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HomeMy WebLinkAbout08-3029GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagors and Real Owners 48 South Terrace Road Wormleysburg, PA 17043 Defendants Term No. O$ - 30619 bvi l Ter" CIVIC. ACTION: MQFI GAGF "fE L NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httn://www.phfa.orgJconsumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionna goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendants are IRENE A. GEKAS, 12703 East Desert Cove Avenue, Scottsdale, AZ 85259 and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS, 12703 East Desert Cove Avenue, Scottsdale, AZ 85259, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On February 18, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1899, Page 1454. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO 1 by assignment of Mortgage August 29, 2007 and recorded on September 18, 2007 as Instrument # 200736274. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2007 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance .................................................................... ........$411,795.36 Interest from 09/01/2007 through 03/06/2008 at 10.5400% ...................$22,355.07 Per Diem interest rate at $118.91 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................$20,589.77 Late Charges from 10/01/2007 to 03/06/2008 ..........................................$1,149.72 Monthly late charge amount at $191.62 Costs of suit and Title Search ....................................................... .$900.00 $456,789.92 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "ininpersonam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $456,789.92, together with interest at the rate of $118.91, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION KheMLY DAWSON , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: FAMMRLYDAWSON, ISTVICE PRESIDENT 48 South Terrace Road Wormleysburg, PA 17043 - IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS E..x.hibit A SCHEDULE C Legal Description Commitment Number: GROS•1006REF ALL that certain piece or parcel of land, situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth of Pennsylvania, morn particularly bounded and described as follows, to wit: BEGINNING at a point on the western line of Greenwood Circle at the Southern Ibm of lands now or late of Harold A Harm and Jane M. Renee: his wife; thence along the western lines of Greenwood Circle, In s southwardly direeftn, a distance of one hundred flSy (150) Net to a point to line of oiler lands now or late of Robert M. Mumma and Barbara.M. Mumma. his wife; thence along said other lands now or late of Robert M. Mwnma and Sarbara M. Murnaw his wlh, in a westwardly direction by a lire parallel to the southern One of Wnds now or late of Harold A Hers and Jane M. Herre, his wft a distance of two hundred frfty (250) feet, more or lass, to a point on the ent m fins of Lot No. 45 on said hereinafter mentioned Plan of Lots, the One of lands now or late of Edwin B. -Romig an d Virginia Rwnig, his wife, thence along said eastern Ins of Lot No. 45 In said hereinafter mentioned Plan of Lots and the eastern line of Lot Nb. 44 on sold Plan, in a northwardly direction, a distance of ens hundred fifty (160) fact to a point on the southemr line of lands now or late of Harold K Harm and Jane M. Herre, his wfte; and thence along said southern Ins of Harold A. Hers and Jans M. Herre, his wife, in an eastwardly direction a distance of two hundred f1Ry (250) feet, more or less, to a point on the western line of Greenwood Circle, the place of SEMNING. BEING the southern one-half (1/2 ) of Lot No. 47 and the northern part of Lot No. 48 an On Revised Plan of Pernrsboro Manor se recorded in the Office for the Recording of Deeds in and for the County of Cumberland In Plan Book 8, Page S. `-, Bi(1899r6 1468 STEWART TITLE I; ®Go??f6ywiile? HOM LLOMS P.O. Banc 9048 Temecula, CA 926589-9048 Send Paymerft To: PO BOX 860694 Dallas, TX 75266-0694 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 7113 8257 1472 5344 519 I 161 111 111116111 1 11 61 11 1111 1611 1611 1 11 11 111 61 11 11 1 11 1 11 11 Constantine Gekas 48 SOUTH TER WORMLEYSBURG, PA 17043-1125 071203-BLQPAl PRESORT First-Class Mail U.S. Postage and Fees Paid WSO MA- ®caft yww HOME LOANS P.O. Box 660694 Dallas. 7X 75266-0694 Send Payments to. PO Box 660694 Dalas, 7X 75266-0694 December 3, 2007 Certified Mail: 7113 8257 1472 5349 5192 Return Reciept Requested Regular Mail Constantine Gekas 48 SOUTH TER WORMLEYSBURG, PA 17143-1125 Account No.: 69014896 Property Address: 48 South Terrace Road Wormleysburg, PA 17043 Current Servicer: Countrywide Home Loans, Inc. 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 tiefaLti'e is provided In the attached paces. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IHEMAP) may be able to help to save your home. This Notice wwlalns how the program worrks To see If HEMAP can help, you must MEET WffH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the ounsy This Notice contains Important legal Information. H you have any questions, representatives at the Consumer Credit Counselling 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 NOTIFICACIGN EN ADJUNTO ES DE SOMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16 N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRtSTAMO 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): Constantine Gekas PROPERTY ADDRESS: 48 South Terrace Road LOAN ACCT. NO.: Wormievsbura. PA 17043 69014896 ORIGINAL LENDER: CURRENT LENDERISERVICER: Countrywide Home Loans. Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YW Mew MIRE MORTGAGE PAYMFNTS • Make your check payable to Co n"cle Horne Loans • Write your akxourcnumber on your check or moray order • Wilke In a y adddonal amounts you are Including (r total is more ? 5000, Please send o? chark) • Dont a2ach your check to the payment coupon • Dont Include comespondence • Dontsend cash W Please WN your accourt nunber m all chacke and mnwPDrdanoo. We may charge you a fee brary payment retuned or ralwao by your financial Irottllbn, subjprsto appn,gbla law Account Number. 880148860 Constantine Gekas Balance Due for charges listed above: $12,066.91 as of 12/03,1007. 48 South Terrace Road BLWA1 Countrywide PO BOX 660694 Dallas, TX 75266.0694 IIr..ICI,I,,,I,Irllrr,ll,rllr,rrllrrlrlrrrlrrllrlrr,lr rlrrlrlllrrrl Pease-P" -rtui idema4m on the ie- Wed ms coupon. Addamal Pmdpal fddaonei Fsuav ah« Check Total 069014896000001206691001206691 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "AC-17% YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a 'Pace-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MErnmr. ab rcT nrr-r to lain ru Tug .?..? 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 spec information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face4o-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision alter it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 48 South Terrace Road Wormleysburg, PA 17043 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following arnounts are now past due Monthly Charges: 10/01/2007 $12,521.16 Late Charges: 10101/2007 $383.24 Other Late Charges Total Late Charges: $0.00 Uncollected Costs: $$0 Partial Payment Balance: !$$15.00 .49) TOTAL DUE: $12,066,91 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not apolicable) 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 $12,066.91, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to E-mail use: Pro Ming yyour a-mail address below will allow us to send you Irfonaatlan an your acmurt Account Number. MUM Constandre Gekas E-mail address Nor ra pat purr p N noepbd I of Md Illow VA be 44M bbbrpd odarrdYO bddmd dug, ado= e11oleir OPN* pdMW a bft by kW. If you VAN as rllerl . b adMm b par adtirdlbd madllAl 0=4 we Vold rp* yar Pill b as him A b oadrrdrlo mow tagawdr of pry raid bdawK 4 emm d,tldrift A bb dlapa ad obr amorarb ya - In e muff we ym ban and 0) b "Ift tiro wYbrdbp pol*d I I - of lair bra. Pb- If ya ralt an SkOmd anrad rppbd b Artrr pgnrrlb Mw Ilan plYafpYrrduafm. Pogddad draab CaarYyrdday poppy b b nd ooap paaMblod dada rabrr aI aft aprrrdbbyabanaaan Wor- - -,*m. Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure an other default b takin the following action within THIRTY 30 DAYS of the date of this letter. Do not use if not aoolicable) IF YOU DO NOT CURE THE DEFAUI T - It you do not cure the default within THIRTY (301 DAYS of the date of this Notice, the lender Intends to exercise Its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (301 DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs cormected 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 H you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - it is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW )CONTACT THE LENDFR- name or Countrywide Home Loans, fnc. Address: P. Q Sox 660694 Dallas, 7X 75266--0694 Phone Number: 1.800-669.0102 Fax Number: 1-805-577-3432 Contact Person: us PTX-36 Attention; Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your RPM RN 7113 8257 1472 5349 5192 property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security Instrument. If you are unable to cure the default on or before January 2, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least'/. of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, lt is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by January 2, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Acorn Fbusing 14 S 13th Street Adams County Interfafth CCCS of Wasism PA . Harrisburg. PA 17104 Housing Authority 40 E High Street 2000 Linrgestown Road 717.213.0150 Gettysburg PA 17325 Harrisburg, PA 17102 , 717.334.1518 888.511.2227 Community Action Commissior Loveship, Inc. Maranathe of Caplial Region 1514 Derry Street 2320 North 51h Street 43 Philadelphia Avenue Harrisburg, PA 17104 Harrisburg, PA 17110 717 232 2207 Waynesboro, PA 17288 717.232.9757 . . 717.762.3285 PHFA 211 North Front Steel Harrisburg, PA 17110 717.780.31340 800.342.2397 ACT 91 NOTICE DATE OF NOTICE: March 24, 2008 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on our 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 to save vour 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 hone number of Consumer Credit Counselin A encies serving your County are listed at the end of this Notice If you have any uestions ou may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (7171780-1869.) 