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HomeMy WebLinkAbout08-1019SHAPIRO & KREISMAN, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 LAUREN R. TABAS, ESQ., ATTORNEY I.D. NO. 93337 ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: dg- ID19 Civil VS. Amos L. Keefer, Jr. P.O. Box 554 Selbyville, DE 19975 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 DEFENDANT(S) COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE 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 THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & KREISMAN, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 LAUREN R. TABAS, ESQ., ATTORNEY I.D. NO. 93337 ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: OF - 16 / 9 C" 7-t, Amos L. Keefer, Jr. P.O. Box 554 Selbyville, DE 19975 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 DEFENDANT(S) COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1, the address of which is, 12650 Ingenuity Drive Orlando, Florida 32826, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: The Cit Group/Consumer Finance, Inc. Mortgagor s): Amos L Keefer Jr. and Carol A Keefer (b) Date of Mortgage: October 17, 2001 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1738 Page 2193 Date: November 8, 2001 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assi ents: Assignor: The Cit Group/Consumer Finances, Inc. Assignee: Bank One NA as Trustee of The Amortizing Residential Collateral Trust 2002-BC 1 Date of Assignment: December 7, 2001 Recording Date: November 22, 2002 Book: 692 Page: 46 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 69 Cherry Grove Road, Shippensburg, Pa 17257 and is more specifically described as attached as part of Exhibit "A": 4. Each Mortgagor named in paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Note"). A true and correct copy of the Note is attached and marked as Exhibit "B." 5. The name and mailing address of each Defendant is: Amos L. Keefer, Jr., P.O. Box 554 Selbyville, DE 19975; Carol A. Keefer, 69 Cherry Grove Road, Shippensburg, PA 17257 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of January 22, 2006 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of February 7, 2008: Principal of Mortgage debt due and unpaid Interest currently due and owing at 9.75% per annum calculated from December 22, 2005 at $35.03 each day Late Charge of $50.00 per month assessed on the 16th of each month from February 6, 2006 to February 7, 2008, (25 Months) Escrow Advances made by Plaintiff Suspense/Unapplied Balance Accrued Late Charges Appraisal Fees Prior Foreclosure Fees Property Inspection Prior Bankruptcy Fees Title Search/Report Fees Attorneys' Fees and Costs TOTAL. $131,124.61 $27,253.34 $1,250.00 $1,408.24 ($865.34) $200.00 $881.37 $6,372.86 $73.50 $3,750.00 $250.00 $5,000.00 $176,698.58 9. Interest accrues at a per diem rate of 35.03 each day after February 7, 2008, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 10. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seMC ., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "C". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & KREISMAN, LLC Date: '?DI ?, kr"? S & K File No. 07-31048 BY: Attorneys for Plai ff NOV-09-2007(FRI) 12:42 Patricia Black Abstracting (FAX)717 337 2248 •rne uvr Group 10117/01 10:19 PAGE 10148 The GI7' 0roup s,? 3733 ROBERT r, 71EOL£.R RECORA; ? ?p DIEDS ?UQERLAHC COUNTY-PA '01 NOV 8 Pn it to REAL PROPERTY MORTGAGE -- - ( NAM ' AND ADDtit N ES OF At1 NORM, AMOS L ]FEEL JR CAROL A HEEFEA Mailing Addrow69CHERRY GROVE RD 5HWPENSWJR% PA 17257 LOAN NUMBER DATE MQtrTOAO? THE C1T CROUP/GONSUMERMANM BIC. X000 SAGEMORE DR SUITE X200 MARLTON, x; 08M Om Final Payment Coo PRINUPAL BAL.11 THE WORM "4# 'AM AND •MY' RMFM TO AI.L NORTGAGORS Oid THE NOTE SECDRBD BY THISMORTGAGI:THEWORM wYotrAND"YOUR'REFt:RTdMORTGAGx& MORTGAGE OF REAL ESTATE - To secom piymmi of a m& whieA I eilaed Wt.7 pma"hS to pq YO, 'be abovc PetndVW Babmoc tom with hrtetrat &at*a at the inteoeet rate sad In the mower set forth in the Notc soeursd by thie MaripSe (the 'Note'). cacti of the tmdetrdXncd gm&% batlamr, a,Ik aileaattte6 eafedt% r?eI- sad Omfirms to yea bo nd estate dce AWd bttoa and PA prewar gad hum *ftwemmta an the Soal eatate, whieh ti loeated ib Pm wNwii ACo tyof WMHEMAM SEE A, Which has the ad&CM of 69 gamy GROVE BD SHQ'PENSBURG Ptiiwayivapla 17237 (stare (ah) (1helprcmbes-I zip case TERMS AND CONDITIONS: PAYMENT 01e OBLIGATIONS - If Ipay the Now z<;to jtx tamr. WW as otims == v=rW by this MottlagA, dhw *10 b[agpp WILL be mX amid void. TA71'BF . LIENS . INSORWCt3 . MAWMKM= _ I Wyi PLY. Who they sae doe and payabh, on rocs, llcll?4 , obiila110tis, water Lades and say other ehwrpes+ptmt the Peamises. Whether hrfutor m tbx of of this UW&Mn mdalaln hamd i==-= as the %.d.. m f -_Qe d am0aot eIWAQlot7r t0 you sad -,interim and" dw ft=& a ht Sood repair at all dmdn U the trap et this Mortgage You rosy. atyotx option, pay Anysedr ter, Uek mmommeat. WW don. Water 'hta'Xe CmobWbrlauy farmesh' or WI&%maa¢e)0r pu dum smell boo,,, ig ?, pad= or athcr do oo. 7bc 40=t you p#y M11 be due acrd padabla z ao yOOL °"'a ltI faLL w faeth lv the Mote-=vd by 16i ' , 9e If i dby l:t.erg iftrot. at r% st beat the highhiieieatgi la< lalara .1c ere a4dded to the saw scatted by thin awfd f0linta®ssitle, be ? ?' tmtatned sad eoLeekd la the woe ft man as dte of er ade dws aocl?ed by this M ?The b-see chosen by me mbjad 10 y aDpm. gttbe ? the bwtmae t'dened to above WILL be va4 WMek will not be W0=*d blywtUd& AU hrssc lw pam ad them?wNcloegd aaoeptabietoyw=dmwtbtAodeastandudmatgajedvm,6YaOatrttLLhavetha? P4 fcWwals. W yon ragait% I wig prampW live to you atl r-ckas of paid peem1w= attd reaewsl SEE PAGES 2 AND 3 FOR ADDrMNA,l, udpoRTANT TERM twvpz IQ2r tbhEa 2-3 MARGOtit.-I.MeM.4, . Yags t of 3 8K 1738pG2193 P. 013/019 f"il "A" X109-09-2007(FRI) 12:43 The CIT Group Patricia Black Abstracting (FAX)717 337 2248 P.014/019 10/17/01 io:18 PAGE 11/46 The CIT Group notioem. In iba event of a logo, I will &0 pr'amptnotice to the hOMMaoe emtMkt and yet. Yon nyy, at your option, Me. 9, PM1 of cif not lied Itamptly by men Yon tttaY, At Your option. negadda asdd=m=af arty cijb= as by mn6odse and deeot tech Inmitmm cempW canaaaed to >omlta psymeaa ender much in$=Da, leclu M Premium toftm * dirtcty to You iNUtemd of to me amd You Jointly, Andhmeby h "Onb(y mPPolatyoa my atrc>rn001114 10 OdUm mtY dmft41unfar, and to sign may and mil pm& of dabo, mk.* and all odhcr documemsnelued Zheteto.7osommoe Ptocsads Shall be mppflmd to the to s=tun or UT&k of the propoeW damaged or. at Your optiat4 the 111m mcc ptne»tda shall be VP&A to &C MM mcurad by this Martptte, whetha a not thm dur, wi* SAW CWXW poid tome. CONDE34IIrTATION -1ho proceeds of a w award a claim far damage; direct or eatmm matimL in a>omeetxlou "buy -daoaadoa (the taldmg of mY PmPUly foe apnb8c um) ere' aaha taking of arty, part at the PknWms. at for OOaYEyaace in HO of caad-Wom arc hereby moved andwill be paid to you and are object to tho liem of and scented by this Mmtgege Is the event of teldug of dw Ptmolga4 yam ace amt odmd io eofim mud apply Qtr Pte , u Your opt. dams to tho restoadaa or repair of the R=dom or to rite m=aocumd by thin Mattfaggwhethesccnotthen due TITLE - 7be Pe®imes amts convoyed to arm: by it dad which 6 m be, at ho barn, mooviod briars this Mortgage, =4 1 wattaat the title to the Frrstlats. I further vaunt that the liar ctoaled by this Nkvpsa is a valid and adc etable rust 11tH, mbaedlaate only to a aimcnts and my iodom of mooed an the tmte of this Mortgage, and that during the entire term of the Noiq such 1im will am beoome saboediuaw to anythig *is& D UE ON SALE OR ALTERATION - Ptcept is those airs nmmcw In which faietal law othcrwimprovidek I will Mr. the 1?raatis it out you wft= yam cell at nanafrr file Ptamisee or alter. remove alt 4=061h the buildings on DEFAULT - 91 dd'amlt is paying guy pat cf the obligation seamadby this b& tgase or if I defmalt In anyother way under the Now a dais bimpgo, asunder my otharlttonpSe an the Pnwjwk ya>, at Ym aPtion a" aft= the dcllvety of arty notices mvimd under hew appSedlo in this Nbr4ne and the lie provided in such naic? mar deaimt:e the endto oM vkdm seomod aY this MortgW due e without further demand mad fa v doss an trls Maetftmgts. I agree to pry a ream ma& anoum's lee p1m can comes F as If moncp is kit ova after You foteelom on this Mortgmea itwM bm paid to, the polo us laptly codtkd to it but If any money Is Stiff owtag,.I agtoo m pay you dw balm= APPOIN[fjr MM OF RECSPP,SR AND ASSERGWENT OF RENTS - I epee that you we tadsW to the appoinaucat of a Molver to may Wdon to faeolow an thin Moaipp mad You met also as the Preatlmes and take pow-don of dray rrat them if the Pavmisea mta not abcady trtutod, receive all rants and ap* 6y to the obligations x=rAbY rids Hangar- I mip mA gents to you but you agree dwI tiny continue: to a&= the nmht valesm I = iaMani ttmder this t4foetgmpt or the Noe. RIGM CIMULAMS - Your riAts enter this Maetpge will be aeparatc, disliactamd oumnlative and none of them wI1i be In aiclasian of anY other nor will Huy act of yam be amsidaad as an eleetioo to proceed under any one panizioa of this MorWgo to due aadudon of may odurpeovisim. Er"NSIONS AND MOODWATION - PA& of the persons agamg t4ls make n of time at o*- razLtticm of any obligation m mod by rids Mattpgo will afY mny gdtat ? ibm d o crwWo ei MWPSQ obfiamtlcros > this noti anotha method d OC&MY i ds l1 cvtuce and demand may Fvsb to men at the Mmlllsg Adeheas by . ssless RUXASI . Upms tnt u ut at all mm aecaodby ibis UmSag4you mall t d mm As Ptceolses from the am of dill mt. 1 shall pay mca8inse*mm thecu=Pest Atmdby aMEas c law APPLI A 1LisMaetpphsornaadbyappliablepd"*?andpodudlsw. Paoli of the prima aip@ns this Moupp adlmow%dgm ape of a C=ggc ed and sigmed cola of dais Mcuphga BUMI iG 1 - Thb Mattgmge is bmdtag on =4 Wam+to toeh yon modmy arocoemsoes amdasdinm AAMJ e819 R SM PAGES I AND 3 POR ADormm L Dmo RTANT TRnm 1047,91 1077 14Wdm 7-31739 >'mgcgof3 SK 1738PG2194 NOV-09-2007(FRI) 12:43 Patricia Black Abstracting (FAX)717 337 2248 P.015/019 . •.. ..a? uzvup 10/17/01 10;19 PAGE 12/48 The CIT droup WANM OF JURY TRIAL - bxk of the pmx" dping this MatMz waivca W al by.luty in any dkote otising pum= to this Mart avvt the Nola. SEE PAGES I AND 2 FOR ADDI1'IpNAL 1WORTANT TIO MS In With- Whcaoof, Mtutsab'arta)b=mlo aab wflxd hcmhdr)naarc(s) r- Qtr-datefi=abovewrt{Itee. tA Z ?A CO WO TH OF PEI?NSYI.V COUNTY OF r On WS, the 1- _, -1 1 day of C kj,??%- befate tna t . the nndet aigncdaetaty, 1X and l ?' Ppdsat(t tvttoao) natneta) (stn) totiecdbcd to dte above m ue&F= s d ey) tmamted &a awe for the purpo =ihetein oomaiaed InwimessWhccea?Ihetcaubaetaty=d.' p - g?N GIMyF11p1Ip My Commimtan mains '-"?!?""'?bWatt >I.2o? ee=t:eae?orz?a.•.,..?a MaMgaEee hereby cetdfl dw its nddCesa is SM SAGBKQiZIC DR, SUM 9242 .• ,. .,adoti>riani?l7nit aL,.t. 4,6 ?vrr.r.,.rws+r.ex..r„ 1 Certify this to be recorded In Of Deeds In and far told Cwag. em In Mdtgage Book Paga ?r Q Of sa14o6ae the dry audyea akren d, 13M Crr OMMYCONSUMmN41 C$ A; owszo: PQ Boxe% ma 1t" Ny' "8g49a 1-117W rigs 3 of s oD ! 738PG219.5 NOV-09-2007(FRI) 12:43 Patricia Black Abstracting (FRX)717 337 2248 P.016/019 Conestoga TIO Insurance Company Commitment Number: 2001080092" SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment Is described as follows ALL the following described real estate lying and being situate In Southampton Township, Cumberland County Pennsylvania, bounded and described as follows: BEGINNING at a railroad spke set in the QW9110ne Of puW0 toad known and des?'gnated as Township Route 302 (Charrtyy Gme Road), thence akun9 the center@ne of Township Route 302, North 28 ?grtrss 37 mtrtutes 45 secrn dis Wt 150.00 feet to a railroad spike set in the center Rne of Tow nsW, Route 302 at common comer of Lot 3 and 2; thence along common boundary IIna of Lop 3 and 2, North 61 degrees 53 Mutes 43 seconds East 323.47 feet to an iron pin set in Ina Of ?attd now or formerlrryy of James HM, thence along Brie of land now or tawny of Jaynes Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an Iron pin ttrt In line of other lands now or formerly of John Thrush; thence along line of lands now or Formerly of John Trush, South 08 deg:%17 12 minutes 52 seconds East 82,85 feet to an iron pin thence lltrottgh lands now tx famtedy of John ThrSouth 81 degrees 53 minutes 43 seconds West 325.63 feet th the poirrt and place of series Con1.178 aces, more or less, and tag Lot No. 3 on a certain subdivision plan Brrlnledtthdivlsion for Johm h dated January 2? , 1988 drawn by John R Iassinger. Reylaterod Surveyor, which pier is recorded in Cumberland County, PA flan t3ook pays . Parea1 #39-14-0171-164 ?d?m?mdment C19D10e0Q?,ppp/?p70900971151 8t 1738P62196 The CIT Group 10/17/01 10:19 PAGE 18/48 The CJ" Group r. V PROMISSORY NOTE THIS NOTE CONTAINS A CALL OPTION AMOS L KEEPER JR THE CIT GROUP/CONSUMER FINANCE, INC. CAROL A KEEFER 2000 SAGEMORE DR Mailing SUITE 2202 °enfe" 69 CHERRY GROVE RD MARLTON, NJ 02053 SHIPPENSBURG, PA 17257 LOAN NUMBER DATE YEARLY Dats Fnanoa Charge NUMBER Of DATE FIRST PAYMENT INTEREST Begins To Acaue PAYMENTS AMOUNT OF FIRST AMOUNTOF PAYMENT PAYMENTS This loan is secured by a Mortgage on the real putty located at: 69 CHERRY GROVE RD, SHIPPENSBURG, PA 172379459 "the words "l;" "me," "my," and "us" refer to all Borrowers signing this Note. The words "you" and "your" refer the holder of the Note. 