOLDERS OF SECURITIZED ASSET-BACKED RECEIVABLES LLC TRUST 2004-DOI, MORTGAGE PASS THROUGH CERTIFICATES SERIES 2004-DO1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff vs. DOMINIC J. OLIVERI SONYA H. OLIVERI a/k/a SONYA OLIVERI (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE Defendant(s) CERTIFICATE OF SERVICE No. 07-6653 Jessica Doebley, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on (p j qI1 J DOMINIC J. OLIVERI 235 Bobcat Road Carlisle, PA 17015 SONYA H. OLIVERI a/k/a SONYA OLIVERI 235 Bobcat Road Carlisle, PA 17015 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: J ssica Doebley, Legal Assistant idoebley@kmllawgroup.com 215-825-6327 (Direct Phone)