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 any 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 notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada 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. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com 1 Date: March 24, 2008 TO: IRENE A. GEKAS Homeowners Name: IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Property Address: 48 South Terrace Road, Wormleysburg, PA 17043 Loan Account No.: 69014896 Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE, LLC Current Lender/Servicer: COUNTRYWIDE HOME LOANS INC. HOMEOWNERS' 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 PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated 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 2 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 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 fact-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: 48 South Terrace Road, Wormleysburg, PA 17043 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 (a) Monthly payment from 10/01/2007 thru 3/24/2008 (6 mos. at $3,832.36/month) $22,994.16 (b) Late charges from 10/01/2007 thru 3/24/2008 (6 mos. at $191.62/month) $1,149.72 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $24,143.88 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 $24,143.88, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: Attention: Act Letter Department COUNTRYWIDE HOME LOANS INC. c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 HomeRetention@goldbecklaw.com 866-413-2311 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 ri hts to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings 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 rijaht 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 writmiz 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 _four (4) to 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: COUNTRYWIDE HOME LOANS, INC. Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 800-669-4576 Work Out Department: 800-669-0102, 877-744-7691, 800-222-9944 Fax Number: 215-825-6441 Contact Person: HomeRetention@goldbecklaw.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: 5 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: HomeRetention@goldbecklaw.com Phone Number: 800-669-4576 Work Out Department: 800-669-0102, 877-744-7691, 800-222-9944 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 ? D LA 3 <<a w -n C? -n y 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03029 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GEKAS IRENE A 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 GEKAS IRENE A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 48 SOUTH TERRACE ROAD WORMLEYSBURG, PA 17043 GEKAS IRENE A NOT FOUND , as to PER POST OFFICE, DEFENDANT LIVES IN ARIZONA Sheriff's Costs: S a r Docketing 18.00 Service 16.00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sh i f of Cumberland County J .00 L/?LIaP 49.00 OLDBECK MCCAFFERTY MCKEEVER 06/02/2008 Sworn and Subscribed to before me this day of , A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03029 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GEKAS IRENE A 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 GEKAS CONSTANTINE A/K/A DEAN N GEKAS but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT GEKAS CONSTANTINE A/K/A DEAN N GEKAS 48 SOUTH TERRACE ROAD WORMLEYSBURG, PA 17043 PER POST OFFICE DEFENDANT LIVES IN ARIZONA. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 00 21.00 So a NOT FOUND , as to ?- R. Thomas Kline 7LDe i fof Cumberland County BECK MCCAFFERTY MCKEEVER 6/02/2008 Sworn and Subscribed to before me this day of A. D. DEUTSCHE BANK NATIONAL TRUST IN THE COURT OF COMMON PLEAS OF COMPANY AS TRUSTEE FOR THE ?D C"ff, 1; 10 1SYLVANIA HOLDERS OF SOUIDVnW HOME LOAN TRUST 2005-DO1, ASSET- BACKED CERTIFICATES, SERIES 2005-DO1, Plaintiff V. :Civil Action No. 08-3029 Civil Term IRENE A. OCAS and CONSTANTINE Action of Mortgage Foreclosure N. GW[AS a/k/a DEAN GER'AB, Mortgagors and Real Owners, Defendants 1 1 1 DAws' PRSLgwom ON.71CR'iow To cmmhm NOW COME Defendants, Irene A. Gekas and Constantine N. Gekas a/k/a Dean Gekas (`Gekas') to make the following Preliminary objections to the Complaint: I. P"1!M u!En Obi•ctim based on nuie 1029 (a) (6) PeaA"St of prior action 1. Plaintiff filed this action on or about May 13, 2008 in the Cumberland Caunty Court of Common Pleas. 2. Rule 1028(a) (6) of the Pennsylvania Rules of Civil Procedure allow preliminary objections where there is a prior action pending which is related to the instant action. 3. Defendants believe that a prior mortgage foreclosure action has been filed in this court, docket No. 2007-01527, which raises the same claims and is based on the same mortgage. 4. Defendant is not aware that such action has been dismissed and remains as a pending case on this court's docket. 5. Defendants believe that it Would be inappropriate to allow the instant action to proceed with the prior suit still pending without first having been resolved. II'll , Defendants request this Court pursuant to Rule 1028(a)(6) to strike Plaintiff's Complaint and require the Plaintiff to dismiss the prior action before re-filing the above matter. 1. felininazz Obirction ftxw amt to Yale 1019(1) Fail=* to confocaa to Pals of Court 6. Rule 1019(i) states that if a claim is based upon a writing, the pleader shall attach a copy of the writing or if the writing is not available, to set forth the reasons it is unavailable and the substance of the writing. 7. A Loan Modification Agreement was entered into between Constantine Qekas and Countrywide Home Loans, Inc. on September 6, 2007, which amended and supplemented the prior agreement between the parties. 8. Based on the Loan Modification Agreement, Defendants paid $30,000 to Countrywide for past due amounts and for principal. 7. Plaintiff failed to include a copy of that document in its pleading and Defendant believes that such contract is 2 i T material to the agreement between them in addition to the Mortgage. 8. If such an agreement was an agreement related to this lending relationship, it ahould have been attached to Plaintiff's complaint because it was related to plaintiff's claim and may contain available defenses to Defendants. YWRIEW FUNA! , Defendants Irene A. Gekas and Constantine N. Gekas a/k/a Dean Gekas, request this Court pursuant to Rule 1028(a)(2) and 1019(i), to strike the Plaintiff's pleading and require it to attach the September 6, 2007 Loan Modification Agreement to its Complaint, account and give credit for all sums paid to Plaintiff and acknowledge the additional terms that comprise the agreement between Plaintiff and Defendants. Dean Oakes (pro sNe} Irmo GOMM (pro Be) 3 w CXRTIFICMM OF SIKoICR I, Dean Gekas hereby certify that I served a true and correct copy of the foregoing Preliminary Objections on this date by depositing a copy of the same in the possession of the United States mail, first-class, postage prepaid, addressed as follows : Michael T. McKeever, Esquire GOLDBECK MCCAFASRTY & MCKEBVM Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Dat•: /g ? ? .? r ry ? ?. ? c `. C.',. N 'u ? ? ? -? u GOLDBECK McCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-3029 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(x) Plaintiff, by and through its attorney, David B. Fein, Esq., in support of its Motion for Substituted Service, represents as follows: Plaintiff is the holder of a first mortgage upon the premises 48 South Terrace Road, Wormleysburg, PA, 17043, hereinafter, the "mortgaged premises". 2. Defendants, IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS, are the mortgagors and real owners of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, David Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. 4. The last known address of Defendants is 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. 5. The Sheriff has been unable to effect service of the Complaint upon Defendants, at the property, 48 South Terrace Road, Wormleysburg, PA, 17043. Per Sheriff, according to the Post Office, the Defendants live in Arizona. Service was also attempted at the last known address, 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. Per Process Server, there was no service after numerous attempts. On one attempt, Process Server spoke to the son thru the door, refused to open because the parents were not home. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendants. WHEREFORE, Plaintiff prays that the Court enter the attached order' allowing Plaintiff to serve the Complaint upon Defendants, by posting the premises and certified and regular mail to the Defendants' last known address. Respectfully submitted, Da l , Es . ProVest, LLC Affidavit of Good Faith Investigation Client provided information: File Number: 64142FC Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: Constantine N. Property Address: Street: 48 South Terrace Road City: Wormleysburg Gekas a/k/a Dean N. Gekas State: PA Zip 17043 Skip Results: Date of Birth: None Found ProVest File Number. 