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay the Principal Balance stated above to your order. I understand that the Lender may transfer this Note. 2. INTEREST I will pay interest at the Yearly Interest Rate shown above. Interest will be charged on the unpaid principal beginning on the date shown above in the "Date Finance Charge Begins to Accrue" box and will continue until the Principal Balance has been paid in full even if you have obtained a judgment againstme. For purposes of oomputing interest, interest will be charged on the assumption that each monthly payment is received on the date It is due. 3. PAYMENTS (A) Time and Place of Payments I will pay the principal and Interest by making payments every mouth. I will make my monthly payments on the same day of each month beginning on the date shown above in the "Date First Payment Due" box. I will make these payments every month until I have paid all of the Principal Balance and interest and any other charges described below that I may owe under this Note. If on the "Date Final Payment Due" shown above, I still owe amounts under this Note, l will pay those amounts in full on that date, which is called the "maturity date." I will make my monthly payments at the address shown above under your name or at a different place if requited by you. (B) Amount of My Monthly Payments Each of my monthly payments will be in the amount shown above in the "Amount of Other Payments" box except my first payment will be in the amount shown above in the "Amount of First Payment" box. (C) Len tiler's Call Option You and 1 agree tha; notwithstandingwhat sections 3(A) and 3(B) states, you shall have the option to require that I pay in full all of the amounts owed under this Note on the IS tb anniversary date of this Note (the "near maturity date"). This is called a"Call Option." If you decide to exercise thisCall on, you must give me notice of such decislon at leastaiaety (90) days, but not more than one hundred twenty (120) days (unless another time period b regtdtedby lawl before the new maturity date. This 30-day time period is the"Call Period." If you exeeelseyour Call Option, l will pay you the full amount owed on or before the new maturity date. If I fail p, y the amount owed when it is due, you may invoke any remedies permitted by this Note or the Deed of Trust for failing tgpay as to4uop I understand that if you exercise your Call Option, the amount due will be substantially greater than the amount of my regular monthly payment I will have to pay the amount due out of other assets which I may own, or I will have to obtain a new loan from a lender. Iunderstand thatyou are not obligated to refinance the loan. If you do notnotify the during this Call Period thatyou have decided to exercise this Call Option, then you lose your tight to do so. 4. MY FAILURE TO PAY AS REQUIRED (A) Late Charge If a payment is moue than 15 days late, I will be charged a late charge equal to 5% of the unpaid amount of the payment or $50, whichever is less. (B) Default I will be in default if: (1) I do not pay the full amount of any monthly payment on lime; (2) I default under the Mortgage as defined in Section 10 which secures this Note or under any other mortgage on the real property subject to the Mortgage; SEE PAGE 2 FOR ADDITIONAL IMPORTANT TERMS n NESS: 1 I bereby acknowledge receipt of s completed and signed copy of this Note. 141 7M 10.27 1109168 TRUE COPY -NOTAN 2•zn8a(41011 taenuyhnialleovaSK000(Pkp?re+enMa ry)auL. , E*141i ?l1il-vl (Borrow-) (Date) (Borrower) (Date) (Borrower) ate 0 11 The CIT Group 10/17/01 10:19 PAGE 19/48 The CJ'" Group r. %WO (4) 1 violate or fail to abide by any tam or condition of this Note a any other agreemaat I have with you; (5) 1 have made any statement or representation to you in connection with this loan which is false or incorrect; (6) I begin (or if someone else begins againstme) a can in bankruptcy, receivership, reorganization, rehabilitation, insolvency or any other matter whether or not similar to them; or if a receiver, sequesttator. liquidator, trustee, guardian, conservator or other judicial representative is appointed fa me or any of my property; or (7) my property becomes subject to a proceeding in eminent domain or other similar governmental action. If] am in default, you may require me to pay the full unpaid principal balance plus accrued and unpaid interest and any other amounts I then owe to you under this loan, after the delivery of, and the expiration of any time period provided in, any notice required by law and applicable to this loan. (C) Check Collection Charge If I make a payment by check, negotiable order of withdrawal, share draft or other negotiable instrument and that instrument is returned or dishonored for say reason, I will pay you a check collection charge. The amount of the charge will be any amount passed on to you by any financial institution in connection with such instrument not to exceed $20. (D) Payment of Note Holder's Costs and Expetim If I default and you require me to pay in full as described above, I promise to pay all reasonable costs and expenses you actually incur in foreclosing on any Mortgage or collecting this loan, including your reasonable onside attorney's fees. 5. MY RIGHT TO MAKE PREPAYMENTWREPAYMENT PENALTY - I have the right to make payments of principal before they are due. Any payment made before it is due is ]mown as a "ptepaymenV A prepayment of only part of the unpaid principal is known as a "partial prepayment." If I make a partial prepayment, there will be no changes in the amount of my monthly payments unless you agree to those changes. Except as provided below, I may make a full or partial prepayment at any time without penalty. If] prepay during the first three years of this loan, you may charge me a prepayment penalty in an amount equal to 5% of the amount prepaid if the prepayment occurs during the first year, 4% of the amount prepaid if the prepayment occurs during the second year, and 3 % of the amount prepaid if the prepayment occurs dining the third year. I will not be charged a prepayment penalty if I refinance the loan with you. You earn any prepaid Finance Charge at the time the loan is made and no part of it will be refunded if I pay in full ahead of schedule. (07) 6. PROPERTY INSURANCE - Property insurance is required to be maintained by me to protect you against lass of or damage to the real estate covered by the Mortgage discarsscd in Section 10 below for the entire tern of this loan. I may choose the person reasonably satisfactory to you through whom such insurance is to be obtained or may utilize existing coverage, but must obtain insurance against such risks and casualty and in such amounts of coverage as you require, with loss payable clause(s) satisfactory to you. 7. MY WAIVERS - I waive my rights to require you to do certain things. Those things are: (A) to demand payment of amounts due (known as "presentment"); (B) to give notice that amounts due have not been paid (known as "notice of dishonor"} (C) to obtain an official certification of nonpayment (known as a "protest"). Anyone else (i) who agrees to keep the promises made in this Note, or (ii) who agrees to make payments to you if I fail to keep my promises under this Note, or (iii) who signs this Note to transfer it to someone else (known as "gustsatorx, sureties, and endorsers"), also waives these rights. & CHANGESIDELAY IN ENFORCEMENT - No change or cancellation of this Note shall be effective unless the change or cancellation is in writing and has been signed by you and me. You can delay enforcing, or fail to enforce, any or all of your remedies under this Note without losing those or other remedies or tights. 9. GIVING OF NOTICES - Any notice that must be given to me under this Note will be given by delivering it or by mailing it addressed to me at the Mailing Address above except if applicable law requires some other method of delivery. A notice will be delivered to me at a different address if I give you a notice of my different address Any notice that trust be given to you under this Note will be given by mailing it to you at the address stated above, except if applicable law requires another method of delivery. A notice will be mailed to you at a different address if I am given a notice of that different address. 10. THIS NOTE COVERED BY A MORTGAGE - A Mortgage of tie sane date containing a description of my real property protects you from possible losses which might result if I do not keep the proatises which I make in this Note. This Note is secured by that Mortgage. That Mortgage describes how and under what conditions I may be required to make immediate payment in full of all amounts that I owe under this Note. I L RESPONSIBILITY OF PERSONS UNDER THIS NOTE - N more than one person signs this Note each of us is fully and personally obligated to pay the full amount awed plus the charges as described in Section 4(D) above and to keep all of the promises trade in this Note. Any guarantor, surety, or endorser of the Note (as described in Section 7 above) is also obligated to do these things. You may enforce your rights under this Note against each of us individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. Any person who takes over my rights or obligations under this Note will have all of my rights and must keep all of my promises made in this Note. Any person who takes over the rights or obligations of a guarantor, surety, or endorser of this Note (as described in Section 7 above) is also obligated to keep all of the promises made in this Note. 12. APPLICATION OF PAYMENTS - Payments will be applied to accrued interest before the unpaid Principal Balance. 13. LOAN CHARGES - If a law, which applies to this loan and which gets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then; (i) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (ii) any mutts already collected from me which exceeded permitted limits will be refunded to use. You may choose to make this refund by reducing the principal I owe under this Note cc by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 14. APPLICABLE LAW - This loan is made pursuant to the Alternative Mortgage Transactions Padty Act of 1982 and applicable g hail Otherwise, to the extent not preempted by such Act and regulations it Is specifically agreed that this loan is governed by applicable Pennsylvania law as well as all other applicable federal Iaws sad regulations In the event of a conflict between any provision of this Note and any Federal or Penmsylvatnia statute, law or regulation in effect as of die date of this Note, the statute, law or regulation will control to the extent of such conflict and the provision contained in this Note will be without effect. All other provisions of this Note will remain fully effective and enforceable. SEE PAGE 1 FOR ADDITIONAL IMPORTANT TERMS AM?rEEFBN "W ,W 10.27 1109169 2-2rreB Date: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 7007 2560 0000 3784 7923 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 pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. E"C' HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: LAW FIRM FILE NO.: Amos L. Keefer, Jr. and Carol A. Keefer 69 Cherry Grove Road, Shippensburg, PA 17257 30972491 The Cit Group/Consumer Finance, Inc. Ocwen Loan Servicing, LLC 07-31048 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) 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 teleRhone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. 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 have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after 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 Eme enc Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 69 Cherry Grove Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: January 22, 2006 to December 22, 2007 @ $1,160.93 = $27.862.32 Other charges (explain/itemize): Late Charges: February 6, 2006 to December 7, 2007 @ _ $50.00 $1,150.00 Pre-Default Late Charges: _ $200.00 Suspense Credit to Borrower: ($865.34) Appraisal Fees: $881.37 Inspection Fees: Prior Foreclosure Fee Prior Foreclosure Cost Prior Bankruptcy Attorney Fee Prior Bankruptcy Cost $73.50 $1,277.86 $5,095.00 $3,150.00 $600.00 TOTAL AMOUNT PAST DUE: _ $39,424.71 B. 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 $39,424.71, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Ocwen Loan Servicing, LLC Cashiering Department 12650 Ingenuity Drive Orlando, FL 32826 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise 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 creditor 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 (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by _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 mortgaged 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. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro and Kreisman Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number: (610) 278-9980 Contact person: Rana Zion, Esquire 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 X may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Acorn Housing 14 S. 13th Street Harrisburg, PA 17104 717.213.0150 Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Date: 1 1 `t t Amos L. Keefer, Jr. 560 0009 3784 7947 69 Cherry Grove Road 7p?? Shippensburg, PA 17257 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 pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Amos L. Keefer, Jr. and Carol A. Keefer PROPERTY ADDRESS: 69 Cherry Grove Road, Shippensburg, PA 17257 LOAN ACCT. NO.: 30972491 ORIGINAL LENDER: The Cit Group/Consumer Finance, Inc. CURRENT LENDER/SERVICER: Ocwen Loan Servicing, LLC LAW FIRM FILE NO.: 07-31048 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) 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 telenhone numbers of designated consumer credit counseling agencies for the countv in which the Dronertv 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 have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after 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.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 69 Cherry Grove Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: January 22, 2006 to December 22, 2007 @ $1,160.93 = $27,862.32 Other charges (explain/itemize): Late Charges: February 6, 2006 to December 7, 2007 @ _ $50.00 $1,150.00 Pre-Default Late Charges: _ $200.00 Suspense Credit to Borrower: ($865.34) Appraisal Fees: $881.37 Inspection Fees: Prior Foreclosure Fee Prior Foreclosure Cost Prior Bankruptcy Attorney Fee Prior Bankruptcy Cost $73.50 $1,277.86 $5,095.00 $3,150.00 $600.00 TOTAL AMOUNT PAST DUE: = $39,424.71 B. 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 $39,424.71, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check, certified check or money order made payable and sent to: Ocwen Loan Servicing, LLC Cashiering Department 12650 Ingenuity Drive Orlando, FL 32826 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise 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 creditor 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 (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by 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 mortgaged 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. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro and Kreisman Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number: (610) 278-9980 Contact person: Ilana Zion, Esquire EFFECT OF SHERIFF'S SALE- You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the 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 X may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Acorn Housing 14 S. 13th Street Harrisburg, PA 17104 717.213.0150 Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Date: V I I Amos L. Keefer, Jr. 7007 2560 0000 3784 7954 P.O. Box 554 Selbyville, DE 19975-0554 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 pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "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): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER LAW FIRM FILE NO.: Amos L. Keefer, Jr. and Carol A. Keefer 69 Cherry Grove Road, Shippensburg, PA 17257 30972491 The Cit Group/Consumer Finance, Inc. Ocwen Loan Servicing, LLC 07-31048 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) 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 counselinp, 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 have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after 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. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 69 Cherry Grove Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: January 22, 2006 to December 22, 2007 @ $1,160.93 = $27,862.32 Other charges (explain/itemize): Late Charges: February 6, 2006 to December 7, 2007 @ _ $50.00 $1,150.00 Pre-Default Late Charges: _ $200.00 Suspense Credit to Borrower: ($865.34) Appraisal Fees: $881.37 Inspection Fees: $73.50 Prior Foreclosure Fee $1,277.86 Prior Foreclosure Cost $5,095.00 Prior Bankruptcy Attorney Fee $3,150.00 Prior Bankruptcy Cost $600.00 TOTAL AMOUNT PAST DUE: _ $39,424.71 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not Lapplicable): 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 $39,424.71, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Ocwen Loan Servicing, LLC Cashiering Department 12650 Ingenuity Drive Orlando, FL 32826 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise 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 creditor 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 (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by 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 mortgaged 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. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro and Kreisman Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number: (610) 278-9980 Contact person: Ilana Zion, Esquire 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 X may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Acorn Housing 14 S. 13th Street Harrisburg, PA 17104 717.213.0150 Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Date: _ 7007 2560 0000 3784 7930 Carol A. Keefer P.O. Box 554 Selbyville, DE 19975-0554 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 pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. rI HOMEOWNER'S NAME(S): Amos L. Keefer, Jr. and Carol A. Keefer PROPERTY ADDRESS: 69 Cherry Grove Road, Shippensburg, PA 17257 LOAN ACCT. NO.: 30972491 ORIGINAL LENDER: The Cit Group/Consumer Finance, Inc. CURRENT LENDER/SERVICER: Ocwen Loan Servicing, LLC LAW FIRM FILE NO.: 07-31048 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) 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 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 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 have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after 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 Eme enc Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 69 Cherry Grove Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: January 22, 2006 to December 22, 2007 @ $1,160.93 = $27,862.32 Other charges (explain/itemize): Late Charges: February 6, 2006 $50.00 Pre-Default Late Charges: Suspense Credit to Borrower: Appraisal Fees: to December 7, 2007 @ $1,150.00 $200.00 ($865.34) $881.37 Inspection Fees: $73.50 Prior Foreclosure Fee $1,277.86 Prior Foreclosure Cost $5,095.00 Prior Bankruptcy Attorney Fee $3,150.00 Prior Bankruptcy Cost $600.00 TOTAL AMOUNT PAST DUE: _ $39,424.71 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not Uplicable): 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 $39,424.71, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check, certified check or money order made pUable and sent to: Ocwen Loan Servicing, LLC Cashiering Department 12650 Ingenuity Drive Orlando, FL 32826 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise 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 creditor 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 (30) DAY period, you will not be required to pay attorney's fees. }, OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paving the total 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 mortgaged 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. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro and Kreisman Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number: (610) 278-9980 Contact person: Ilana Zion, Esquire 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 X may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. M L YOU 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). u r HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Acorn Housing 14 S. 13th Street Harrisburg, PA 17104 717.213.0150 Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 A'? f4 VERIFICATION Ilana Zion, Esquire hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Verification as the Plaintiff is outside the jurisdiction of the Court and Plaintiff's verification could not be obtained within the time necessary to file this pleading, and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: Ilan ion, Esquire Atto for Plaintiff Dated: Oba1 a- .Q W ?? r v -bq 4 00 r x i F 'a _ :. t CU SHERIFF'S RETURN - REGULAR CASE NO: 2008-01019 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK NA VS KEEFER AMOS L JR 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 KEEFER CAROL A the DEFENDANT , at 1845:00 HOURS, on the 19th day of February-, 2008 at 69 CHERRY GROVE ROAD SHIPPENSBURG, PA 17257 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 18.00 Service 19.20 Affidavit .00 Surcharge 10.00 a/a 510 k q, .00 47.20 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 02/20/2008 SHAPIRO & KREISMAN By: e ut S e ff A.D. a _ --- SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01019 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JPMORGAN CHASE BANK NA VS KEEFER AMOS L JR 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 OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT , OCCUPANT 69 CHERRY GROVE ROAD SHIPPENSBURG, PA 17257 CAROL WAS THE ONLY OCCUPANT. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 2/fig/0 S? 21.00 So answers- R. Thomas Kline Sheriff of Cumberland County SHAPIRO & KREISMAN 00/00/0000 Sworn and Subscribed to before me this day of , A. D. SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I. D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I Ocwen Federal Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) NO:08-1019 CIVIL TERM PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to the Complaint in the above-captioned civil action. Respectfully Submitted, SHAPIRO & KREISMAN B qlana Zion, Esquir luf fl Attorneys for Plai f JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 v. Amos L. Keefer, Jr. and Carol A. Keefer VERIFICATION The undersigned is Foreclosure Facilitator of Ocwen Loan Servicing, LLC on behalf of JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC l and as such is familiar with the records of said corporation, and being authorized to make this verification on behalf of Plaintiff an officer of the corporation and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Ocwen Loan Servicing, LLC on behalf of JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I Date: C__r ame: Anna V. Jim ne -Reyes Title: US Foreclos acilitator Company: JPMo Chase Bank, N.A. Loan: 30972491 07-31048 f`a C= czz ? f G? 7 SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I. D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF vs. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM PRAECIPE FOR REINSTATEMENT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & KREISMAN, LLC BY: Ilana Zion, Esquire Attorney for Plaintiff o C ? o SHERIFF'S RETURN - REGULAR CASE NO: 2008-01019 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK NA VS ;. KEEFER AMOS L JR ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, r. says, the within COMPLAINT - MORT FORE was served upon KEEFER AMOS L JR the DEFENDANT at 1918:00 HOURS, on the 8th day of April 2008 at 69 CHERRY GROVE ROAD SHIPPENSBURG, PA 17257 by handing to CAROL KEEFER, WIFE ADULT IN CHARGE 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 18.00 Service 20.00 Affidavit .00 Surcharge 10.00 )OF 00 48.00 Sworn and Subscibed to -=-"' before me this day of _ So Answers: r R. Thomas Kline 04/10/2008 SHAPIRO & KREISMAN By: Deputy Sheriff A. D. ?'/- 3 /v /f -4 PROVEST, LLC SHAPIRO AND KREISMAN, LLC (PA) P.O. Box 1180 3600 HORIZON DRIVE, SUITE 150 Bay Shore, New York 11706 KING OF PRUSSIA, PA 19406 (631) 666-6168 IN THE COURT OF COMMON PLEAS OF CUMBERLAND CIVIL ACTION- LAW COURT CASE NO.: 08-1019 JPMORGAN CHASE BANK, N.A., AS TRUSTEE SUCCESSOR IN INTEREST TO BANK ONE, N.A., AS TRUSTEE OF THE STRUCTURED ASSET SECURITIES CORPORATION, AMORTIZING RESIDENTIAL COLLATERAL TRUST, 2002- BC1, Plaintiff, Against AFFIDAVIT OF NON-SERVICE AMOS L. KEEFER, JR., CAROL A. KEEFER, ET AL Defendants, STATE OF MARYLAND COUNTY OF WORCESTER lex ill e-If SJ??'V 6 G1'6'?4eing duly sxN orn. deposes and saes that deponent is not a party to this action. is over 18 years of age and resides in the State of MD. A- 11c-,t 1f S n, .Q e e f'3 L'A Gh S ,",a 4 7` s en '4s A- .7 #,A 72 /54.A%r 13,4 "? .C'L 141-0 ti, X'c A-1 y u. h, / .r ,r 6 SWORN TO BEFORE M] ? ?_:oj /68 LICE S FILE # 7-31048 CASE ID # /cps s. ?y? OJ ?. NOTARY PUBIC That on 3?? f Od' at /IJ I went to the address at 11225 SAINT MARTINS PKWY, BERLIN, MD 21811. , ?'yi_00 'Oe o.?/ /?--;p ,- ? ? '. , ? i? a"4'1 ?..,.? 6`? 1'._ '"mow i _ oFr i::,y. ? k i ?.? 't °`t C/? .? -_. fib..„' SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, SHAPIRO & DENARDO, LLC, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, upon Amos L. Keefer, Jr, by regular mail and certified mail to the last known addresses of Amos L. Keefer, Jr., which are 69 Cherry Grove Road, Shippensburg, PA 17257 and 11225 Saint Martins PKWY, Berlin, MD 21811, and by posting of the subject premises located at 69 Cherry Grove Road, Shippensburg, PA 17257, and in support thereof avers the following: 1. The Sheriff has been unable to serve the Complaint in Mortgage Foreclosure. Further attempts at personal service would not be successful. A true and correct copy of the Sheriffs Return of Service is attached hereto and marked as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results there from is attached hereto and marked as Exhibit "B". 3. The last known addresses of the Defendant is as set forth in Exhibits "A" and "B". WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, upon the above named Defendant, Amos L. Keefer, Jr., by regular mail and certified mail to the last known addresses of the Defendant, Amos L. Keefer, Jr., which are 69 Cherry Grove Road, Shippensburg, PA 17257 and 11225 Saint Martins PKWY, Berlin, MD 21811, and by posting of the subject property located at 69 Cherry Grove Road, Shippensburg, PA 17257. SHAPIRO & DENARDO, LLC BY: Ilana Zion, Es e Attorney for P tiff ?n?xi r r ? x.G i vruv - x??uLxn o ;?- 3l? 5??--y1' CASE NO: 2008-01019 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK NA VS KEEFER AMOS L JR ET AL DAVID MCKINNEY .Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon .,n?nnn - rl T Tn the DEFENDANT at 1918:00 HOURS, on the 8th day of April 2008 at 69 CHERRY GROVE ROAD SHIPPENSBURG, PA 17257 by handing to CAROL KEEFER, WIFE ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 f 20.00 00 10.00 R. Thomas Kline .00 48.00 04/10/2008 SHAPIRO & KREISMAN By. day Deputy Sheriff A.D. jj 3 Ot A PROVEST, LLC SHAPIRO AND KREISMAN, LLC (PA) P.O. Box 1180 3600 HORIZON DRIVE, SUITE 150 Bay Shore, New York 11706 KING OF PRUSSIA, PA 19406 (631) 666-6168 IN THE COURT OF COMMON PLEAS OF CUMBERLAND CIVIL ACTION- LAW COURT CASE NO.: 08-1019 JPMORGAN CHASE BANK, N.A., AS TRUSTEE SUCCESSOR IN INTEREST TO BANK ONE, N.A., AS TRUSTEE OF THE STRUCTURED ASSET SECURITIES CORPORATION, AMORTIZING RESIDENTIAL COLLATERAL TRUST, 2002- BC 1, Plaintiff, Against AFFIDAVIT r=?, OF NON-SERVICE a? f ---t AMOS L. KEEFER, JR., CAROL A. KEEFER, ET AL Defendants, STATE OF MARYLAND COUNTY OF WORCESTER ?/`!iG/?' Sy?AI G 4-A74eing duly sworn, deposes and says that deponent is not a party tit actia . is 18 years of age and resides in the State of MD. p L,,: « That on at k 1d 1 went to the address at 11225 SAINT MARTINS PKWY, BERLIN MD 21811. f - w n? ?a L f ryi 'P'r o w 3) z- L/ f 12 ll+X s .a .? ?'?.a ?- h?:,?-:f ?,?i T-•s?,c-.t 70 12 Lc (iL gi c& /V v tx- l? z r r i 6 SWORN TO BEFORE ME ON ?3 FILE 3;7-31048 LIC 90 441 CASE ID # / 5s. NOTARY PUBLIC [?efe?lt Ex??re?s Services, letc. 3103 I.Wibcott Dr. Sidto 320 4yj Fliarte: 85G-"5-3a40 Fax: 855-985-3312 irtfa:gt?clef.?uhe xtr?ess_ cartii File # Client File # Firm Subject: Current Address Property Address Mailing Address: 4778 07-31048 Shapiro & Kreisman Amos L. Keefer, Jr. 11225 Saint Martins Pkwy Berlin, MD 21811 59 Cherry Grove Rd. Shippensburg, PA 17257 11225 Saint Martins Pkwy Berlin, MD 21811 I Steven M. Ruffo,being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above noted individual(s) 3/19/08 and have discovered the following I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following to be true and correct Amos L. Keefer, Jr. - xxx-xx-xxxx B. EMPLOYMENT SEARCH Amos L. Keefer, Jr. - Our Office was unable to verify the employment information on the credit report. C. INQUIRY OF CREDITORS On 3/19/08 our inquiry with the creditors indicate that Amos L. Keefer, Jr. reside (s) at 11225 Saint Martins Pkwy Berlin, MD 21811 II. INQUIRY OF TELEPHONE COMPANY A.DIRECTORY ASSISTANCE SEARCH On 3/19/08 our inquiry with the Directory Assistance indicated that Amos L. Keefer, Jr. reside(s) at 11225 Saint Martins Pkwy Berlin, MD 21811 non published. Our office could not reach the mortgagor due to the non published number. III. INQUIRY OF NEIGHBORS Using our Whitepages database on 3/19/08 we were unable to verify the current address with any of the Neighbors within ten houses of the above referenced subject. IV. INQUIRY OF POSTOFFICE A. NATIONAL ADDRESS UPDATE Our inquiry with National Address database on 3/19/08 indicates the following is correct Amos L. Keefer, Jr. - 11225 Saint Martins Pkwy Berlin, MD 21811 B. ADDITIONAL ACTIVE MAILING ADDRESS Our investigation could not find Another active mailing address V. MOTOR VEHICLE REGISTRATION A. MOTOR VEHICLE & DMV OFFICE Per the Pennsylvania/ Maryland Department of motor vehicle Amos L. Keefer, Jr. has a valid identification registered with the state. h E 1, ".r 113X I- 13 % ?? VI. OTHER INQUIRIES A. DEATH RECORDS As of 3/19/08 Vital records has no death records on file for Amos L. Keefer, Jr. B. PUBLIC LISCENSES (PILOT, REAL ESTATE ETC.) Our investigation could not find Public licenses/ records for the mortgagor C. COUNTY VOTER REGISTRATION The Cumberland Cnty voter registration would only indicate a registration for Amos L. Keefer, Jr. D. INTERNET All accessible public databases have been checked and cross-referenced for the above named individual(s). E. TAX ASSESSMENT OFFICE On 3/19/08 our office conducted a search of the following tax records which showed the following : See Attached VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Amos L. Keefer, Jr. - 7/6/56 B. A.K.A Amos L. Keefer, Jr. - none The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities I hereby verify that the statemants made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to t enalties of 18 Pa. Sec 4904 relating to unsworn falsification to authorities. I ?? ak _ Default Express Services, INC. President Sworn to and subscribed before me this 19th day of Mar 2008 NOTARIAL SEAL Joseph J. Sarocy Notary Public of New Jersey Commission Expires 10/20/2009 lofatift press Services, Inc. 303 L#W%catt Dr. Sv * 320 tvUnlion. NJ 08853 Phone: 856-W-3310 F<ax€:85ti {85.3312 i nf«?a'tiief.? Mite ?€t>? es?s, c r,tn Input Parameters Reference Number Permissible Purpose = ;SI;; Primary Subject = ;;;;;;;;;;;;;;XXXXX7391;;; TRANSUNION SSN REPORT FOR MKT/SUB INFILE DATE TIME SBJ Y NJ0200302 22 SM 4/82 03/19/08 12:44CT RPT ON SSN DOB KEEFER, AMOS L. JR. 7/56 -KEEFER,LEE-KEEFER,AL TEL# CURR/ADD RPTD 208-9555 11225 SAINT MARTINS PY., BERLIN MD. 21811 10/2006 FRMR ADD 37291 LIGHTHOUSE RD., SELBYVILLE DE. 19975 11/2006 69 CHERRY GROVE RD., #T304. SHIPPENSBURG PA. 17257 CURR EMP & ADD PSTN INCM EMPDATE RPTD SUSQUEHANNA SPRINKLER TRUCK DRIVER 6/94R FRMR EMP & ADD HUB CITY SPRINKLERS 5/94R *** INQUIRY ANALYSIS *** NO INQUIRIES WITHIN THE PAST 90 DAYS END OF TRANSUNION REPORT **************************************************************************** 647- 31eyt-q March 17, 2008 Postmaster Selbyville, DE 19975-0554 3600 Horizon Drive, Ste.150 King of Prussia, PA 19406 RUSH Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or name and street address (if a boxholder) for the following: PLEASE PROVIDE A PHYSICAL ADDRESS FOR THS P.O. BOX ADDRESS NAME & ADDRESS: Amos L. Keefer, Jr. ADDRESS: P.O. BOX 554 Selbyville, DE 19975-0554 NOTE: 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 boxholder information, The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee or providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. Capacity of Requester (e.g. process server, attorney, party representing himself): ATTORNEY. 