876439 Verified Dates: As of 3/11/2008 Street: 12703 East Desert Cove Avenue Phone: 480-284-8978 City. Scottsdale State: AZ Zip: 85259 Death Records: As of 3/11/2008, the Social Security Administration has no death record on file for Constantine N. Gekas a/k/a Dean N. Gekas. Social Security Number Search Completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Constantine N. Gekas a/k/a Dean N. Gekas as 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. % of Motor The Pennsylvania Department of Motor Vehicles provided no change for Constantine N. Gekas 6hicle ,F_ r'_ a/k/a Dean N. Gekas from 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. Public Licenses (Pfiot, Search performed provided no information. Real Estate, etc): Voter Registration The County Voters Registration Office has no listing for Constantine N. Gekas a/k/a Dean N. Information: Gekas. National Postal Has no change for Constantine N. Gekas a/k/a Dean N. Gekas from 12703 East Desert Cove Address Search: Avenue, Scottsdale, AZ 85259. Commerft: 770-645-1985: Spoke with relative, Vicki Gekas, verified current address as 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. There is no current active military status. On 3/11/2008, I, Gladis Umanzor being duly swom according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investgation. y Subscribed and to betbre:, me, 1 Notary is #ffiant haw Glades umanzor rri Date. 3/11/2008 MY?tiltlN ProVest, LLC Affidavit of Good Faith Investigation Client provided information: File Number: 64142FC Attorney Firm: GOLDBECK, MCCAFFERTY $ MCKEEVER Subject Name: Irene A. Gekas Property Address: Street: 48 South Terrace Road City: Wormleysburg State: PA Zip 17043 Skip Results: Date of Birth: 11/05/1969 ProVest File Number: 876439 Verified Dates: As of 3/11/2008 Street: 12703 East Desert Cove Avenue Phone: 717-439-8583 City: Scottsdale State: AZ Zip: 85259 Death Records: As of 3/1112008, the Social Security Administration has no death record on file for Irene A. Gekas. Social Security Number Search Completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Irene A. Gekas as 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. DeParknerd of Mohr The Pennsylvania Department of Motor Vehicles provided no change for Irene A. Gekas from Vehicle Records: 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. Public Licenses (PIK Search performed provided no information. Real Estate, etc): Voter Registration The County Voters Registration Office has no listing for Irene A. Gekas. Information: National Postal Has no change for Irene A. Gekas from 12703 East Desert Cove Avenue, Scottsdale, AZ Address Search: 85259. Comments: 770-645-1985: Spoke with relative, Vicki Gekas, verified current address as 12703 East Desert Cove Avenue, Scottsdale, AZ 85259. There is no current active military status. On 3/1112008, I, Gladis Umanzor being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investgation. Subscribed and * worn to before', rite, JJ Notary "ic At iam hawe Gtadis Umanaw Date: 3/11/2008 M1P?iICW>ll Via" SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03029 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GEKAS IRENE A 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 GEKAS IRENE A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT NOT FOUND , as to GEKAS IRENE A 48 SOUTH TERRACE ROAD WORMLEYSBURG, PA 17043 PER POST OFFICE, DEFENDANT LIVES IN ARIZONA Sheriff's Costs: S Docketing 18.00 Service 16.00 Not Found 5.00 Surcharge 10.00 .00 49.00 Sworn and Subscribed to before me this day of A. D. R. Thomas Kline Sh i f of Cumberland County OLDBECK MCCAFFERTY MCKEEVER 06/02/2008 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03029 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GEKAS IRENE A ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named GEKAS CONSTANTINE A/K/A DEAN unable to locate Him in his COMPLAINT - MORT FORE , the within named DEFENDANT GEKAS 48 SOUTH TERRACE ROAD NOT FOUND , as to GEKAS CONSTANTINE A/K/A DEAN N WORMLEYSBURG, PA 17043 PER POST OFFICE DEFENDANT LIVES IN ARIZONA. Sheriff's Costs: Docketing Service Not Found Surcharge So a s• / 6.00 .00 5.00 R. Thomas Kline 10.00 She i f of Cumberland County .00 21.00 LDBECK MCCAFFERTY MCKEEVER 06/02/2008 Sworn and Subscribed to before me this day of A. D. -,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and DEFENDANT N GEKAS but was bailiwick. He therefore returns the Page 1 of 1 9uNIYED 5Mf Ei s POML SERWE. Detail COA Information Restricted Information I I Ionic Logout Current COA Information (PCOA) Exclude COA Move FP Request: Added Effective 10/23/2007 Or* 'g 0729590000063620 Created 10/24. Type: Date: Trans: On: Name: GEKAS DEAN Adds 48 SOUTH TER;WORMLEYSBURG, PA 17043-1125-48 ANe 12703 E DESERT COVE AVE;SCOTTSI ALE, AZ 85259-4319-03 COARS History Record I Move FP Type: Request: Added Change ICOA Reason: Effective 10/23/2007 Date: 0"9 0729590000063620 Trans : Created 10/24/2007 00:04 On: Status: Active Last modified ICOA by: Machine 9000 Primary: GEKA048 Maint. Added Function: Last Update: 10/24/2007 Old CRID• 0006 New CRID R033 No Name: GEKAS DEAN Old CRID: C006 Old 48 SOUTH TER Address: WORMLEYSBURG, PA 17043-1125-48 New CRID: R033 New 12703 E DESERT COVE AVE Address: SCOTTSDALE, AZ 85259-4319-03 Copyright©2002-2008, Siemens. All Rights Reserved ( v3.2.0 Build 1084 ) coaweb-08 05/30/2008 02:45:12 PM https://coars.usps. gov/pls/usps/coa_search.detail?p__coa__id=200710002756225 &p_show_c... 5/30/2008 ProVest, LLC - New York 93 E. Main St Bay Shore, NY 11706 (631)666-6t6g IN THE COMMON PLEAS COURT OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DOI; et seq. Plaintiff, Against IRENE A. GEKAS, CONSTANTINE N. GEKAS A/K/A DEAN N. GEKAS; et al. Defendants, GOLDBECK, MCCAFFERTY & MCKEEVER MELLON INDEPENDENCE CENTER 701 MARKET STREET SUITE 5000 PHILADELPHIA, Pennsylvania 19106 Court Case No.: 08-3029 AFFIDAVIT OF SERVICE et& UW pT being duly sworn, deposes and says: that deponent is not a party to this action, is over 18 years of age and resides in the State of AZ. That on at at 12703 East Desert Cove Avenue Scottsdale, AZ 85259 deponent served the within COMPLAINT bearing court case number 08-3029 on CONSTANTINE N. GEKAS AIKIA DEAN N. GEKAS; et al. INDIVIDUAL SUBSTITUTE a CORPORATE DESCRIPTION NON-SERVICE by delivering thereat a true copy of each to said defendant personally, deponent knew said person so served to be the person described as said defendant therein. (S)He identified (her) himself as such. By delivering thereat a copy of each to a person of suitable age and discretion. That person was also asked by deponent whether said premises was the defendant's dwelling home and the reply was affirmative. A corporation, by delivering thereat a true copy of each to , personally; deponent knew said so served to be the corporation described as the named defendant and knew said individual to be the AUTHORIZED AGENT thereof. Deponent describes the individual served to the best of deponent's ability at the time and circumstances of service as follow: Sex Skin Color Hair Color Ag?A__pnc) Height LAprx) Weight (Aptx) The defendant, CONSTANTINE N. GEKAS A/K/A DEAN N. GEKAS, does not reside at this address as per Attempt l: ?- Z7-0(g Attempt 2:5- ! -f o Attempt 3: ?4 - 40 s/ f4 ?? s c4- 4 ? 0" 11r.-C, W'qp?'t bark,., SERVICE / 6"Cl ', rl?&$ '? -to I asked the person spoken to whether the defendant was in aW c m litarservice of the United States or of the State of Arizona in any capacity whatever and received a negative reply. The source of my information and the grounds of my belief l aver that th endant i of in the military service of Arizona or of the United States as that term is defined in either the State or Federal sta tutes. SWORN TO BEFORE ME ON /_ < C- . n 0 Server Signature Date LICENSE # No - FILE # 64142FC R, owl CASE ID # 1005797 Commission Expiration WWy'1Ne - M?? oftwpuumg bpaG 12 aS??a ? l3T?? ProVest, LLC - New York 93 E. Main St Bay Shore, NY 11706 (631) 666-6168 IN THE COMMON PLEAS COURT OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1; et seq. Plaintiff, GOLDBECK, MCCAFFERTY & MCKEEVER MELLON INDEPENDENCE CENTER 701 MARKET STREET SUITE 5000 PHILADELPHIA, Pennsylvania 19106 Court Case No.: 08-3029 Against AFFIDAVIT IRENE A. GEKAS, CONSTANTINE N. GEKAS A/K/A DEAN N. OF SERVICE GEKAS; et al. Defendants, JtUhV ? 5440 being duly swom, deposes and says: that deponent is not a party to this action, is over 18 years of age and resides in the State of AZ. That on GEKAS; et al. INDIVIDUAL a SUBSTITUTE a CORPORATE DESCRIPTION NON- ERVICE MILITARY SERVICE at 12703 East Desert Cove Avenue Scottsdale, AZ 85259 deponent served the within COMPLAINT bearing court case number 09-3029 on IRENE A. by delivering thereat a true copy of each to said defendant personally, deponent knew said person so served to be the person described as said defendant therein. (S)He identified (her) himself as such. By delivering thereat a copy of each to a person of suitable age and discretion. That person was also asked by deponent whether said premises was the defendant's dwelling home and the reply was affirmative. A corporation, by delivering thereat a true copy of each to , personally; deponent knew said so served to be the corporation described as the named defendant and knew said individual to be the AUTHORIZED AGENT thereof. Deponent describes the individual served to the best of deponent's ability at the time and circumstances of service as follow: Sex Skin Color Hair Color Age_(Arx) Hei ht AArx? Weft A rx The defendant, IRENE A. GEKAS , does not reside at this address as per Attempt 1: S 27_ d G) Attempt 2: - 0 C5 Attempt 3: 6 w ?t -0 1 ???? ?e }}??s> t- ootive r r??Sc?ol .?Th ° rv C.1 hts ot? Nv ar+,st,,,#r- ?el ? o o+r ar?.'{-i I asked the person spoken to whether the defendant was in ac military service o the United States or of the State of Arizona in any capacity whatever and received a negative reply. The source of my information and the grounds of my belief I aver that the defer is not in military service of Arizona or of the United States as that term is defined in either the State or Federal statutes. SWORN TO BEFORE ME ON / D Server Signature Date LICENSE # FILE # 64142FC of CASE ID # 1005797 Commission Expiration ?. Yrum - "W"" CRAW Rip- - 0113VA12 «tw ,?«? ?„ `? v u? +?r . ;'?. GOLDBECK WCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 VERIFICATION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-3029 I, David B. Fein, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. BY: David . Fein, Esq. GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024" VS. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 No. 08.3029 MEMORANDUM OF LAW IN S PORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendants, which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants, by posting the premises and certified mail and regular mail to the Defendants' last known address. Respectfully submitted, IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY d B. Fein, Es GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Sheet Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 CERTIFICATE OF SERVICE Of Cumberland County No. 08-3029 David B. Fein, Esq., does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants, this ? day of 1' .t prepaid. IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 BY 2008, by first class mail, postage 4ad B. OFF Esq IN THE COURT OF COMMON PLEAS 4.? ? ti _? CWt9 < ...-? `? ? ytC' N . ; .,m? , ... -? r' ?; C:. -?? ?...,? ?.t?7 ,. ?;,, -? JUL 0 32008 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 08-3029 ORDER AND NOW, this day of 1.11,2008, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants, by posting a copy of the Complaint upon the premises 48 South Terrace Road, Wormleysburg, PA, 17043, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 12703 East Desert Cove Avenue, Scottsdale, AZ 85259, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants, by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE COURT: I)istn'bution list: VUichael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 / IRENE A. GEKAS, 12703 East Desert Cove Avenue Scottsdale, AZ 85259 n CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS, 12703 East Desert Cove Avenue Scottsdale, AZ 85259 c do GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 THOMAS I. PULEO ATTORNEY I.D. #27615 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DOI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagors and Real Owners 48 South Terrace Road Wonnleysburg, PA 17043 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3029 Civil AMENDED COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A LISTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.aov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orWconsumers/homeowners/real.aWx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. AMENDED COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendants are IRENE A. GEKAS, 12703 East Desert Cove Avenue, Scottsdale, AZ 85259 and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS, 12703 East Desert Cove Avenue, Scottsdale, AZ 85259, who are the mortgagors and real owners of the mortgaged premises hereinafter described. On February 18, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1899, Page 1454. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 by assignment of Mortgage August 29, 2007 and recorded on September 18, 2007 as Instrument # 200736274. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. On September 6, 2007, the mortgagors executed a Loan Modification Agreement which amended the terms of the aforesaid mortgage. A true and correct copy of the said Loan Modification Agreement is attached hereto, made a part hereof and marked Exhibit "A". 5. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "B" ("Property"). 6. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2007 and each month thereafter and by the terms of the Mortgage, as modified, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 7. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$411,795.36 Interest from 09/01/2007 through 03/06/2008 at 10.5400% ...................$22,355.07 Per Diem interest rate at $118.91 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................$20,589.77 Late Charges from 10/01/2007 to 03/06/2008 ..........................................$1,149.72 Monthly late charge amount at $191.62 Costs of suit and Title Search ......................................................................$900.00 $456,789.92 8. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 9. Plaintiff is not seeking a judgment of personal liability (or an "in nersonam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 10. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "C". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $456,789.92, together with interest at the rate of $118.91, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the t s of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of> %edrtgage and Sheriff' Sale of the Property. By: Voles GOLD CK McCAFF RTY & McKEEVER BY: MICHAEL T. MCKEEVER., ESQUIRE THOMAS I. PULED, ESQUIRE, ATTORNEYS FOR PLAINTIFF EXHIBIT "A" ,r HomeSaver - Workout MFA Change R! ?II?I?IIif ? Workout Type: Modification 610 069014896 LMA 001 001 Loan1WO ID: 69014896-0 1 Date Printed: 10102/2007 Borrower 1: CONSTANTINE %Sed Borrower 2: l Reclass: No 2 4 2007 Voluntary Funds: $0.00 Reinstatement Fig: $0.00 Attorney Fees: $0.00 Bankruptcy Fees: $0.00 Miscellaneous Fees: $0.00 - Loan Terms Current Data: Principal Balance: $392,085.28 P&I Payment: $2,532.46 Paid To Date: 09/01/2006 First Payment Date: 04/2005 Loan Type/Subclass: 67 Maturity Date: 03/2035 Tenn of Loan: 360 Remaining Term: 342 Interest Rate: 6.540 Branch/Source Code: 601115019 Service Fee Rate: .500 Original Principal: $399,000.00 I Change Requested: $411,970.77 $3,832.35 09/01/2007 04/01/2005 67 03/01/2035 360 330 10.540 601/15019 .500 $411,970.77 .-%&J",Va,WW r1nwINai %-Jurnrnary- Debit Principal to Credit Escrow: Debit Principal to Credit Partial: rib Vr / el $0.00 Capitalized interest: $0.00 Capitalized Fees: New Principal: Anticipated Principal: $19,885.49 $0.00 $411,970.77 $392,085.28 AL_ _I_ T_ _____ ?ne?K rcequesi Amount to Escrow: $0.00 Amount to Partial: $0.00 Amount to Fees Due: $0.00 Check Amount: $0.00 Modification Information Status: MarIDr?P k1, 0jille Completed Date: . Id h2 r+NN1 vvana Approved By: Dante pasquini Date: WT 17 Manager Approval: __ Lisette N19yt,,S Date: 60 Al- Z 6 7 frm p 03 O I tD pl r? ^t z r 0 ?Aa 'gyp 3 m " i ? A ? ? •n ? ?C qT A ? ? ? u? ? n C o ro? ? ? e? ?u a v 3 a r o °. N J+ N N+ i ?? i p ?Q+? oo?yoo oN° o$ ao M7 Q p°° iA a 0 p p a c p Sn g °° O 'O M ? .03ga q M 1?? 9 e 41 N ?o a • A N J T m O 0 " o y? w N r Vi .yp w a VO1 W S .,{ o O 4 `C?\? a 0.. r r s° yam: 1-0 1-0 " x C..egpp?\?q ? tp ?j ID p y ?n v Z A 00 Q A m m '?? ' Z J„ D O 1 //? V/ N 0 7 O, W O v v w A o °•x n Y? N ut O ? G g Q R V A '0 C -qi O "'? r Z A Z A A S S? 7t i '^ 9 c i 01 N N N ? .i + p -i ? y? q y .y? M N? w N N? Q to ??i? ° p O .i 0? Y? ZA .`C?? A t`q??' 000 411 pp? '? r?qp Op i0 ? ,J? a C J Sol 0 ° PN } 0 ? W OC ? o ? ? ? ? O ?, ? ° p O N 'twn y W y ? ? ? V y ? b J IG Q ? g p w c,ro ?w m c m? w o 0° v , N 0 g O ? ym A ? m w 121 ? o Q g?g y 'TI o id w C A G O a C. 0 L 3 9 x 4 Countrywide Home Loans, Inc. Attie WORKOUT DEPARTMENT, SV-65 450 AMERICAN STREET SIMI VALLEY, CA 93065 PREPARED BY: Tricia Helf Loan * 69014896 ----------FOR INTERNAL USE ONLY- LOAN MODIFICATION AGREEMENT (Adjustable Interest Rate) This Loan Modification Agreement ('Agreement"), made this eth day of September 2007, between CONSTANTINE GEKAS, and Countrywide Home Loans, Inc. (Lender), amends and supplements (1) the Mortgage, Deed of Trust, or Deed to Secure Debt (the Security Instrument), dated the 18th day of February 2005 and in the amount of $399,000.00 and (2) the Note bearing the same date as, and secured by, the Security Instrument, which covers the real and personal property described in the Security Instrument and defined therein as in the 'Property', located at 48 SOUTH TERRACE ROAD, WORMLEYSBURG, PA 17043. The real property described being set forth as follows: SAME AS IN SAID SECURITY INSTRUMENT In consideration of the mutual promises and agreements exchanged, the parties hereto agree as follows (not withstanding anything to the contrary contained in the Note or Security Instrument): 1. As of the 1st day of October 2007, the amount payable under the Note or Security Instrument (the "Unpaid Principal Balance") is U.S. $411,970.77 consisting of the amount(s) loaned to the borrower by Lender and any interest capitalized to date. The Borrower promises to pay the Unpaid Principal Balance, plus interest, to the order of the Lender. Interest will be charged on the Unpaid Principal Balance from the 1 st day of September 2007. The Borrower promises to make monthly payments of principal and interest of U.S. $3,832.35 beginning on the 1st day of October 2007. The interest rate and monthly payment will adjust in accordance with the Note, Adjustable Rate Rider ahd any other loan document that is affixed to or incorporated into the Note and Rider and provides for, implements or relates to any change or adjustment in the interest rate and monthly payment amount under the Note. If on the 1 st day of March 2035 (the "Maturity Date"), the Borrower still owes amounts under the Note and Security Instrument, as amended by this Agreement, the Borrower will pay these amounts in full on the Maturity Date. 3. The Borrower will make such payments at 450 American Street, Simi Valley, California 93065 or at such other place as the Lender may require. 4. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in the Borrower is sold or transferred and the Borrower is not a natural person) without the Lender's prior consent, the Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. If the Lender exercises this option, the Lender shall give the Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which the Borrower must pay all sums secured by this Security Instrument. if the Borrower fails to pay these sums prior to the expiration of this period, the Lender may Invoke any remedies permitted by the Security Instrument without further notice or demand on the Borrower. 5. The Borrower also will comply with all other covenants, agreements, and requirements of the Security Instrument, including withoutiimitation, the Borrower's covenants and agreements to make all payments of taxes, Insurance premiums, assessments, escrow items, impounds, and all other payments that the Borrower is obligated to make under the Security Instrument. CHL Low# 69014896 Page t of 2 6. Nothing in this agreement shall be understood or construed to be a satisfaction or release in whole or in part of the Note and Security Instrument Except as otherwise specifically provided in this Agreement, the Note and Security Instrument will remain unchanged, and the Borrower and Lender will be bound by, and comply with, all terms and provisions thereof, as amended by this Agreement. As evide their signatures below, the Borrower and the Lender agree to the foregoing. CONSTANTINE GEMS Dated ?u??7 CoMMONwEALTH OF PENNSYTLVawn v x.1 1 Aj 21 1+,, 1 NOterfal SEeI . .'3J?J W`? .4???` ?/?p r ?M ?'MII($ai011 r.`Y"as DBC. ?6, ?Q$ GfWNI?