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute(s): N/A 3. The names of all known parties to this litigation: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 vs. Amos L. And Carol Keefer Jr. 4. The court in which the case has been or will be heard: The Court of Common Pleas of CUMBERLAND County 5. The docket or other identifying number if one has been issued: Pending 6. The capacity in which tl-ds individual is to be served (e.g, defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. § 1001 } I certify that the above information is true and that the address information is needed and will be used solely for service of legal process i nnection with actual or prospective litigation. "USH ADDRESS: Shapiro & Kreisman Signature 3600 Horizon Drive, Ste. 150 Kevin Dwyer King Of Prussia, PA 19406 Legal Assistant S&K File Number: 07-31048 FOR PO'ST OFFICE USE ONLY Good As Addressed/No change of address order on file. NEW ADDRESS or BOXHOLDER'S POSTMARK Not known at address given NAME and STREET ADDRESS Moved, left no forwarding address 1 ] a 5 ? t r1'S ?L No such address •co? ? a ti O 3600 Horizon Drive, Ste.150 King of Prussia, PA 19406 November 8, 2007 Postmaster SHIPPENSBURG, PA, 17257 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or name and street address (if a boxholder) for the following: NAME & ADDRESS: ADDRESS: Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 NOTE: 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 boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee or providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. Capacity of Requester (e.g. process server, attorney, party representing himself): ATTORNEY. 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute(s): N/A The names of all known parties to this litigation: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 vs. Amos L. And Carol Keefer Jr. 4. The court in which the case has been or will be heard: The Court of Common Pleas of CUMBERLAND County The docket or other identifying number if one has been issued: Pending The capacity in which this individual is to be served (e.g. defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. § 1001). I certify tha he above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or P P ti i 'g n. ADDRESS: Shapiro & Kreisman Si ae 3600 Horizon Drive, Ste. 150 Jennr 111k an King Of Prussia, PA 19406 Legal Assistant S&K File Number: 07-31048 FOR POST OFFICE USE ONLY Good As Addressed/No change of address order on file. NEW ADDRESS or BOXHOLDER'S POSTMARK. Not known at address given NAME and STREET ADDRESS Moved, left no forwarding address PO 1X .5r- No such address,` Ste, LOG 0 -3'S'Y JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 Vs. Amos L. Keefer, Jr. and Carol A. Keefer VERIFICATION Ilana Zion, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. SHAPIRO & DENARDO, LLC BY: LE? 11 Ilana Zion, Esquire Attorney for Plain*) S & K FILE NO. 07-31048 SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I. D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation, which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. The comment to Pa.R.C.P. 430(a) illustrates what would be a good faith effort to locate the Defendant: NOTE: [A]n illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant, and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. Comment to Pa.R.C.P. 430 (a). In real property actions, such as actions in mortgage foreclosure, the Pennsylvania Rules of Civil Procedure, Rule 410 (c), provides how service shall be made pursuant to an Order of Court under Pa R.C.P. 430 (a): The court shall direct one or more of the following methods of service: (1) publication as provided by Rule 430 (b), (2) posting a copy of the original process on the most public part of the property, (3) registered mail to the defendant's last known addresses, and (4) such other methods, if any, as the court deems appropriate to serve notice to the defendant. As set forth in the Sheriffs Return of Service, attached to the Plaintiffs motion as Exhibit "A", the Sheriff has been unable to serve the Complaint in Mortgage Foreclosure. A good faith effort to discover the whereabouts of the Defendant has been made in accordance with Pennsylvania Rule of Civil Procedure 430(a), as evidenced by the attached Affidavit of Good Faith Investigation, attached to the Plaintiffs motion as Exhibit "B". In order to complete service on the Defendant, Amos L. Keefer, Jr., so as to move this action forward to ultimate disposition, the Plaintiff respectfully requests that this Honorable Court, pursuant to Pennsylvania Rule of Civil Procedure 430, grant a special Order directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on the Defendant, Amos L. Keefer, Jr., by regular mail and certified mail to the last known addresses of the Defendant, Amos L. Keefer, Jr., which are 69 Cherry Grove Road, Shippensburg, PA 17257 and 11225 Saint Martins PKWY, Berlin, MD 21811; and by posting of the subject property located at 69 Cherry Grove Road, Shippensburg, PA 17257 by the Sheriff, competent adult, or other party allowed by law. Respectfully Submitted, SHAPIRO & DENARDO, LLC 1, .1 _ Date: BY: dwa- (?t M Ilana Zion, Esqui Attorney for Plain ' f SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I. D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I PLAINTIFF vs. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM CERTIFICATION I hereby certify that I have served a true and correct copy of this Motion For Service Pursuant to Special Order Of Court and the papers attached thereto on all parties named herein at his last known address or upon his attorney of record by regular mail, postage prepaid to the parties listed below on 2008. Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Amos L. Keefer, Jr. 11225 Saint Martins PKWY Berlin, MD 21811 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 SHAPIRO & DENARDO, LLC i BY: ' liana Zion, Esquir Attorney for Plain ff SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF VS. Amos L. Keefer, Jr. DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM CERTIFICATION OF ADDRESS I, Kevin Dwyer, the undersigned, being duly sworn according to law, hereby depose and say that the addresses of the above Defendant are as follows: Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Amos L. Keefer, Jr. 11225 Saint Martins PKWY Berlin, MD 21811 SHAPIRO & DENARDO, LLC BY: Kevin Dwyer Legal Assistant to Attorney for Plaintiff C-) ^a t t-I ? y1 (Y w? 0 M SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS MAY 0 7 2008 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM ORDER AND NOW, this 13', day of M!!T , 2008 upon consideration of Plaintiffs Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent pleadings by certified mail and regular mail to the last known addresses of the Defendant, Amos L. Keefer, Jr., which are 69 Cherry Grove Road, Shippensburg, PA 17257 and 11225 Saint Martins PKWY, Berlin, MD 21811, and the Sheriff, Marshal or other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of Sale or said subsequent pleading on the most public part of the property located at 69 Cherry Grove Road, Shippensburg, PA 17257, which is the subject of this action in mortgage foreclosure. F [r THE s ? aµ:.S 2008 HAY 13 PH 12: 4 8 's-112108- (2oPy en:a I'LC -?) tTIn R4-? -?T -zibD SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I. D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM PRAECIPE FOR REINSTATEMENT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & DENARDO, LLC BY: %w (1? r(\ ""u, Ilana Zion, Esquire Attorney for Plaintiff 1-0 `?v r SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as ; Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS AFFIDAVIT OF SERVICE I, Tiffany Donnell, the undersigned, being duly sworn according to law, hereby depose and say that on the I (sue day of C ? , 2008, pursuant to the attached Order of Court, attached as Exhibit "A", I served a true and correct copy of the Complaint in Mortgage Foreclosure in the above captioned matter to the Defendant by certified and regular mail, to their last known address of: Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Amos L. Keefer, Jr. 11225 Saint Martins PKWY Berlin, MD 21811 SHAPIRO & DENARDO, LLC SWORN AND SUBSCRIBED Before me this ? day of Od 2 $. Not ublic BY: Tif y Do ell Legal Assistant to Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA Noy;, --ii ?3ea) Jennifer M. % _ar,tey Notary Public Upper Merton Twl;. 4ontgomery County My Commission FYI^ires Oct. 19, 2010 Member, Pennsyivarna Association of Notaries m 0 ; woell uan;aa a 4) anlHaa pa;ala ab m LL 2 m N fiu IpueH upedg Ml LL LL u ;ewJI u03 aJ ;eu6Ig oLL uol.; wal.;uo /I. em d m k m go - 0 o w? Oo c O ck 'O ? ? ANN O> C c> ? ?? s Ll ? ? w V Q 00 ac \ /y a ?o°? 0 da 6 '® gv ? ? N L ( zo N O Q e..?,,,+,.,....... g 0311NC1 O CD z maa a> C F U m =U n y o y a i Em?A maa??aom? } 0 X N m co °i LL Qc.c io°?L? C N N Ol N O U c O C L 9 C (D . O E _ 0 nU m a o U '2 N NEm ? N a7 >, c y m ? ? ?? e U cq a 2 € W ? 0 y y 14 N tF O CO 'm CI ? ? 1?1 ?'? CV OO C,.q O w N U? Z N O N 41 N O Z E ?p > LD y x ?? d OD 00 .0 CL Y ????? Q O (, ?L O N '. N ? m U I'D COO o a 0- E m 729 0 z >_ CO a E _ O .4 ' N O m b .? a z vZA a 00 Q °? o ^V?Nj O a `m M N di cc O?w m.gxr O l? O n ?a Z t?. 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I= V- Street Apt No.-------------- I- orPOBoxNo. 11ZZ 5 i . --------• . . .... r-` r l 0 1) e City, te, Z/P+4 - _ _ - - ,rya m SHERIFF'S RETURN - REGULAR CASE NO: 2008-01019 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK NA VS KEEFER AMOS L JR ET AL MICHAEL BARRICK Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KEEFER AMOS L JR the DEFENDANT , at 0019:01 HOURS, on the 13th day of October , 2008 at 69 CHERRY GROVE ROAD SHIPPENSBURG. PA 17257 POSTED PER COURT ORDER AT 69 Sheriff or Deputy Sheriff of by handing to CHERRY GROVE RD, SHIPPENSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 21.00 Posting 6.00 Surcharge 10.00 lu'16?bP ??., .00 55.00 Sworn and Subscibed to before me this So Answers: r? -04 R. homas Kline 10/14/2008 SHAPIRO & DENARDO By: Deputy heriff day of A.D. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee ; COURT OF COMMON PLEAS successor in interest to Bank One, N.A., as CIVIL DIVISION Trustee of the Structured Asset Securities CUMBERLAND COUNTY Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 NO:08-1019 CIVIL TERM PLAINTIFF ; VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $187,463.09 in favor of the Plaintiff and against the defendant(s), jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid Interest at 9.75% from December 22, 2005 to November 17, 2008 (1,062 days @ $35.03 per diem) Late charges (for certain months prior to default and every month after) Escrow Advance (As stated in Complaint) Suspense/Unapplied Balance Appraisal Fees Property Inspections Prior Foreclosure Fees Prior Bankruptcy Fees Title Search Report Fees Attorneys Fees TOTAL AMOUNT DUE BY: $131,124.61 $37,201.86 $1,350.00 $1,779.73 (-$865.34) $992.37 $147.00 $6,732.86 $3,750.00 $250.00 $5,000.00 $187,463.09 Michael J. Clark, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $187,463.09. 07-31048 othy. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF vs. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:08-1019 CIVIL TERM CERTIFICATE OF SERVICE I, Michael J. Clark, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Amos Keefer Jr. 69 Cherry Grove Rd. Shippensburg PA, 17257 Date mailed: SHAPIRO & DENARDO, BY: I r V V V) Michael J. Clark, Attorney for Plaii SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I. D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, November 4, 2008 to the following Defendants: Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos L. Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Sheena C. Mayer, Legal Assistant to Ilana Zion, Esquire for Shapiro & DeNardo, LLC SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC l PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Amos L. Keefer, Jr. DATE OF NOTICE: November 4, 2008 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMMRTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dial de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos L. Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 UW QUY/A Ilana Zion, Esquire Shapiro & DeNardo, L9 Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Carol A. Keefer DATE OF NOTICE: November 4, 2008 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTMCACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la action debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o flame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos L. Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Ilarna Zion, Esq ire Shapiro & DeN o, LLC Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as ; Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Amos L. Keefer, Jr. DATE OF NOTICE: November 4, 2008 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION E IPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la action debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos L. Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 UAMA j1t&-(M Ilana Zion, Esquir Shapiro &DeNard , C Attorney for Plaintiff ` t 6` ? t7 o -x . ::3r- _ , OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Curtis R. Long Prothonotary TO: Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:08-1019 CIVIL TERM VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in tp oc di indicated below. is R. ng honotary [XX] Judgment by Default [ ] Judgment for Possession N1'aMloB [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: () Confessed Judgment () Other JPMorgan Chase Bank, N.A., as Trustee File No. 68- 1014 Oliva T successor in interest to Bank One, N.A., as Amount Due $187,463.09 Trustee of the Structured Asset Securities Interest December 22, 2005 to March 4 Corporation, Amortizing Residential 2009 is $3,297.31 Collateral Trust, 2002-BC1 Atty's Comm PLAINTIFF ; Costs vs. ' Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: Signature: Print Name: Michael J. Cl k Esquire Address: 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 202929 a -ct LT% -n ..- c MAY 0 7 2008 SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee COURT OF COMMON PLEAS successor in interest to Bank One, N.A., as ; CUMBERLAND COUNTY Trustee of the Structured Asset Securities Corporation,,Amortizing Residential NO: 08-1019 CIVIL TERM Collateral Trust; 2002-BC1 ; PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer ; DEFENDANTS ? ORDER AND NOW, this 0"?day of , 2008 upon consideration of Plaintiffs Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith Investigatibn attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent pleadings by certified mail and regular mail to the last known addresses of the Defendant, Amos L. Keefer, Jr., which are 69 Cherry Grove Road, Shippensburg, PA 17257 and 11225 Saint Martins PKWY, Berlin, MD 21811, and the Sheriff, Marshal or other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of Sale or said subsequent pleading on the most public part of the property located at 69 Cherry Grove Road, Shippensburg, PA 17257, which is the subject of this action in mortgage foreclosure. tRUS Pit FROM RECORU t TesVrzony wheriW, I here unto sm my hand ,;d the alafi wd COW at Carlisle, Pa f - 'W,& °ro?i?mata BY THE OURT: SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee COURT OF COMMON PLEAS successor in interest to Bank One, N.A., as CUMBERLAND COUNTY Trustee of the Structured Asset Securities Corporation, Amortizing Residential NO: 08-1019 CIVIL TERM Collateral Trust, 2002-BCl PLAINTIFF vs. ; Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS CERTIFICATION AS TO THE SALE OF REAL PROPERTY I hereby certify that I am the Attorney of record for the Plaintiff in this Action against Real Property and further certify this Property is: FHA - Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit That the Plaintiff has complied in all respects with Section 403 of the X Mortgage Assistance Act including but not limited to: (a) Service of notice on Defendant(s) (b) Expiration of 30 days since the service of notice (c) Defendant(s) failure to request or appear at meeting with Mortgagee or Consumer Credit Counseling Agency (d) Defendant(s) failure to file application with Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any false statement given herein. SHAPIRO & DENARDO, LLC BY: VVW ? a Michael J. Cl*, Esquire PA Bar # 202929 C3 r -z ?