°OF C [J? Member, Pennsylvania gasociatton of Ndarlea On Q -2.?2• ZjYQ before me, ? {{ 1 L ? L l Ci L Notary Public, personally appeared personally known to me (or proved to me on the basis of satisfactory evidence) to be the person (s) whose name (s) istare subscribed to the within Instrument and acknowledged me that he/she/they executed the same in his/her/their authorized capacity (ies), and that by his/her/their signatues (s) on the instrument the person (s), or entity upon behalf of which the person (s) acted, executed the instrument VVITNESS my band and official sealA n Signature Countrywide Home Loans, Inc. By. !riz _ Dated 3 CHL Load 69014896 Page 2 of 2 EXHIBIT "!3 9 Commitment Number: GR05-1006REF ALL that certain piece or parcel of land, situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western line of Greenwood Circle at the Southern line of lands now or late of Harold A. Herre and Jane M. Herre, his wife; thence along the western line of Greenwood Circle, in a southwardly direction, a distance of one hundred fifty (150) feet to a point to line of other lands now or late of Robert M. Mumma and Barbara.M. Mumma, his wife; thence along said other lands now or late of Robert M. Mumma and Barbara M. Mumma, his wife, in a westwardly direction by a line parallel to the southern line of lands now or late of Harold A. Herre and Jane. M. Herre, his wife,. a distance of two hundred fifty (250) feet, more or less, to a point on the eastern line of Lot No. 45 on said hereinafter mentioned Plan of Lots, the line of lands now or late of Edwin B.'Romig an d Virginia Romig, his wife; thence along said eastern line of Lot No. 45 In said hereinafter mentioned Plan of Lots and the eastern line of Lot No. 44 on said Plan, in a northwardly direction, a distance of one hundred fifty (150) feet to a point on the southern line of lands now or late of Harold A. Herre and Jane M. Herre, his wife; and thence along said southern line of Harold A. Herre and Jane M. Herre, his wife, In an eastwardly direction a distance of two hundred fifty (250) feet, more or less, to a point on the western line of Greenwood Circle, the place of BEGINNING. BEING the southern one-half (112 ) of Lot No. 47 and the northern part of Lot No. 48 on the Revised Plan of Pennsboro Manor as recorded In the Office for the Recording of Deeds In and for. the County of Cumberland In Plan Book 3, Page 6. EXHIBIT "G„ ®cw HOPE wwws P.O. Box 9048 Temecula, CA 92589-9048 Send Payments To: PO BOX 660694 Dallas, TX 75266-0694 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 2206238558 Constantine Gekas 48 SOUTH TER WORMLEYSBURG, PA 17043-1125 071203-OLOPAI PRESORT First-Class Mail U.S. Postage and Fees Paid WSO ' s B r'F HOME LOANS P.O. Box 660694 Dallas, 7X 75266-0694 Send Payments to: PO Box 660694 Dallas, TX 75266-0694 December 3, 2007 Constantine Gekas 48 SOUTH TER WORMLEYSBURG, PA 17043-1125 Account No.: 69014896 Property Address: 48 South Terrace Road Wormleysburg, PA 17043 Current Servicer: Countrywide Home Loans, Inc. 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 EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. TMs 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. This Notice contains Important legal Information. H you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIbN EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VMENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCC1 Nd INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGBBLE 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): Constantine Gekas PROPERTY ADDRESS: 48 South Terrace Road WormleysbMM, PA 17043 LOAN ACCT. NO.: 69014896 ORIGINAL LENDER: CURRENT LENDERISERVICER: Countrywlde Home Loans, inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY B ELIGIBLE OR FINANCIAL ASSISTANCE YMHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS • Make your check payable to Countrywide Home Loans • Write yotr axoutt number on your check or moray order • Write In ahy additional amounts you are indudng (tt trial is more than $5000, please send lefhfled check) • Dont attach your check to the payn ant coupon • ude correspondence • Dont send rash Please write your account number on all decks and correspondence. We may charge you a fee forarry parnerd rdumed or reladetl byyourfinanctal institution, subled to Applicable lay. Accourn Number. 890148880 Constantine Gekas Balance Due for charges listed above: $12,066.91 as of 1210312007. 48 South Terrace Road Countrywide PO BOX 660694 Dallas, TX 75266-0694 Phase update s l nbimatbn on the ate side d the coupon. Addtional Principal BLOPAt Addinnal EsaoH char .;fi=x II..,I.IrIr„I.Irllrrrllr,Il..r,Ilrrlrlrrrlr,llrlrrrl„Irrl,lllrrrl Check Taal 069014896000001206691001206691 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "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 forth at the end of this Notice. It is only necessary to schedule one face4o-face meeting. Advise your lender your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for spec information about the nature of your defauft.) 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 All out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. 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.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 48 South Terrace Road Wormleysburg, PA 17043 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 10/01/2007 Late Charaes: 10/01/2007 Other Late Charges Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not aoolicable) $12,521.16 $383.24 $0.00 $15.00 ($852.49) $12,066.91 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 $12,06621, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (301 DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to E-mail use: Provld?ingyou?r__ a mal address below will allow us ro send you irfornabon on your accourt Account Number !WNlN Coreramme, Gekas E-mall address Nor aw pad y- pV-ft M noapbd peerwlb ef prI % 'owl' Wwat we be q*W b to b od oubb oft bobinod dw, who aMwYs OWN* paW1111 1 CF 111Y IAW. 1 you vftg m Waawd in Adam b your adndlid waltily p7-K rw M ** yar polyolMWlb 0 ft- 10 b aWlb4ardYWIt moellfr pWemrrb of I 1 4 - ad tdaWwl (ID aamar dotidrWrdoo (1) bb doMa and 01ra anarnb ya on In oomaelm Wo you bin Will M b m*w 1w abbndnl pWtadpal lalroa of yaw ham. Pbora Wga* 9 YON +ard al adam l angst rppbd b A*" poprlorlb ratio M Iabaipalrad00bn. Pa MW dwdai c=ftVlda'a poioy b b nd WOW paakbtod daft uiM W s tte* aped bby a loan 0orna11ft or b1 ddm. 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. Countrywide at P.O. Box 660694, Dallas, TX 75266-0694 You can cure any other default by takina the foliowina action within THIRTY (301 DAYS of the date of this letter. (Do not use it 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 oft the mortgage I. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY 1301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (301 DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth In this notice will restore your mortgage to the same position as H you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans, inc. Address: P. O. Box 660694 Dallas, YX 73266--0694 Phone Number: 1-800-669-0402 Fax Number: 1-803-377-3432 Contact Person: MS PYX-36 Attention. Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, ender upon and conduct an inspection of your fib 2206238558 property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. if you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security instrument. If you are unable to cure the default on or before January 2, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 1/2 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, it your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by January 2, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence. H you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Aram Housing Adams County Interfaith CCCS of Western PA 14 S. 131h Street Housing Authority 2000 Linglestown Rued Harrisburg, PA 17104 40 E High Street Harrisburg, PA 17102 717.213.0150 Gettysburg, PA 17325 888.511.2227 717.334.1518 Community Action Commission Loieship, Inc. Maranathe of Captial Region 2320 North 5th Street 43 Philadelphia Avenue 1514 Derry Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17104 717.232.2207 717.762.3285 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 ACT 91 NOTICE DATE OF NOTICE: March 24, 2008 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 to save your home This Notice explains how the program works. To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you 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 Agent 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 any 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 continuer viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada 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. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com 1 Date: March 24, 2008 TO: IRENE A. GEKAS Homeowners Name: IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Property Address: 48 South Terrace Road, Wormleysburg, PA 17043 Loan Account No.: 69014896 Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE, LLC Current Lender/Servicer: COUNTRYWIDE HOME LOANS INC. HOMEOWNERS' 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 PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated 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 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 fact-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: 48 South Terrace Road, Wormleysburg, PA 17043 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 10/01/2007 thru 3/24/2008 (6 mos. at $3,832.36/month) $22,994.16 (b) Late charges from 10/01/2007 thru 3/24/2008 (6 mos. at $191.62/month) $1,149.72 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $24,143.88 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 $24,143.88, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: Attention: Act Letter Department COUNTRYWIDE HOME LOANS INC. c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 HomeRetention@goldbecklaw.com 866-413-2311 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 lender brings 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 four (4 to 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: COUNTRYWIDE HOME LOANS, INC. Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 800-669-4576 Work Out Department: 800-669-0102, 877-744-7691, 800-222-9944 Fax Number: 215-825-6441 Contact Person: HomeRetention@goldbecklaw.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY 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. Contact: HomeRetention@goldbecklaw.com Phone Number: 800-669-4576 Work Out Department: 800-669-0102, 877-744-7691, 800-222-9944 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION CoMbA ()F IHE C ApITAI. RFCi10N 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 1.3.2-10-CAd k Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 VERIFICATION I, Vi Q-bk , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Amended Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: I CAS Irene A. Gekas and Constantine N. Gekas a/k/a Dean N. Gekas 48 South Terrace Road Wormleysburg, PA 17043 `. i r > ._ro (. "'i'i <, a ? r _ 7"- _? :c c?; r ;; ?` .> 1`"T GOLDBECK cCAFFERTY & McKEEVER A Professional Corporation By: Thomas I. P leo, Esquire Attorney I.D. #: 7615 Suite 5000 - Me Ion Independence Center 701 Market Stre t Philadelphia, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE B NATIONAL TRUST COMPANY AS USTEE FOR THE HOLDERS F SOUNDVIEW HOME LOAN TRUST 2005-DO1 , ASSET-BACKED CERTIFICATES, ERIES 2005-DO1 7105 Corporate ve PTX C-35 Plano, TX 75024 Plaintiff VS . IRENE A. GEKA and CONSTANTI E . GEKAS a/k/a DEAN N. G KAS 48 South Terrace oad Wormleysburg, P 17043 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW AMENDED ACTION OF MORTGAGE FORECLOSURE Term No. 08-3029 AFFIDAVIT OF SERVICE I hereby Oertify that Plaintiff's Amended Complaint relative to the above captioned matter was served pursuant to Rule 440 by first class mail on pro se Defendants, IRENE A. GEKAS & CONMNTINE N. GEKAS a/k/a DEAN N. GEKAS at 12703 East Desert Cove Avenue, Scottsd4le, AZ 85259 on July 22, 2008. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsifications to authorities. Date: GOLDBE , McCAF & McKEEVER mas I. Puleo, squire Attorney for Plaintiff N C C=k ° xr. c'S .? ? ;? ray GOLDBECK WCAFFERTY & WKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3029 Vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER T By Michael T. McKeever, Esq. Attorney for Plaintiff t? o ? o ? ' , ° ` ? ? J . ?'' ?- - .4? ? : ?.. -? . ? cna . ? _:_ ?, - .. r- .x . _ T? --'7 GOLDBECK McCAFFERTY ,& McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I, ASSET-BACKED CERTIFICATES, SERIES 2005- DOI 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3029 CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER ESQUIRE hereby certifies that on fiuia he did serve upon Defendant CONSTANTINE N. GEKAS aWa DEAN N. GEKAS a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated July 7, 2008. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, 'T" -i- I?A GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE r? ?° ?'°' -r?:s?s ?,T, ? ? ?s? ., , ` ?:? -? - - _ ?:? ? ?, ? ?, -t ,? GOLDBECK WCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005- DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE VS. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) Term No. 08-3029 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: , GOLDBECK McCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF Cl) C7- ` N w , 'r-t SHERIFF'S RETURN - REGULAR CASE NO: 2008-03029 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GEKAS IRENE A ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GEKAS IRENE A the DEFENDANT , at 0015:25 HOURS, on the 13th day of August , 2008 at 48 SOUTH TERRACE ROAD WORMLEYSBURG, PA 17043 by handing to POSTED PER COURT ORDER @ 48 S. TERRACE DR, WORMLEYSBURG, PA 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 Posting Sworn and Subscibed to before me this So Answers: 18.00 16.00 .00 r 10.00 R. Thomas Kline 6.00 50.00 08/14/2008 GOLDBECK MCCAFFERTY & K VER "Jos 8I p? By: day Deputy Sheriff of , A. D. SHERIFF'S RETURN - REGULAR ... CASE NO: 2008-03029 P COMMONWEALTH OF PENNSYLVANIA: -r- COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS GEKAS IRENE A ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GEKAS CONSTANTINE A/K/A DEAN N GEKAS the DEFENDANT , at 2105:00 HOURS, on the 3rd day of September, 2008 at 48 SOUTH TERRACE ROAD WORMLEYSBURG, PA 17043 by handing to POSTED AT 48 S TERRACE RD PER COURT ORDER 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 16.00 Posting 6.00 Surcharge 10.00 .00 ?/b y/o C?- 50.00- Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 09/04/2008 GOLDBECK MCCAFFERTY MCKEEVER By puty S eri f A.D. GOLDBECK McCAFFERTY & McKEEVER BY: THOMAS I. PUELO, ESQUIRE Attorney I.D. #27615 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- 001, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 Plaintiff VS. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagors) and (Record Owners) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) ATTORNEY FOR PLAINTIFF In the Court of Common Pleas of Cumberland County Civil Action - Law Action of Mortgage Foreclosure Term No. 08-3029 SUGGESTION OF BANKRUPTCY TO THE CLERK OF THE COURT: Please take note that Defendant IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS filed a Chapter 13 Bankruptcy on July 15, 2008 in the United States Bankruptcy Court for the District of Arizona at Case Number 08-08683. Accordingly, the above captioned matter should be deferred until the proceedings. TY & McKEEVER BY: Thomas I. Puelo, Esquire Attorney for Plaintiff JA CERTIFICATE OF SERVICE Thomas I. Puelo, Esquire, hereby certifies that on he did serve true and correct copies of the within Suggestion of Bankruptcy by first class mail, postage pre-paid upon the following: IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 GOLDBECK, M9eA0F,FgWFY & McKEEVER BY: 'Puuelo, Esquire for Plaintiff t i-{; !? rt r t.7 w`r 14 ~ W GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Thomas I. Puleo, Esquire Attorney I.D. # 27615 Suite 5000 - Mellon Independence Center 701 Market Street ATTORNEY FOR PLAINTIFF Philadelphia, PA 19106-1532 215-627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 08-3029 vs. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagors and Record Owners 48 South Terrace Road Wormleysburg, PA 17043 PRAECIPE TO REACTIVATE CASE n ^a C? N m ?? C7 '. C Please be advised that the Bankruptcy case filed on July 15, 2008 at Case Number 08- 08683 in the U.S. Bankruptcy Court District of Arizona was dismissed on September 15, 2008 and the case was terminated on September 9, 2009. As such, the above captioned matter should no longer be in deferred status. GOLDBECK NWAFFERTY EVER BY. omas I. Pule, Esquire Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER ,Professional Corporation By: Thomas I. Puleo, Esquire Attorney I.D. # 27615 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagors and Record Owners 48 South Terrace Road Wormleysburg, PA 17043 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 08-3029 CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of Praecipe to Reactivate Case was sent by first class mail, postage pre-paid, upon the following on the date listed below: IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 GOLDBECK McCAFFERTY-4 McKEEVER ThorP'as I. Puleo, Attorney for Plai: Date: March 25, 2010 GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation ATTORNEY FOR PLAINTIFF By: Thomas I. Puleo, Esquire Attorney I.D. #: 27615 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DOI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 Defendants AFFIDAVIT OF SERVICE Term cc N No. 08-3029! ? a = - -ter c7 .a I hereby certify that Plaintiff's Amended Complaint relative to the above captioned matter was served pursuant to Rule 440 by first class mail on pro se Defendants, IRENE A. GEKAS & CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS at 12703 East Desert Cove Avenue, Scottsdale, AZ 85259 on March 31, 2010. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsifications to authorities. GOLDBEC AFFERT EEVER Date: A kAo Thomas. Puleo, Esqui Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW AMENDED ACTION OF MORTGAGE FORECLOSURE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ????tir ai Zumbrrf$?? OFFI[CE OF THE SHERIFF FILE Jody S Smith Chief Deputy Edward L Schorpp Solicitor Deutsche Bank National Trust Company vs. Constantine N Gekas (et al.) 2Of0 f,'t27 P f2: CUP>r :- t Case Number 2008-3029 SHERIFF'S RETURN OF SERVICE 05/24/2010 07:33 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 24, 2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Constantine N. Gekas a/k/a Dean N. Gekas, pursuant to order of court by posting the premises located at 48 South Terrace Road, Wormleysburg, Cumberland County, Pennsylvania 17043 with a true and correct copy according to law. GERALD WORTHING , DEPUTY 05/24/2010 05:33 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 24, 2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Irene A. Gekas, pursuant to order of court by posting the premises located at 48 South Terrace Road, Wormleysburg, Cumberland County, Pennsylvania 17043 with a true and correct copy according to law. GERALD WORTHINGT , DEPUTY SHERIFF COST: $70.40 May 25, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) GountySUIte Sheriff, ieieosoff. Inc. RL GOLDBECK McCAFFERTY & MCKEEVER AT BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 200 0 MAY 28 h i U SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 PE;` lAv: ' `i ,';r sn (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO 1, ASSET-BACKED CERTIFICATES, SERIES 2005- DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) CERTIFICATE OF SERVICE Term No. 08-3029 MICHAEL T. MCKEEVER ESQUIRE hereby certifies that on - s he did serve upon Defendant(s) IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated July 7, 2008. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, Vkl?,lk4 /_ /?" IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE PPI W Our File No.: 158500 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff DISCOVER BANK Plaintiff, VS. JOYCE GAYE HUTCHERSON +L" l 2010 MAY 28 Pi's J- UL4 r r+, ? r r COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3173 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS CIATES, P.C. Attorneys or laintiff A Law Firm Ent ed ' Debt Collection By: \409C David J. Apothaker, Esquire Dated: 5/20/2010 In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff No. 08-3029 vs. IRENE A. GEKAS ~ ~' ~, `'~ i CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS ~. ~~- t. ~- "_~ (Mortgagor(s) and Record Owner(s)) - 48 South Terrace Road ~ ~ c ~ r~ _~_ ~5~3 ;~r, Wormleysburg, PA 17043 - '. iC' cs-~ Defendant(s) ` .~ ~-' 3` -? PRAECIPE FOR TUDGMENT ~ '" ~ fi ;~ 6 c~ :® THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A D~"BT { OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS by default for want of an Answer. Assess damages as follows: Debt Interest from 07/21/2010 to Date of Sale per diem at $118.91 Total `' (Assessment of Damages attached) $565,131.35 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the defaul and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237. ByGO BECK AFFERTY & MCKEEVER ~) ~' ~xinP pQ pm Mi ael McKeever Pa. ID 56129 C1krj3J'1( D McCafferty Pa. ID 42386 ..I3 4 'sa Lee Pa. ID 78020 ~,~ p'~5 1"~~~J~ ~~~ Krishna Murtha Pa. ID 61858 ~ ~`~^r"" David Fein Pa. ID 82628 ~-~, Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW ~'1i o?plp , Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST C MPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 and against IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS by default for wan Answer and dams es assessed in the sum of $565,131.35 as per the above certification. Prothonotary Rule of Civil Procedure No. 236 -Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff No. 08-3029 vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagors and Record Owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Prothonotary By: Deputy If you have any questions concerning the above, please contact: 7 fa.