- _ ? .? ? ?_? _. ? + ?' N .i ?-' w f? :. r, ? ? ?r ?? I SHAPIRO & KREISMAN, LLC BY: DANIELLE BOYLE-EBERSOLE, ESQ. LAUREN R. TABAS, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 81747, 93337 & 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF VS. Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 DEFENDANT(S) STATE OF: COUNTY OF: AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the Plaintiff and that the above-captioned Defendants' last known address is as set forth in the caption and they are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Aqt of 1940, as amended. Ocwen Loan Servicing, LLC on beh, successor in iinteWst to Bank One, N By: NAME: )Ma V. Ji TITLE: Foreclosure Facili COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: f JPMorgaf Chq§e Bank, N.A., as Trustee as Trustee of a Structured Asset Securities IJ Sworn to and subscribed before me this day of Itir. 2008. , Notary Public 07-31048 `"" " o bcida a a Ex 0888/2010 'r- ga , t:>- ?? . C7 c r-r SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as ; Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF VS. ; Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:08-1019 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 Ocwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 and that the last known address(es) of the judgment debtor (Defendant(s)) is: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Amos Keefer Jr. 69 Cherry Grove Rd. Shippensburg PA, 17257 SHAPIRO & EMNARDO, LLC BY: 1 V y v Michael J. C Attorney for ?;? ? ?? "=> ? ? ;-? ??? : °? <? , ?? _ ?? J ? ? i`?? f : i <: . ? l_.' C, ? C.,..3 i..., i TY _ j ?r?. G> `? ?.i ?,? 4 vs. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, N.A., as Trustee COURT OF COMMON PLEAS successor in interest to Bank One, N.A., as CUMBERLAND COUNTY Trustee of the Structured Asset Securities Corporation, Amortizing Residential NO: 08-1019 CIVIL TERM Collateral Trust, 2002-BC 1 PLAINTIFF SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 69 Cherry Grove Road, Shippensburg, PA 17257. 1. Name and address of Owner(s) or Reputed Owner(s) Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Amos Keefer Jr. 69 Cherry Grove St Shippensburg PA, 17257 2. Name and address of Defendant(s) in the judgment: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I Ocwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I, PlaintiffOcwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations, 13 North Hanover Street, Carlisle, PA 17013 I , , Ak 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: TENANT OR OCCUPANT 69 Cherry Grove Road Shippensburg, PA 17257 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. BY: 07-31048 SHAPIRO & DENARDO, LLC C,i .s.. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee COURT OF COMMON PLEAS successor in interest to Bank One, N.A., as CUMBERLAND COUNTY Trustee of the Structured Asset Securities ; Corporation, Amortizing Residential Collateral ; NO: 08-1019 CIVIL TERM Trust, 2002-BC 1 PLAINTIFF vs. ; Amos L. Keefer, Jr. and Carol A. Keefer ; DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Amos Keefer Jr. 69 Cherry Grove Rd Shippensburg PA, 17257 Your house (real estate) at: 69 Cherry Grove Road Shipp?Ensburg, PA 17257 39-14-0171-164 is scheduled to be sold at Sheriffs Sale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the courtjudgment of $187,463.09 obtained by JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. W. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 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. 6. 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 717-240-6390. 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. 8. 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. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . 1-0 ALL the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route 302 (Cherry Grove Road); thence along the centerline of Township Route 302, North 28 degrees 37 minutes 45 seconds West 150.00 feet to a railroad spike set in the center line of Township Route 302 at common corner of Lot 3 and 2; thence along common boundary line of Lots 3 and 2, North 61 degrees 53 minutes 43 seconds East 323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pin set in line of other lands now or formerly of John Thrush; thence along line of lands now or formerly of John Trush, South 08 degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John Thrush, South 61 degrees 53 minutes 43 seconds West 325.83 feet to the point and place of beginning. Containing 1.176 acres, more or less, and being Lot No. 3 on a certain subdivision plan entitled "Subdivision for John Thrush" dated January 22, 1988, drawn by John R. Kissinger, Registered Surveyor, which plan is recorded in Cumberland County, PA Plan Book 1738, Page2196. BEING the same premises which Amos L. Keefer and Carol A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, Page 2196, granted and conveyed unto Amos L Keefer Jr. and Carol A. Keefer husband and wife. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Your house (real estate) at: 69 Cherry Grove Road Shippensburg, PA 17257 39-14-0171-164 is scheduled to be sold at Sheriffs Sale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $187,463.09 obtained by JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 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. 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 717-240-6390. 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. 8. 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. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 07-31048 ALL the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route 302 (Cherry Grove Road); thence along the centerline of Township Route 302, North 28 degrees 37 minutes 45 seconds West 150.00 feet to a railroad spike set in the center line of Township Route 302 at common comer of Lot 3 and 2; thence along common boundary line of Lots 3 and 2, North 61 degrees 53 minutes 43 seconds East 323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pin set in line of other lands now or formerly of John Thrush; thence along line of lands now or formerly of John Trush, South 08 degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John Thrush, South 61 degrees 53 minutes 43 seconds West 325.83 feet to the point and place of beginning. Containing 1.176 acres, more or less, and being Lot No. 3 on a certain subdivision plan entitled "Subdivision for John Thrush" dated January 22, 1988, drawn by John R. Kissinger, Registered Surveyor, which plan is recorded in Cumberland County, PA Plan Book 1738, Page2196. BEING the same premises which Amos L. Keefer and Carol A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, Page 2196, granted and conveyed unto Amos L Keefer Jr. and Carol A. Keefer husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1019 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., as Trustee successor in interest to BANK ONE, N.A., as Trustee of the STRUCTURED ASSET SECURITIES CORPORATION, AMORTIZING RESIDENTIAL COLLATERAL TRUST, 2002-BC1, Plaintiff (s) From AMOS L. KEEFER, JR. and CAROL A. KEEFER (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 $187,463.09 L.L. $.50 Interest 12/22/05 to 3/04/09 is -- $3,297.31 Atty's Comm % Due Prothy $2.00 Atty Paid $310.20 Other Costs Plaintiff Paid Date: 11/24/08 rtis R. Lo g, Prothonotary (Seal) By: REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Deputy Supreme Court ID No. 202929 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 69 Cherry Grove Road, Shippensburg, PA 17257. Name and address of Owner(s) or Reputed Owner(s) Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Amos Keefer Jr. 69 Cherry Grove St Shippensburg PA, 17257 2. Name and address of Defendant(s) in the judgment: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway S Berlin, MD 21811 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 Ocwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 4. Name and address of the last recorded holder of every mortgage of record: The Bank of New York Mellon, as Trustee Amortizing Residential Collateral Trust, 2002-BC1, Plaintiff Ocwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 5. Name and address of every other person who has any record lien on the property: US District Court, Middle District of Pennsylvania c/o Christopher A. Ferro 129 East Market Street York, PA 17401 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations, 13 North Hanover Street, Carlisle, PA 17013 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: TENANT OR OCCUPANT 69 Cherry Grove Road Shippensburg, PA 17257 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. SHAPIRO & DENARDO, LLC BY: i Michael J. Clark, Esquire 07-31048 n +aa SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust, 2002- BC1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Lisa Kosik, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff, The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust, 2002- BC1, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on January 12, 2009 and January 14, 2009, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, SHAPIRO & DENARDO, LLC BY: A /kz Lisa Kosik Legal Assistant 07-31048 r -? 90 .? ? N c a 0 Z 1' g 4 n N N C d N M O O N < Z v? 00 O ? r ? . n N a 0 d 0 T 3 T d n N 3 0 0 ?a 7Y Ivory 9)1 ?" I ?I 41 I r P" C/1 w C/1 Z O r Oro 5-5 N ° O x O MtA O N ?-+ ON.R°Q C> d 00 a W D ? z Q CD Y c?D o N Z rr 3 ? r° O m 7 a CD r W ? CrN "? \O (yD ?Q Wnn J O n O C O UQ O ?. b CD b D a m d N a C m co:0XX m ? tQp ?? A fA m " 3 0 ? v O m m 00 3 ? ? FD 7 j 6P m CL O N m .- N d O W ? _ 4. N igli m g?? ke v ? m O= iiiii%dddddd' Olt m m' m mm f. 4 n o N umit" C, 0 ??,C'ja tion K CD, N irmati n n 3 OOZOZ Handl ng "' V ° Acted elive ID C. a Returo Receipt r c PD v ? to N ?' Z N a C N O'O 3 Ki N m ,c z 0- x "tAo 0 m ?N ?CL awo m -P- v, d D V o o Z CL n N a o y v r pN c ? ? O? CD 7 O N Z Z C. g3 m r T N _ N \ cn o $ a 3 C 000130 ? co .0 =OCD a Q m b ?p aZ a 3 u 3 z c e C o m ?: r? q a m m zz d ?° 073Na Qn o a. CO) d n a » 3 0 W Wery rmatic Handi Return) Recei N o N n o m m m N o?io.?$gZyD W I. m N a'agm m m = ' m b o N unNreo s? i= C) m A, y O ? ? 4 K ° ? ? acs N L 46n H O Z40 m co n>? A O O O O O 0)(0 .ra -? _ ., ?'^} W ? ? ? .::? _. i .?'?,. ??- _£Y? ?. ?. ? ("FT `1 -- r S14APIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust, 2002-BC I PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM VS. ; Carol A. Keefer; and Amos Keefer Jr. ; DEFENDANTS VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that she is a legal assistant for Plaintiff in the above case and that pursuant to the attached Court Order she has mailed a true and correct copy of the Notice of Sale in the above-captioned case to Defendant(s) by certified and regular mail, to the last known address of said Defendant(s) as follows: Amos L. Keefer, Jr., 69 Cherry Grove Road, Shippensburg, PA 17257, and 11225 Saint Martins Parkway, Berlin, MD 21811 on December 16, 2008 as evidenced by the receipts of mailing attached hereto and made a part hereof. I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties set forth in 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATED: 8 7 Dq SHAPIRO & DENARDO, LLC BY: /)(W &e Lisa Kosik Legal Assistant 07-31048 MAY 0 7 2008 SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee ; successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential ; Collateral Trust, 2002-BC 1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM ORDER AND NOW, this O,-day of 2008 upon consideration of Plaintiffs Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent pleadings by certified mail and regular mail to the last known addresses of the Defendant, Amos L. Keefer, Jr., which are 69 Cherry Grove Road, Shippensburg, PA 17257 and 11225 Saint Martins PKWY, Berlin, MD 21811, and the Sheriff, Marshal or other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of Sale or said subsequent pleading on the most public part of the property located at 69 Cherry Grove Road, Shippensburg, PA 17257, which is the subject of this action in mortgage foreclosure. tRU9 OOP" FROM RECORU i? Tesvrsny whared, I here unto sm my hand A t *1 of Sal d Cart r4 Carlisle, Pa f° d _&.1ul- rot htmote BY THE COURT- Q? ??-C -• U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT P VIDE FOR FOR Received From: Shapiro and KreismanLLC 3600 Horizon Drive Ste. 150 King Of Prussia, PA 19406 vc One place of ordinary mail addressed to: ry Amos L. Keefer, Jr. 69 Cherry Grove Road '~- Shippensburg, PA 17257 PS Form 3817, January 2001 ?p a N) UrurFb CD N) p i S9 O l t ' N m C) o CD M rn M ? c p oC 0 C. rn OD O U.S. POSTAL SERVICE CERTIFICATE NF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT Received From: Shaviro and Kreisman, LLC 3600 Horizon Drive Ste. 150 King Of Prussia, PA 19406 O one piece of ordinary mail addressed to: G) o N UwrFb N 'S'am Amos L. Keefer Jr. A C) , 11225 Saint Martins Parkway 016 4 0 -1 Berlin- NM 21811 lK- 07- o 20 PS Form 3817, January 2001 M rn _ (o N a? O O _N co rn O U.S. Postal Service (ERTIFIED MAIL RE CLIi-, I' CERTIFIED M AIL,; R ECEIPT rn mestic Mail Only; No Insurance Coverage Provided) (Domestic Mail Only; No Insuranc e Coverage Provided) In Ln For delivery information visit our webs ite at www.usps.com ' OFFICI a ,` -- . Postage $ u Postage $ _ o r C3 Certified Fee Q9u \ Certified Fee - °" G Return Receipt Fee (Endorsement Required) Postmark ` H 1 y O Return Receipt Fee Q (Endorsement Required) 1 ' Here r, - p Restricted Delivery Fas (Endorsement Required) } (y?r??,? O Restricted Delivery Fee (Endorsement Required) 10 $ ; N Total Postage & Fees SF,' 1f' 1...? __.... „.,... Total Postage & Fees $ 9 f o Sent To t 4 ?° mil?. Sent ro o ?.. '` - ?I-! : - ?° , .. . O (? - - No, Street, Apt'No." or PO Box 0 ? % . lYj/__Illl!`_L11 C-??` q ,, 2 ? ?r .xa, { ? "?" { ? JF,rvlorgan Chase Bank, N.A., as Trustee In The Court of Common Pleas of Successor in Interest to Bank One, N.A., as Cumberland County, Pennsylvania Trustee of the Stnrcfured Asset Securities Writ No. 2008-1019 Civil Tema Corporation, Amortizing Residential Collateral Trust, 2002-BCI VS Amos L. Keefer, Jr. and Carol A. Keefer William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 16, 2009 at 1658 hours, he served a true copy of the within Real Estate Writ., Notice and Description, in the above entitled action, upon the within named defendants, to wit: Amos L. Keefer, Jr. and Carol A. Keefer, by posting the premises located at 69 Cherry Grove Road, Shippensburg, Cumberland County, Pennsylvania with a true and correct copy of the: same according to law. R. Thomas Kline, who being duly sworn according to law, states that he made a diligent search and inquiry, for the within named defendant to wit: Carol A. Keefer, but was unable to locate her in his balliwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Real Estate Writ, Notice and Description, according to law. Franklin County Return- and now, the 3ra day of March 2009, served the within, Real Estate Writ, Notice and Description, upon the defendant, Carol A. Keefer, by making known unto, Carol A. Keefer., personally at the Franklin County Sheriff's Office, 157 Lincoln Way East., Chambersburg, Pennsylvania its contents and at the same time handing to her a true and correct copy of the same. So Answers; Dane Anthony, Sheriff of Franklin County, Pennsylvania. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 13, 2009 at 1806 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 Amos L. Keefer, Jr. and Carol A. Keefer located at 69 Cherry Grove Road, Shippensburg, 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: Amos L. Keefer Jr. and Carol A. Keefer, by regular mail to their last known address of 69 Cherry Grove Road, Shippensburg, PA 17257. These letters were mailed under the date of January 20, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ is returned. STAYED, in accordance to civil process rule 3129.3, "If the plaintiff or a representative of the plaintiff is not present at the sale, the real property shall not be sold. The sheriff shall return the writ of execution to the prothonotary and file a return pursuant to Rule 3139, indicating that the real property was not sold because the plaintiff or a representative of the the plaintiff was not present at the sale". Sheriff's Costs: Docketing 30.00 Poundage 20.42 Posting Bills 15.00 Adverti sing 15.00 Law Library .50 Prothonotary 2.00 Mileage 56.70 Levy 15.00 Franklin County 9.00 Si- charge 30.00 Post Pone Sale 20.00 Law Journal 401.00 Patriot News 411.08 Share of bills 15.52 J- 1,041.22 So Answers: R. Thomas Kline, eriff `BY C 44"? Real Estate Coordi? ?i7U ? J 7 // ? SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee COURT OF COMMON PLEAS successor in interest to Bank One, N.A., as CUMBERLAND COUNTY Trustee of the Structured Asset Securities Corporation, Amortizing Residential NO: 08-1019 CIVIL TERM Collateral Trust, 2002-BC I ; PLAINTIFF vs. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS AFFIDAVIT PURSUANT TO RULE 31219.1 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 69 Cherry Grove Road, Shippensburg, PA 17257. Name and address of Owner(s) or Reputed Owner(s) Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MI) 21811 Amos Keefer Jr. 69 Cherry Grove St Sh.ippensburg PA, 17257 2. Name and address of Defendant(s) in the judgment: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 112.25 Saint Martins Parkway Berlin, MD 21811 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:. JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I Oewen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC I, PlaintiffOcwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations, 13 North Hanover Street, Carlisle, PA 17013 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: TENANT OR OCCUPANT 69 Cherry Grove Road Shippensburg, PA 17257 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 unswom falsification to authorities. BY: 07-31048 SHAPIRO & DENARDO, LLC SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF F's. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS ; NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Amos Keefer Jr. 69 Cherry Grove Rd Shippensburg PA, 17257 Your house (real estate) at: 69 Cherry Grove Road Shippensburg, PA 17257 39-14-0171-164 is scheduled to be sold at Sheriffs Sale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $187,463.09 obtained by JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIF'F'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank:, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE BOTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the ''highest bidder. You may find out the price bid by calling (610) 278-6800. 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. 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 717-240-6390. 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. 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. Al. that time, the buyer may bring legal proceedings to evict you. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ALL the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows; BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route 302 (Cherry Grove Road); thence along the centerline of Township Route 302, North 28 degrees 37 minutes 45 seconds West 150.00 feet to a railroad spike set in the center line of Township Route 302 at common corner of Lot 3 and 2; thence along common boundary line of Lots 3 and 2, North 61 degrees 53 minutes 43 seconds East 323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pin set in line of other lands now or formerly of John Thrush; thence along line of lands now or formerly of John Trush, South 08 degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John Thrush, South 61 degrees 53 minutes 43 seconds West 325.83 i:eet to the point and place of beginning. Containing 1.176 acres, more or less, and being Lot No. 3 on a certain subdivision plan entitled "Subdivision for John Thrush" dated .January 22, 1988, drawn by John R. Kissinger, Registered Surveyor, which plan is recorded in Cumberland County, PA Plan Book 1738, Page2196. BEING the same premises which Amos L. Keefer and Carol A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, Page 2196, granted and conveyed unto Amos L Keefer.Jr. and Carol A. Keefer husband and wife. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 PLAINTIFF vs. COURT OF COW/TON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Your house (real estate) at: 69 Cherry Grove Road Shippensburg, PA 17257 39-14-0171-164 is scheduled to be sold at Sheriffs Sale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the courtjudgment of $187,463.09 obtained by JPM:organ Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court: to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to ;postpone the sale for good cause. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how 1.0 obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 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. 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 717-240-6390 . 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. 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. You may be entitled to a share of the money, which was paid for yourhouse. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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 I:)O 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 07-31048 ALL the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route 302 (Cherry Grove Road); thence along the centerline of Township Route 302, North 28 degrees 37 minutes 45 seconds West 150.00 feet to a railroad. spike set in the center line of Township Route 302 at common corner of Lot 3 and 2; thence along common. boundary line of Lots 3 and 2, North 61 degrees 53 minutes 43 seconds East 323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pin set in line of other lands now or formerly of John Thrush; thence along line of lands now or formerly of John Trush, South 08 degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John Thrush, South 61 degrees 53 minutes 43 seconds West 32.83 feet to the point and place of beginning. Containing 1.176 acres, more or less, and being Lot No. 3 on a certain subdivision plan entitled "Subdivision for John Thrush" dated January 22, 1988, drawn by John R.. Kissinger, Registered Surveyor, which plan is recorded in Cumberland County, PA Plan Book 1738, Page2196 . BEING the same premises which Amos L. Keefer and Carol A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, Page 2196, granted and conveyed unto Amos L Keefer Jr. and Carol A. Keefer husband and wife. WRIT OF EXECUTION and/or ATTACHMENT ('Oti1MON%VEALTII OF PENNSYLVANIA) NO 08-1019 Civil COI 77NTY OF CUMBERLAND) CIVIL ACTION I A%y' TO fill- SHERIFF OF CUMBERLAND COUNTY: l'o satisfy the debt, interest and costs due JPYIORGAN CHASE BANK, N.A., as Trustee successor in interest to BANK ONE, N.A., as Trustee of the STRUCTURED ASSET SECURITIES CORPORATION, AMORTIZING RESIDENTIAL COLLATERAL'I'RUST, 2002-BG'I. Plaintiff (s) From ABIOS L. KEEFER, JR. and CAROL A. KEEFER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (?) You arc also directed to attach the property of the defendant(s) not levied upon in the posse;sion of GARNISHEE(S) as follows: and to notify the p rnishee(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 5187,463.09 Interest 12/22/05 to 3/04/09 is -- $3,297.31 AM's Comm L. L. $.50 Due Prothy $2.00 Attu Paid 5310.20 Plaintiff Paid Date: 11/24/08 (Sea!) REQUFS ITNG PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING: OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 Other Costs 4 - ?z (EUrtis R. Long.11o hono'tar By: Deputy Real Estate Sale #74 On December 18, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA. Known and numbered as 69 Cherry Grove Road, Shippensburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 18, 2008 By: Real Estate Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 30, February 6, and February 13, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, Edi SWORN TO AND SUBSCRIBED before me this 3 day of February 13, 2009 / G-C Notary .. o.... r "WAL SEAL Dc?C:;tkl-r f-A CCLL(PI;S Nv,tary CARLISLE B(DRO, CUTA!IF< A.F 7. COUNTY My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 74 Writ No. 2008-1019 Civil JP Morgan Chase Bank, N.A.. as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amoritizing Residential Collateral Trust, 2002-BC 1 vs. Amos L. Keefer. Ji and Carol A. Keefer Atty.: Michael Clark ALL the following described real estate lying and being situate in Southampton Township, Cumber- land County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route 302 (Cherry Grove Road); thence along the centerline of Town- ship Route 302, North 28 degrees 37 minutes 45 seconds West 150.00 feet to a railroad spike set in the center line of Township Route 302 at com- mon corner of Lot 3 and 2; thence along common boundary line of Lots 3 and 2, North 61. degrees 53 min- utes 43 seconds East 323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pin set in line of other lands now or for- merly of John Thrush; thence along line of lands now or formerly of John Trush, South 08 degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John Thrush, South 61 degrees 53 minutes 43 seconds West 325.83 feet to the paint and place of beginning. Containing 1. 1.76 acres, more or less, and being Lot No. 3 on a certain subdivision plan entitled "Subdivision for John Thrush" dated January 22, 1988, drawn by John R. Kissinger, Registered Surveyor which plan is recorded in Cumber land County, PA Plan Book 1738 Page 2196. BEING the same premises which Amos L. Keefer and Carol A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland. County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, Page 2196, granted and conveyed unto Amos 1 Keefer Jr. and Carol A. Keefer hus band and wife. e Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Zhe PNow 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 RAAL ii1STM SAN.ROM 74 Nhlt 1W 908 W9 Grit 1bM JP UorQW. 8WW4.N.A., as T iMao succonsor In Inlareal: to Barak One, NJL, as Trustee of he' Structured Asset Socurfth Corporadon, Adng, - Coftter'alTnA%L= _W1 Amon L. KoWer, Jr. and Carol & rester Anorney MkhaW Clark LEGAL DIQN ALL the folWW described real esnte lying and being- situate im 3vailgappm Tmm*, Cumberland Comity, Ammyi ; bounded and describ c d as follows: 8BGROW. at It m6ad spike set in the centerline of pubfic road bon and designated as Tbww4 Route 302 K'berry Grove Road), thence dons the cm%dbw of Uimbip Route 302, Nordt 28 degrees 37 s 45 seconds West 1MA0 feet to g railroad spite set in the cents he of lbv ado Rdbte 302 at common caner of Lot l and 2; tiNeee,akatg common boundaryline of Lots 3 and, 2 North 61 degrees 53 mid 43 n- oafs'lllast 323.47 feet to an iron pin set inrioe of bw n6w or hmlmiy of -=times HiiB; Aeeae $Iong line of land now or fotmaiy.of James Ek South 57 degrees 33 minutes 28 seconds lisst 71.88 feet to an iron '* set. in lin e of other lands now of famedy of John Thrush; tiaeace a4mg lime of lands now or fo taetty of John Tn* 08 degrees 12 mrinates 52 woods 'East 92.95 feet b an iron goes through loads WWI %medy of r n Thmsh, South 61 ft ees 53 minutes 43 sends West 325.83 fed to the point and place of begmnrag. Coettaicang 1.176 acim more or less, and bdgLot N4,wacatain subdivision plan entithed "Subdivision for John Tbrush„ dated hoary 22, 4988; drawn by John R. Kissinger; Registered Surveyor which plan is recorded in Cumberland County, PA Plan Book 1738, Page 2196. BEM ,ft same-psemises_wbich Amos L. Keefer and Cad A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, hp 21%,.graved and amveyed onto Amos L Keefer k W Cad A. Keefer husband and v kf This ad ran on the date(s) shown below: 01 /21 /09 01/28/09 02/04/09 Sworn to and" scribed before 71hi,3 25 ytay of February, 2009 A.D. Notary Public i,OMMONWEx t_ T HI OF PENNSYLVANIA a Nota!t: Ssal Sherrie L. Kisner, Notary Pubk Cky Of Hamsl)urq, Oauphin County My Conv dasior EnVires Nov. 26, 2011 Member, Pennsylva.w* Assacletkm of Wefts SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust 2002-BC I PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM VS. Amos L. Keefer, Jr., Carol A. Keefer, and Amos Keefer Jr. DEFENDANTS MOTION OF PLAINTIFF TO PLACE PROPERTY FOR STALE ON SEPTEMBER 2.2009 SHERIFF'S SALE LIST Plaintiff, by its counsel, SHAPIRO & DENARDO, LLC, moves this Honorable Court to reconsider its Order denying Plaintiff's Motion for Alternate Service of Process. In support of this Motion, Plaintiff avers the following: On or around November 24, 2008, Plaintiff obtained a default judgment against the Defendants, Amos L. Keefer, Jr. and Carol A. Keefer (collectively "Defendants") for their failure to file any response to its Complaint. 2. Shortly thereafter, the Plaintiff caused a Writ of Execution to be issued and the Sheriffs Sale of the property situated at 69 Cherry Grove Road, Shippensburg, PA 17257 ("Property") was originally scheduled for March 4, 2009. 3. In accordance with Pa. R.C.P 3129.3., Plaintiff was required to postpone the Sheriffs sale of the Property since the Notice of Sale was not served upon Defendant, Carol A. Keefer, before thirty (30) days of the March 4, 2009 sale. 4. Defendant Amos L. Keefer, Jr. was served by posting of the Property pursuant to a Court Order, which posting occurred on or around January 16, 2009. 5. Plaintiff postponed the Sheriff s sale of the Property to the June 10, 2009, Cumberland County Sheriff's sale and Defendant, Carol A. Keefer, was properly served with the Notice of Sale on March 3, 2009, in Franklin County. 6. At the June 10, 2009, Plaintiffs local counsel was in attendance at the Sheriff s Sale, however, she did not hear the Property announced by the Sheriff s office, although she received instructions to proceed with selling the Property at that sale. 7. After the Sheriff s sale, Plaintiff's undersigned law firm contacted the Cumberland County Sheriffs Office and was informed that the sale of the Property was stayed because it was announced three (3) times during the sale, but no one responded during the auction. Since the Sheriff s sale of the Property was stayed by the Cumberland County Sheriffs Office, Plaintiff must now incur the costs associated with starting the entire sale process over against, which amounts to nearly several thousand dollars. 9. Additionally, the Property will not likely be listed again for another six (6) months until the December 9, 2009, Sheriff s sale, while the Property remains vacant. 10. The Cumberland County Sheriff does not hold its Sheriffs sales every month like most other counties in the Commonwealth of Pennsylvania, but instead holds them every three (3) months. 