~~ro Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 64142FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: IRENE A. GEKAS GEKAS, IRENE A. 12703 East Desert Cove Avenue Scottsdale, AZ 85259 DATE OF THIS NOTICE: June 24, 2010 Tn the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOl, ASSET-BACKED CERTIFICATES, SERIES 2005-DOl 7105 Corporate Drive PTX C-35 Plano, TX 75024 PlaintiffJ' vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/kJa DEAN N. GEKAS (Mortgagor(s) and Record Owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) TO: IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 CNIL ACTION -LAW Action of Mortgage Foreclosure Term No. 08-3029 IlVII'ORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WR11T'EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FIIE IN WRITING WTII3 THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THLS OFFICE CAN PROVIDE YOU WfTH INFORMATION ABOUT HIItING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 MicAaeJ T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 64142FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WII,L BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: CONSTANTINE N. GEKAS alWa DEAN N. GEKAS GEKAS, CONSTANTINE N. a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DOl 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. 1REAiE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record Owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) TO: CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS DATE OF THIS NOTICE: June 24, 2010 in the Court of Common Pleas of Cumberland County CTVII. ACTION -LAW Action of Mortgage Foreclosure Term No. 08-3029 12703 East Desert Cove Avenue Scottsdale, AZ 85259 IbIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII.ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FIIE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIItING A LAWYER. IF YOU CANNOT AFFORD TO H1RE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McI~EVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 64142FC THIS LAW FIRM l A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: IRENE A. GEKAS GEKAS, IRENE A. 48 South Terrace Road Wormleysburg, PA 17043 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DOI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IItENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record Owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) TO: IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 DATE OF THIS NOTICE: June 24, 2010 In the Court of Common Pleas of Cumberland County CIVIL ACTION -LAW Action of Mortgage Foreclosure Term No. 08-3029 IIVIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FII.E IN WRITING W1TH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WIIIIIN TEN (10) DAYS FROM THE DATE OF THLS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LASE YOUR PROPERTY OR OTHER A~IPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELAW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIIZING A LAWYER. IF YOU CANNOT AFFORD TO HIl2E A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Laberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McIGrEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825fi318 64142FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS GEKAS, CONSTANTINE N., a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 DATE OF THIS NOTICE: June 24, 2010 in the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DOI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record Owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) TO: CONSTANTINE N. GEKAS a/Wa DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 CIVII. ACTION -LAW Action of Mortgage Foreclosure Term No. 08-3029 IIbIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII ED TO ENTER A WRTITEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRTI'ING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WTfHIN 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 IIvIPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIl2ING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvir-e Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Iaberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McI~EVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, IRENE A. GEKAS, is about unknown years of age, that Defendant's last known residence is 48 South Terrace Road Wormleysburg, PA 17043, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: ~/~/~ 0 ~ Martin Hynes VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS, is about unknown years of age, that Defendant's last known residence is 48 South Terrace Road Wormleysburg, PA 17043, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: ~/~~~ U Martin Hynes GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attornev for Plaintiff AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(sZ ORDER FOR iUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3029 Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1, and against IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS for failure to file an Answer in the above action within (20) days (or sixty (60 da s ' defendant is the United States of America) from the date of service of the Complaint, in the sum of $565,131.35. By: GOLDBECK MCCAFFERTY & MCKEEVER Mi hael McKeever Pa. ID 56129 G~Cy McCafferty Pa. ID 42386 isa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are IRENE A. GEKAS, 48 South Terrace Road Wormleysburg, PA 17043 and CONSTANT N. GEKAS a/k/a DEAN N. GEKAS, 48 South Terrace Road Wormleysburg, PA 17043; B• BECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gi~y McCafferty Pa. ID 42386 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 09/01/2007 through 07/20/2010 Reasonable Attorney's Fee Late Chazges Costs of Suit and Title Search Escrow Payments Due 0 X $0.00 $411,795.36 $125,331.14 $20,589.77 $6,515.08 $900.00 $0.00 $565,131.35 B ECK MCCAFFERTY & MCKEEVER Mic ael McKeever Pa. ID 56129 G McCafferty Pa. ID 42386 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW, this pZ~p'~'~ day of ~d~,y , 2010 damages aze assessed as above. C Fro othy PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Mazket Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3029 PRAECIPE FOR WRIT OF EXECUTION C7 ''.> ~' C <: o '' ,, ~_i 1 r, s: ~- - _~ ~ c, _ -:,_ $ ~. . , _ _-f 3 c= r ~, ; ~ ) ~ . C: C : ~.. ~ .,~ Issue Writ of Execution in the above matter: O Amount Due #a~{.oo Pq I~rry ~f4.00 Cam' 6!1.00 '' 50.00 '~ 50.00 " 70.40 '~ 78 . So " 10 .Op ~ !O. p0 " la.od " I~ . oo " 01.50 ~, ~ ~ , r.~p - PD A'!rl ~a. oo ~ve~'o • 50 td. ~~' 538416 R.~' ay5?g3 $565,131.35 Interest from 07/21/2010 to Date of Sale per diem at $118.91 (Costs to be added) By. G~b$ECK MCCAFFERTY & MCKEEVER Mi ael McKeever Pa. ID 56129 McCafferty Pa. ID 42386 isa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff w Q o ~ c W~ `~ ~ w ~~~o zv ~ a z oQ¢A H ~ ~ ~ ~ ~Ho ~o~~ -oW 3~v~ SAO o° ~ w o~~ En"yu"dw Q~ oaQ U a p ~~++ G O 0 ~ ~i o w h w~~ y~ FF-I H~o oA°~ ¢~ ~~~ 3 zH QooH x ~~~o~ o o x ~~ ~ w ~w ~~ ~ ~~ ~ 3 w U ~ a ~ Cx-~ pq t~ H ~ ~~~U ~ ~~ d H~~ Z a ~ O U W Q~ H i N U U ~~ ;v ~, U ~ ~ ~ o y, ~ O~ N ~~~a~ ~ . G c~C ~y C; O ~ R+~ O ~ N .`ji ~ ~ ~ ~ o a.. ~° o a~ C7 ALL that certain piece or pazcel of land, situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western line of Greenwood circle at the Southern line of lands now or late of Hazold A. Herre and Jane M. Herre, his wife; thence along the western line of Greenwood Circle, in a southwazdly direction, a distance of one hundred fifty (150) feet to a point to line of other lands now or late of Robert M. Mumma and Bazbaza M. Mumma, his wife; thence along said other lands now or late of Robert M. Mumma and Bazbaza M. Mumma, his wife, in a westwazdly direction by a line pazallel to the southern line of lands now or late of Hazold A. Herre and Jane M. Herre, his wife, a distance of two hundred fifty (250) feet, more or less, to a point on the eastern line of Lot No. 45 on said hereinafter mentioned Plan of Lots, the line of lands now or late of Edwin B. Romig and Virginia Romig, his wife; thence along said eastern line of Lot No. 45 in said hereinafter mentioned Plan of Lots and the eastern line of Lot No. 44 on said Plan, in a northwazdly direction, a distance of one hundred fifty (150) feet to a point on the southern line of lands now or late of Harold A. Herre and Jane M. Here, his wife; and thence along said southern line of Hazold A. Herre and Jane M. Herre, his wife, in an eastwazdly direction a distance of two hundred fifty (250) feet, more or less, to a point on the western line of Greenwood Circle, the place of BEGINNING. BEING the southern one-half (1/2) of Lot No. 47 and the northern part of Lot No. 48 on t Revised Plan of Pennsboro Manor as recorded in the Office for the Recording of Deeds in and for the County of Cumberland in Plan Book 3, Page 6. TAX PARCEL #47-20-1856-032 BEING KNOWN AS: 48 South Terrace Road, Wormleysburg, PA 17043 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHII.ADELPHIA, PA 19106-1532 (215)627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DOl, ASSET-BACKED CERTIFICATES, SERIES 2005-DOl 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY n -°^ ii .Y `_ - 6 r~ - r~ ~- ?. _ _ 3 . Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: G BECK McCAFFERTY & McKEEVER Mic ael McKeever Pa. ID 56129 G McCafferty Pa. ID 42386 sa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3029 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff Gold>eckYMcCafferty & McKeever BY'~ Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005- DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record Owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-3029 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DOl, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 48 South Terrace Road Wormleysburg, PA 17043 1.Name and address of Owner(s) or Reputed Owner(s): ~ ,.~, C ° IRENE A. GEKAS ,,, =~ _ ~ .~ 48 South Terrace Road '-'-" : ~=~ - -~ Wormleysburg, PA 17043 ;.,,, -;_- ~~ - a , _ ._ CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS _ _- 48 South Terrace Road -•- Wormleysburg, PA 17043 ~ - ^:? ..7 C? zip 2. Name and address of Defendant(s) in the judgment: '~'~~ IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfaze Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DEUTSCHE BANK NATIONAL TRUST GO Francis S. Hallinan Phelan Hallinan & Schmieg, 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 PENNSYLVANIA STATE BANK C/O Thomas G. Klingensmith Gingrich, Smith, ET AL, 45 East Orange Street Lancaster, PA 17602 SUSQUEHANNA BANK PA GO BARRY HANDWERGER 22 S Duke Street Lancaster, PA 17602 REISMAN DAVID LAWN SERVICE, INC. 4705 Gettysburg Road Mechanicsburg, PA 17055 INTEGRITY BANK 3345 Mazket Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA STATE BANK 2148 Mazket Street P.O. Box 487 Camp Hill, PA 17011 ANDY KARTALIS 25505 Alberton Road Beechwood, OH 44122 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 48 South Terrace Road Wormleysburg, PA 17043 One Oxford Centre 35th Floor Pittsburgh, PA 15219 (attach sepazate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: July 20, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Martin Hynes ~" GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff 08-3029 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3029 C -~, ;=- r ~ I r. _~ C> ~- i, - !'