11. According to Pa.R.C.P. 3118(a) (6) titled "Supplementary Relief in Aid of Execution," this Honorable Court has the power to grant relief as is "necessary and appropriate." 12. The long delay and unnecessary costs Plaintiff will incur if the Property is not placed on the September 2, 2009 Sheriff's sale list are avoidable if this Honorable Court issues an order to that effect. 13. The requested relief is "necessary and appropriate" because the Property is believed to be vacant and Plaintiff will suffer irreparable harm unless the relief requested herein is granted and Plaintiff is permitted to proceed to sell the Property. Any of the following issues could significantly compromise the value of the property which is securing the obligation of Plaintiff; and action is warranted insofar as: a. Plaintiff is unaware as to whether there are any squatters or criminals in the Property; b. Plaintiff is unaware as to whether any squatter or criminals are causing any damage, waste, and/or illegal activity on the Property; c. Plaintiff is unaware as to whether any casualty has occurred in and/or to the Property; d. Plaintiff is unaware as to whether the Property is being used for activities that are contrary to City zoning rules, regulations, and/or ordinances; e. Plaintiff is unaware as to whether there have been any accidents in and/or on the Property such that Plaintiff could be sued and be liable for premises liability; and f. Plaintiff is unaware as to whether the Property is secured such that it could be subject to destruction, vandalism, and/or arson. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order requiring the Cumberland County Sheriff to place the Property on the September 2, 2009, Cumberland County Sheriff's sale list in order for it to be sold by Plaintiff. SHAPIRO & DENARDO, LLC BY: vv., 4 VL--- Michael J. Clark, Esquire Attorney for Plaintiff VERIFICATION Michael J. Clark, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that is authorized to take this Verification, and that the statements made in the foregoing Motion to Place Defendants' Property for Sale on September 2, 2009, Sheriff s Sale List are true and correct to the best of knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. SHAPIRO & DENARDO LLC BY: V Y \.. Michael . Clark, Esquire Attorney for Plaintiff S & D FILE NO. 07-31048 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust 2002-BC I PLAINTIFF VS. Amos L. Keefer, Jr., Carol A. Keefer, and Amos Keefer Jr. DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM MEMORANDUM OF LAW According to Pa.R.C.P. 3118(a) (6) titled "Supplementary Relief in Aid of Execution," this Honorable Court has the power to grant relief as is "necessary and appropriate." The long delay and unnecessary costs Plaintiff will incur if the Property is not placed on the September 2, 2009 Sheriff's sale list are avoidable if this Honorable Court issues an order to that effect. The requested relief is "necessary and appropriate" because the Property is believed to be vacant and Plaintiff will suffer irreparable harm unless the relief requested herein is granted and Plaintiff is permitted to proceed to sell the Property. Any of the following issues could significantly compromise the value of the property which is securing the obligation of Plaintiff; and action is warranted insofar as: a. Plaintiff is unaware as to whether there are any squatters or criminals in the Property. b. Plaintiff is unaware as to whether any squatters or criminals are causing any damage, waste, and/or illegal activity on the Property. c. Plaintiff is unaware as to whether any casualty has occurred in and/or to the Property. d. Plaintiff is unaware as to whether the Property is being used for activities that are contrary to City zoning rules, regulations, and/or ordinances. e. Plaintiff is unaware as to whether there have been any accidents in and/or on the Property such that Plaintiff could be sued and be liable for premises liability. f. Plaintiff is unaware as to whether the Property is secured such that it could be subject to destruction, vandalism, and/or arson. Plaintiff respectfully requests that this Honorable Court enter an Order requiring the Cumberland County Sheriff to place the Property on the September 2, 2009, Cumberland County Sheriff s sale list in order for it to be sold by Plaintiff. Respectfully Submitted, SHAPIRO & DENARDO, LLC Date: July 10, 2009 BY: Vv? A V Michael J. lark, Esquire Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee COURT OF COMMON PLEAS for Amortizing Residential Collateral Trust CUMBERLAND COUNTY 2002-BC I PLAINTIFF NO: 08-1019 CIVIL TERM VS. ; Amos L. Keefer, Jr., Carol A. Keefer, and Amos Keefer Jr. DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of this Motion to Reconsider Order Denying Service Pursuant to Special Order of Court and the papers attached thereto on all parties named herein at last known adcess or upon attorney of record by regular mail, postage prepaid to the parties listed below on W % i 0 '2009. Amos L. Keefer, Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Cumberland County Sheriff's Department Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 SHAPIRO & IDENARDO, LLC BY: ? Michael J. lark, Esquire Attorney for Plaintiff Fly,) ?' a'? ? E OF ?i-i r C ;?y G,.;,: SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust 2002-BC I PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM VS. Amos L. Keefer, Jr.; Carol A. Keefer; and Amos Keefer Jr. DEFENDANTS AMENDMENT TO PLAINTIFF'S MOTION TO PLACE PROPERTY FOR SALE ON SEPTEMBER 2, 2009 SHERIFF'S SALE LIST No Judge has ruled upon any other issue in this matter 2. No concurrence has been sought on this Motion by opposing counsel as the interested parties are not represented by counsel. SHAPIRO & DeNARDO, LLC Date: G` BY: , Michael J. Cl , Esquire Attorney for P intiff SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee ; for Amortizing Residential Collateral Trust 2002-BC I PLAINTIFF VS. Amos L. Keefer, Jr.; Carol A. Keefer; and Amos Keefer Jr. DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of this Amendement on 01 to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Amos L. Keefer, Jr., 69 Cherry Grove Road, Shippensburg, PA 17257 Carol A. Keefer, 69 Cherry Grove Road, Shippensburg, PA 17257 Amos Keefer Jr., 11225 Saint Martins Parkway, Berlin, MD 21811 SHAPIRO & DeNARDO, LLC Date: BY:l (I- k, Esquire Michael J. Ctaintiff Attorney for ALEU + ' OF THE P" "7NRv 2009 JU'L 23 All i 10: 1: R SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust 2002-BC I PLAINTIFF VS. Amos L. Keefer, Jr., Carol A. Keefer, and Amos Keefer Jr. DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM ORDER AND NOW, this Tay of , 2009 upon consideration of Plaintiff s Motion to Place Defendants' Property for Sale on September 2, 2009, Sheriff s Sale List and the response, if any, of Defendants, it is hereby ORDERED and DECREED that the Plaintiffs Motion is GRANTED; and It is FURTHER ORDERED and DECREED that the Sheriff of Cumberland County place the property located at 69 Cherry Grove Road, Shippensburg, PA 17257, on the September 2, 2009 Sale list; and no further costs, advertisement, or notice is required by Plaintiff. Plaintiff must mail a copy of this Order to the Defendants by regular mail, postage prepaid, to the Defendants last known address and Plaintiffs attorney, must file with the Prothonotary's Office a Certificate of Service as to such mailings. BY THE COURT: OF ALEU--O =U TFrE: 2009 JUL 27 Ph 1: 53 PEN' SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust 2002-BC I PLAINTIFF VS. Amos L. Keefer, Jr.; Carol A. Keefer; and Amos Keefer Jr. DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM AFFIDAVIT OF SERVICE I, Lisa Kosik, the undersigned, being duly sworn according to law, hereby depose and say that on the 3rd day of August, 2009, pursuant to the attached Order of Court, attached as Exhibit "A", I served a true and correct copy of the Order of Court in the above captioned matter to the Defendants by certified and regular mail, to their last known address of: Amos L. Keefer, Jr., 69 Cherry Grove Road, Shippensburg, PA 17257 Carol A. Keefer, 69 Cherry Grove Road, Shippensburg, PA 17257 Amos Keefer Jr., 11225 Saint Martins Parkway, Berlin, MD 21811 SHAPIRO & DeNARDO, LLC BY: W SWORN AND Befo me this, 20hv of o Public S & FILE NO. A- 1048 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Andrea Madden. Notary Public Upper Merion 1Wp., Montgomery County my commission F-xpires June 19, 2012 Member, Pennsylvania Associatlon of Notaries Lisa Kosik Legal Assistant to Attorney for Plaintiff MIS r ?f SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of -Newyork Mellon, as Trustee ; for Amortizing Residential Collateral Trust 2062-BC 1 PLAINTIFF VS. ; Amos L. Keefer, Jr., Carol A. Keefer, and ; Amos Keefer Jr. DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM ORDER AND NOW, this -?7q '; Ta?y of IAAr_ 2009 upon consideration of Plaintiffs I 6f Motion to Place Defendants' Property for Sale on September 2, 2009, Sheriff's Sale List and the response, if any, of Defendants, it is hereby ORDERED and DECREED that the Plaintiffs Motion is GRANTED; and it is FURTHER ORDERED and DECREED that the Sheriff of Cumberland County place the property located at 69 Cherry Grove Road, Shippensburg, PA 17257, on the September 2, 2009 Sale list; and no further costs, advertisement, or notice is required by Plaintiff. Plaintiff must mail a copy of this Order to the Defendants by regular mail, postage prepaid, to the Defendants last known address and Plaintiffs attorney, must file with the Prothonotary's Office a Certificate of Service as to such mailings. BY THE COURT: TRUE COPY FROM RECOM M Tes t whe(S A l h" auto set +4 bens Wd ft so d sWd OW" at,C60ft. P& "IF TI i C..; rr?Py 2099 AUG -6 AH 10: 20 cli, soot r s inr NO 00321 AVS THE BANK OF NEW YORK MELLON, IN THE COURT OF COMMON PLEAS OF AS TRUSTEE FOR AMORTIZING CUMBERLAND COUNTY, PENNSYLVANIA RESIDENTIAL COLLATERAL TRUST 2002-BC1, PLAINTIFF V. AMOS L. KEEFER, JR., CAROL A. KEEFER AND AMOS KEEFER, JR., DEFENDANTS NO. 08-1019 CIVIL AMENDED ORDER OF COURT AND NOW, this /?'y'"day of August, 2009, upon consideration of the Plaintiff's Motion to Place Defendants' property for Sale on September 2, 2009, Sheriff's Sale List, IT IS HEREBY ORDERED AND DIRECTED that the Plaintiff's Motion is GRANTED. The Docket in this matter shall be reopened with the original writ and affidavit 3129.1 returned to the Office of the Sheriff; IT IS FURTHER ORDERED AND DIRECTED that Plaintiff, at its expense, shall advertise proper notice that the subject property will be sold on September 2, 2009, and Plaintiff shall pay any additional costs lawfully imposed by the Office of the Sheriff. IT IS ALSO FURTHER ORDERED AND DIRECTED that the Sheriff of Cumberland County shall expose for sale the property located at 69 Cherry Grove Road, Shippensburg, PA 17257 at the September 2, 2009, sale. Plaintiff must mail a copy of this order to the defendants by regular mail, postage prepaid, to the Defendants' last know address and Plaintiff's attorney must file with the Prothonotary's Office, a Certificate of Service as to such mailings. No further continuances shall be granted except upon further Order of Court. By the Court, SAA % % M. L. Ebert, Jr., J. Michael J. Clark, Esquire Attorney for Plaintiff Edward Schorpp, Esquire -S gjl?oJ? Solicitor, Cumb. Co. Sheriff Cumberland County Sheriff -bPrb bas eof? #4vMWL `" k _.I,_.'? ?.',. 1 ?_ r" tt r. (;i..? _ `i`t ?. ?. , ,. e SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-31048 The Bank of New York Mellon, as Trustee for Amortizing Residential Collateral Trust 2002-BC I PLAINTIFF VS. Amos L. Keefer, Jr.; Carol A. Keefer; and Amos Keefer Jr. DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM AFFIDAVIT OF SERVICE I, Lisa Kosik, the undersigned, being duly sworn according to law, hereby depose and say that on the 12th day of August, 2009, pursuant to the attached Order of Court, attached as Exhibit "A", I served a true and correct copy of the AMENDED ORDER in the above captioned matter to the Defendants by certified and regular mail, to their last known address of: Amos L. Keefer, Jr., 69 Cherry Grove Road, Shippensburg, PA 17257 Carol A. Keefer, 69 Cherry Grove Road, Shippensburg, PA 17257 Amos Keefer Jr., 11225 Saint Martins Parkway, Berlin, MD 21811 Carol Keefer, 361 Center Street, Chambersburg, PA 17201 SHAPIRO & DeNARDO, LLC SWORN AND SUBSCRIBED Before me this L2X` day ofAVNA - 200(?. I, ' Lj1'j'6-- Notary Public S & D FILE NO. 07-31048 - ngn,rr ".J -??- !., BY: , /'oom Lisa Kosik Legal Assistant to Attorney for Plaintiff THE BANK OF NEW YORK MELLON, IN THE COURT OF COMMON PLEAS OF AS TRUSTEE FOR AMORTIZING CUMBERLAND COUNTY, PENNSYLVANIA RESIDENTIAL COLLATERAL TRUST 2002-BC 1, PLAINTIFF V. AMOS L. KEEFER, JR.. CAROL A. KEEFER AND AMOS KEEFER, JR., DEFENDANTS NO. 08-1019 CIVIL AMENDED ORDER OF COURT AND NOW, this /0"-day of August, 2009, upon consideration of the Plaintiff's Motion to Place Defendants' property for Sale on September 2, 2009, Sheriffs Sale List, IT IS HEREBY ORDERED AND DIRECTED that the Plaintiffs Motion is GRANTED. The Docket in this matter shall be reopened with the original writ and affidavit 3129.1 returned to the Office of the Sheriff; IT IS FURTHER ORDERED AND DIRECTED that Plaintiff, at its expense, shall advertise proper notice that the subject property will be sold on September 2, 2009, and Plaintiff shall pay any additional costs lawfully imposed by the Office of the Sheriff. IT IS ALSO FURTHER ORDERED AND DIRECTED that the Sheriff of Cumberland County shall expose for sale the property located at 69 Cherry Grove Road, Shippensburg, PA 17257 at the September 2, 2009, sale. Plaintiff must mail a copy of this order to the defendants by regular mail, postage prepaid, to the Defendants' last know address and Plaintiffs attorney must file with the Prothonotary's Office, a Certificate of Service as to such mailings. No further continuances shall be granted except upon further Order of Court. By the Court, Nh, -4, ?AA M. L. Ebert, Jr., J. v Michael J. Clark, Esquire Attorney for Plaintiff Edward Schorpp, Esquire Solicitor, Cumb. Co. Sheriff Cumberland County Sheriff bas ,." 7WE PROTHONOTARY 1109 AUG 14 AN 14: 39 COUNTY AEI 01VAN UA ,. ' , SHAPIRO & DENARDO, LLC BY: Michael J. Clark, squire >i I??PIIZO & DENARDO, LLC Y: MICHAEL J. CLARK, ESQUIRE TTORNEY 1. D. NO: PA Bar # 202929 _+OUO HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 S & D FILE NO. 07-31048 I'Mon an Chase Bank, N.A., as Trustee ;uccessor in interest to Bank One, N.A., as , .isiee of the Structured Asset Securities 'corporation, Amortizing Residential 'ollateral Trust, 2002-BC1 P[,AINTIFF Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM .1,CIPE TO MARK THE, JUDGMENT TO THE USE OF THE BANK OF NEW YORK 1,L.LON, AS TRUSTFT' FOR AMORTIZING RESIDENTIAL COLLATERAL TRUST 2002-BC I 'I i 1 THE PROTHONOTARY: Kindly marl, the judgment in the above-captioned matter to the use of "The Bank Of New ?.'url: Mellon, As "Trustee For Amortizing Residential Collateral Trust, 2002-BCI" as the real ;-,?u-ty/Plaintiff in interest in this action and the holder of the Note and Mortgage. i_> ATLD: `?1-IAPIRO & DFNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 >600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 1) FILE NO. 07-31048 " •'? organ Chase Bank, N.A., as Trustee ??ssor in interest to Bank One, N.A., as o f the Structured Asset Securities >rporation, Amortizing Residential ?_'ollateral Trust, 2062-13CI PLAINTIFF Enos L. Keefer, Jr. and Carol A. Keefer )!-PENDANTS COURT OF COMMON PLEAS CUMBERLAND COITNTY NO: 08-1019 CIVIL TERM CERTIFICATION hereby certify than I have served a true and correct copy of this Praecipe to Mark .1 udgment to the Use of THE BANK OF NEW YORK MELLON, AS TRUSTEE FOR AMOP,TIZ4reeor I ',ENTIAL COLLATERAL TRUST, 2002-BC] and the papers attached hereto on to all parties named herein at their last known address or upon their ;ittorney of belowlisted by regular mail, postage prepaid: nos L. Keefer, jr. Cherrv Grove Road ? !!)i?ensburg. PA 17257 .'?u-ol A. Keefer 01) Cherry Grove Road Ship:-?ensburg, PA 17257 \mos Keefer Jr. ??5 Saint Martins Parkway . rlin. MD 2181 1 1:1:c I: /9j/2/d ? SHAPIRO & DENARDO, LLC BY: Vael arksquire FILED-OWICE OF THE I RC,fH, T 2884 AUG 20 AM 10: 4 3 CUA??? „u ?:v1?3Y I~'ENNSYaIANA ??? ?33?UU COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND f SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which AMORITIZING RESIDENIAL COLLATERAL TRUST 2002-BC 1 TR is the grantee the same having been sold to said grantee on the 2ND day of SEPT A.D., 2009, under and by virtue of a writ Execution issued on the 24TH day of NOV, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 1019, at the suit of STRUCTURES ASSET SERV CORP TR against AMOS L KEEFER JR & CAROL A is duly recorded as Instrument Number 200934134. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 15,tz,. LP-t , A.D. ?-O c) day of Recorder of Deeds a7 ; A44'tiii(y gT Ha l_ aL11U Amended Return 19 1..1.- F-11},` .'^,r-1 J'i`c.l.. OR THE €' ;../? ,011 r K TAR JPMorgan Chase Bank, N.A., as Trustee In The Court of Common Pleas of Successor in Interest to Bank One, N.A., as Cumberland County, Pe Wj1il'a5 AH 11: Q4 Trustee of the Structured Asset Securities Writ No. 2008-1019 Civil Term Corporation, Amortizing Residential G'Jlr Collateral Trust, 2002-BC 1 VS Amos L. Keefer, Jr. and Carol A. Keefer William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 16, 2009 at 1658 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Amos L. Keefer, Jr. and Carol A. Keefer, by posting the premises located at 69 Cherry Grove Road, Shippensburg, Cumberland County, Pennsylvania with a true and correct copy of the same according to law. R. Thomas Kline, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Carol A. Keefer, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Real Estate Writ, Notice and Description, according to law. Franklin County Return- and now, the 3rd day of March 2009, served the within, Real Estate Writ, Notice and Description, upon the defendant, Carol A. Keefer, by malting known unto, Carol A. Keefer, personally at the Franklin County Sheriff's Office, 157 Lincoln Way East, Chambersburg, Pennsylvania its contents and at the same time handing to :her a true and correct copy of the same. So Answers; Dane Anthony, Sheriff of Franklin County, Pennsylvania. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 13, 2009 at 1806 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 Amos L. Keefer, Jr. and Carol A. Keefer located at 69 Cherry Grove Road, Shippensburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states lie 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: Amos L. Keefer Jr. and Carol A. Keefer, by regular mail to their last known address of 69 Cherry Grove Road, Shippensburg, PA 17257. These letters were mailed under the date of January 20, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 2, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael Clark, on behalf of The Bank of New York Mellon, as Trustee for Amoritizing Residential Collateral Trust 2002-BC1, of, 12650 Ingenuity Drive, Orlando, FL, 32256, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $ 137.70 Sheriff's Costs: Poundage 2.70 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 2.50 Distribution of Proceeds Sheriff's Deed So Answers, R. T omas Kline, Sheriff By Real Estate Coordinator 25.00 49.50 137.70 P`'°?' a kw S-b 4P- -7 / y v7-G A,'? 3i -? THE BANK OF NEW YORK MELLON, AS TRUSTEE FOR AMORTIZING RESIDENTIAL COLLATERAL TRUST 2002-BC1, PLAINTIFF V. AMOS L. KEEFER, JR., CAROL A. KEEFER AND AMOS KEEFER, JR., DEFENDANTS AMENDED ORDER OF COURT Motion to Place Defendants' property for Sale on September 2, 2009, Sheriff's Sale List, GRANTED. The Docket in this matter shall be reopened with the original writ and affidavit 3129.1 returned to the Office of the Sheriff; advertise proper notice that the subject property will be sold on September 2, 2009, and Plaintiff shall pay any additional costs lawfully imposed by the Office of the Sheriff. Cumberland County shall expose for sale the property located at 69 Cherry Grove Road, Shippensburg, PA 17257 at the September 2, 2009, sale. Plaintiff must mail a copy of this order to the defendants by regular mail, postage prepaid, to the Defendants' last know address and Plaintiff's attorney must file with the Prothonotary's Office, a Certificate of Service as to such mailings. No further continuances shall be granted AND NOW, the /_'day of August, 2009, upon consideration of the Plaintiff's IT IS HEREBY ORDERED AND DIRECTED that the Plaintiff's Motion is IT IS FURTHER ORDERED AND DIRECTED that Plaintiff, at its expense, shall IT IS ALSO FURTHER ORDERED AND DIRECTED that the Sheriff of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1019 CIVIL except upon further Order of Court. t. l h9r811!? r' Y By the Court, --? b, ? " k y` M. L. Ebert, Jr., J. JP Morgan Chase Bank, N.A., as Trustee In The Court of Common Pleas of Successor in Interest to Bank One, N.A., as Cumberland County, Pennsylvania Trustee of the Structured Asset Securities Writ No. 2008-1019 Civil Term Corporation, Amortizing Residential Collateral Trust, 2002-BCl VS Amos L. Keefer, Jr. and Carol A. Keefer William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 16, 2009 at 1658 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Amos L. Keefer, Jr. and Carol A. Keefer, by posting the premises located at 69 Cherry Grove Road, Shippensburg, Cumberland County, Pennsylvania with a true and correct copy of the same according to law. R. Thomas Kline, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Carol A. Keefer, but was unable to locate her in his balliwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Real Estate Writ, Notice and Description, according to law. Franklin County Return- and now, the 3rd day of March 2009, served the within, Real Estate Writ, Notice and Description, upon the defendant, Carol A. Keefer, by making known unto, Carol A. Keefer, personally at the Franklin County Sheriff's Office, 157 Lincoln Way East, Chambersburg, Pennsylvania its contents and at the same time handing to her a true and correct copy of the same. So Answers; Dane Anthony, Sheriff of Franklin County, Pennsylvania. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 13, 2009 at 1806 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 Amos L. Keefer, Jr. and Carol A. Keefer located at 69 Cherry Grove Road, Shippensburg, 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: Amos L. Keefer Jr. and Carol A. Keefer, by regular mail to their last known address of 69 Cherry Grove Road, Shippensburg, PA 17257. These letters were mailed under the date of January 20, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, in accordance to civil process rule 3129.3, "If the plaintiff or a representative of the plaintiff is not present at the sale, the real property shall not be sold. The sheriff shall return the writ of execution to the prothonotary and file a return pursuant to Rule 3139, indicating that the real property was not sold because the plaintiff or a representative of the the plaintiff was not present at the sale". Sheriff's Costs: Docketing 30.00 Poundage 20.42 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 56.70 Levy 15.00 Franklin County 9.00 Sr rcharge 30.00 Post Pone Sale 20.00 Law Journal 401.00 Patriot News 411.08 Share of bills 15.52 1,041.22 So Answers: R. Thomas Kline, eriff '` BY Real Estate Coordina or ? 4/l /0P (,- 2 O-D (K 7oaYD SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF vs. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM S AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 69 Cherry Grove Road, Shippensburg, PA 17257. Name and address of Owner(s) or Reputed Owner(s) - Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Amos Keefer Jr. 69 Cherry Grove St Shippensburg PA, 17257 2. Name and address of Defendant(s) in the judgment: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 69 Cherry Grove Road Shippensburg, PA 17257 Amos Keefer Jr. 11225 Saint Martins Parkway Berlin, MD 21811 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC10cwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1, Plaintiff0ewen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations, 13 North Hanover Street, Carlisle, PA 17013 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: TENANT OR OCCUPANT 69 Cherry Grove Road Shippensburg, PA 17257 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. BY: 07-31048 SHAPIRO & DENARDO, LLC SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee COURT OF COMMON PLEAS successor in interest to Bank One, N.A., as CUMBERLAND COUNTY Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral ; NO: 08-1019 CIVIL TERM Trust, 2002-BC1 PLAINTIFF VS. Amos L. Keefer, Jr. and Carol A. Keefer ; DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Amos Keefer Jr. 69 Cherry Grove Rd Shippensburg PA, 17257 Your house (real estate) at: 69 Cherry Grove Road Shippensburg, PA 17257 39-14-0171-164 is scheduled to be sold at Sheriffs Sale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $187,463.09 obtained by JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-13C1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact: one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. 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. 6. 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 717-240-6390. 7. 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. 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. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ALL the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route 302 (Cherry Grove Road); thence along the centerline of Township Route 302, North 28 degrees 37 minutes 45 seconds West 150.00 feet to a railroad spike set in the center line of Township Route 302 at common corner of Lot 3 and 2; thence along common boundary line of Lots 3 and 2, North 61 degrees 53 minutes 43 seconds East 323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pin set in line of other lands now or formerly of John Thrush; thence along line of lands now or formerly of John Trush, South 08 degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John Thrush, South 61 degrees 53 minutes 43 seconds West 325.83 feet to the point and place of beginning. Containing 1.176 acres, more or less, and being Lot No. 3 on a certain subdivision plan entitled "Subdivision for John Thrush" dated January 22, 1988, drawn by John R. Kissinger, Registered Surveyor, which plan is recorded in Cumberland County, PA Plan Book 1738, Page2196. BEING the same premises which Amos L. Keefer and Carol A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, Page 2196, granted and conveyed unto Amos L Keefer Jr. and Carol A. Keefer husband and wife. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar ## 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 07-31048 JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC1 PLAINTIFF vs. Amos L. Keefer, Jr. and Carol A. Keefer DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-1019 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Carol A. Keefer 69 Cherry Grove Road Shippensburg, PA 17257 Your house (real estate) at: 69 Cherry Grove Road Shippensburg, PA 17257 39-14-0171-164 is scheduled to be sold at SheriffsSale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $187,463.09 obtained by JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as Trustee of the Structured Asset Securities Corporation, Amortizing Residential Collateral Trust, 2002-BC 1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact: one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 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. 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 717-240-6390. 7. 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. 8. 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. :mss 9. You may be entitled to a share of the money, which was paid for-your_hopse. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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 TELE13HONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 07-31048 ALL the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of public road known and designated as Township Route 302 (Cherry Grove Road); thence along the centerline of"Township Route 302, North 28 degrees 37 minutes 45 seconds West 150.00 feet to a railroad spike set in the center line of Township Route 302 at common corner of Lot 3 and 2; thence along common boundary line of Lots 3 and 2, North 61 degrees 53 minutes 43 seconds East 323.47 feet to an iron pin set in line of land now or formerly of James Hill; thence along line of land now or formerly of James Hill, South 57 degrees 33 minutes 28 seconds East 71.88 feet to an iron pain set in line of other lands now or formerly of John Thrush; thence along line of lands now or :formerly of John Trush, South 08 degrees 12 minutes 52 seconds East 92.95 feet to an iron pin; thence through lands now or formerly of John Thrush, South 61 degrees 53 minutes 43 seconds West 325.83 feet to the point and place of beginning. Containing 1.176 acres, more or less, and being Lot No. 3 on a certain subdivision plan entitled "Subdivision for John Thrush" dated January 22, 1988, drawn by John R. Kissinger, Registered Surveyor, which plan is recorded in Cumberland County, PA Plan Book 1738, Page2196. BEING the same premises which Amos L. Keefer and Carol A. Keefer husband and wife by Deed dated October 17th, 2001 and recorded in the Cumberland County Recorder of Deeds Office on November 8th, 2001 in Deed Book 1738, Page 2196, granted and conveyed unto Amos L Keefer Jr. and Carol A. Keefer husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-1019 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., as Trustee successor in interest to BANK ONE, N.A., as Trustee of the STRUCTURED ASSET SECURITIES CORPORATION, AMORTIZING RESIDENTIAL COLLATERAL TRUST, 2002-BC1, Plaintiff (s) From AMOS L. KEEFER, JR. and CAROL A. KEEFER (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 $187,463.09 L.L. $.50 Interest 12/22/05 to 3/04/09 is -- $3,297.31 Atty's Comm % Due Prothy $2.00 Arty Paid $310.20 Other Costs Plaintiff Paid Date: 11/24/08 rtis R. Long, ro honotar (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 30, February 6, and February 13, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIIIED before me this 3 day of February 13, 2009 Notary NO (ARIAL SEAL DESORA1i A COLLINS Notary Public LCAPLISLE BORO, CUMBERLAND COUNTY ommission Expires Apr 28, 2010 e Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE Z4ePahiot-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: 01 /21 /09 01/28/09 02/04/09 ------------- Sworn to an scribed before tFebruary, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisner, Notary Puble Cby Of Harrisburg, Dauphin County W Convrftsior• Expires Nov. 2d, 2011 Member, Pennsylvania Assnclatlon of Notaries t . i REAL ESTATE SALE NO. 74 Writ. No. 2008-1019 Civil Term JP Morgan Chase Bank, N.A., as Trustee successor in interest to Bank One, N.A., as - Trustee of the Structured Asset Securities _Corporation, _? ._ ... .. ?? ?` i ,.. ? .. ...