-' TJ c, r~,~ c~ c~ -fi _~ iii ~ Ti ~.__. -~- m --=~ THIS LAW FIRM LS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE LS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS, IItENE A. IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 Your house at 48 South Terrace Road, Wormleysburg, PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $565,131.35 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-3029 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET- BACKED CERTIFICATES, SERIES 2005-DO1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as i~ the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. ~ You may be entitled to a shaze of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2}. Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud~o_v for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http://www.phfa. org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@~oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Para information en espanol puede communicarse con Loretta a1215-825-6344. * 08-3029 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IltENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant( Term , 08-3029 No C ~ ~ , ' i . <~ ~ -~,, >-~~ : c~ T -- i -, r ;-, rs c• ;-':~ _. - ;~_ ~, ~ ~~ : ~ -=' : f ~ THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE LS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS, CONSTANTINE N. a/k/a DEAN N. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale, AZ 85259 Your house at 48 South Terrace Road, Wormleysburg, PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $565,131.35 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-3029 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET- BACKED CERTIFICATES, SERIES 2005-DO1, the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a shaze of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue ,Carlisle, PA 17013 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.~ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http://www.phfa.or~~consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Paza information en espanol puede communicazse con Loretta al 215-825-6344. 08-3029 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IlZENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 IN THE COURT OF COMMON PLEAS of Cumberland County CIVII, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3029 o ~1 r.~ ,~., ~.' c..- -, ~ ,-, ~_ c~ ~ , ,; r- _. ~ , ~: C" t? THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS, IRENE A. IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 Your house at 48 South Terrace Road, Wormleysburg, PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $565,131.35 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DOl against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-3029 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET- BACKED CERTIFICATES, SERIES 2005-DO1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: httn://www.philadelphiafed.or~,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 717-243-9400 08-3029 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.vhfa.org/consumers homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. !° 08-3029 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendants; IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAG~ ~ = F ~. FORECLOSURE t ~! ~,, ,_ _ -,-~ <_.... r- ~~~ . , , ; r~; .. ~ , Term ~ _ _ u. ~ _ . No. 08-3029 ~ = ;_ _ ~> `;. .~ ~- 'a) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS, CONSTANTINE N., a/kJa DEAN N. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 Your house at 48 South Terrace Road, Wormleysburg, PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $565,131.35 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE >r 08-3029 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET- BACKED CERTIFICATES, SERIES 2005-DO1, the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orglforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE_LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 717-243-9400 08-3029 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http: //www. phfa. org/con sumers/homeowners/real . aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Paza information en espanol puede communicazse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3029 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY as Trustee for THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOl, ASSET- BACKED CERTIFICATES, SERIES 2005-DOl, Plaintiff (s) From IRENE A. GEKAS & CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (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 $565,131.35 L.L.$.50 Interest from 7/21/10 to Date of Sale per diem at $118.91 Atty's Comm % Due Prothy $2.00 Atty Paid $389.40 Other Costs Plaintiff Paid Date: 7/26/10 ~ David D. Buell, Proth notary RE~Q.IJESTING PARTY: Name: LISA LEE, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Deputy s Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED-OFFICE ?xxtn qt .:trtrt?rr?t?? r ,. , . f, 'III SEP 23 Phi 3, Deutsche Bank National Trust Company vs. Case Number Constantine N Gekas (et al.) 2008-3029 SHERIFF'S RETURN OF SERVICE 09121/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney McKeever on 8/12/10 SHERIFF COST: $94.78 SO ANSWERS, j? September 23, 2010 RON R ANDERSON, SHERIFF 4 -* ??/?/ 11?2?0 a4t;;? 746 (c) GountySuite Sher •:ff. Ieleos7£t. Inc. GOLDBECK McCAFFERTY 8~ McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attomey for Plaintiff it..~:s-~lr ~ ~~(:~~. 2~~OOr~ _~ ~t~ ~~ 4 ~~3~~Yfl.~':'~~~(4 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-D01, ASSET-BACKED CERTIFICATES, SERIES 2005-D01 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) PRAECIPE TO VACATE JUDGI~NT TO THE PROTHONOTARY: No. 08-3029 Kindly vacate the judgment with reference to the above-captioned matter, insofar as judgment was entered in error due to the filing of a petition in Bankruptcy on 0611 0/2 0 1 0. Please file enclosed; however, do not Discontinue and End as we wish to have case remain open until further notice. MICHAEL T. MCKEEVER, ESQUIRE ~~ ~~-~ ~~ k ~g~~~ o~' ~ ~~,g ~~~~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE In-the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1,ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 No. 08-3029 7105 Corporate Drive PTX C-35 Plano,TX 75024 O r.., Plaintiff vs. IRENE A.GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS tip (Mortgagor(s)and Record Owner(s)) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against IRENE A.GEKAS and CONSTANTINE N.GEKAS a/k/a DEAN N. GEKAS by default for want of an Answer. Assess damages as follows: $700,959.85 Debt Interest from 12/18/2013 to Date of Sale per diem at$118.91 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurrdd and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.23,;.1 By: ,( KML LAW GROUP, �p• O(�Q AV-11 _Michael McKeever Pa.TD 56129 C jl r 07 _Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 j g� Kristina Murtha Pa.ID 61858 _David Fein Pa.ID 82628 �ha�led Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 TJill P.Jenkins Pa.ID 306588 �rgw F.Go mall P .-r92382�i ?"/7 AND NOW , _AWotr e��'lai iJ , 4013 ,Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI,ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 and against IRENE A. GEKAS d CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS by default for want of a nsw d da assessed in t m of $700,959.85 as per the above certification. tho Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO 1,ASSET-BACKED CERTIFICATES, SERIES 2005-DO 1 7105 Corporate Drive PTX C-35 Plano,TX 75024 Plaintiff No.08-3029 VS. IRENE A. GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS (Mortgagors and Record Owner(s)) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered 4ainst you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary By: Deputy If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 64142FC TIM LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORI1 AT#AN OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF TEAS NOTICE: November 1992013 TO: IRENE A.GEKAS GEKAS,IRENE A. 48 South Terrace Road Wormleysburg,PA 17043 Li the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY AS Common Pleas TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN of Cumberland County TRUST 2005-DO1,ASSET-BACKED CERTIFICATES,SERIES 2005-DO1 CIVIL ACTION-LAW 7105 Corporate Drive PTX C-35 Action of Plano,TX 75024 Plaintiff' Mortgage Foreclosure VS. IRENE A.GEKAS No.08-3029 CONS'I'ANI'INE N.GEKAS a/k/a DEAN N.GEKAS (Mortgagor(s)and Record Owner(s)) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) TO: IRENE A.GEKAS 48 South Terrace Road Worndeysburg,PA 17043 1MPOR TAMP NOTICE YOU ARL IN DETAULT BECAUSE YOU HAVE FARM TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FII.F.IN WRITING WITH THE COTJRT YOUR DEFENSES OR OB1E(,T10NS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACr WITHIN TEN(10)DAYS FROM THE DATE OF 1TIS NOTICE,A JUDGMENT MAY BE]ENTERED AGAINST YOU W111101T1 A HEARING AND YOU MAY LOSE YOUR PItOPI1t1'Y OR ornnal IMPORTANT RIGHTS. YOIJ SHOULD TAKE'1111S PAPER TO YOUR IAWYF.R AT ONCE. IF YOTJ DO NOT HAVE A LAWYER,GO TO OR TEIEPHONE THE OFFICE SET FORTH BF7.OW. 11US OFFICE CAN PROVIDE YO1I WITH INFORMATION ABOUT HIRING A LAWYER. 7 YOU CANNOT AFFORD TO HIRE A LAVirYER,THIS OFFICE MAY BE ABLE TO PROVIDF.YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERV1CLS I O LLIGIULL PIRSONS AT A RLiDUCED kll OR NO kLE. LEGAL SPRVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avcram Carlisle,PA 17013 By. 4Q KML LAW Gk",P.C. Michael McKeever Pa.ID 56129 _Lisa Lee Pa.ID 78020 _Krishna Murtha Pa.ID 61858 _David Fein Pa.ID 82628 _Thomas Pulce Pa,ID 27615 _Jill P.Jenkins Pa.ID 306588 N Alyk I.Olarian Pa.ID 312912 =Salvatore Filippello Pa.ID 313897 -Michael J.Coskey Pa ID 311835 215-627-1322 Attomeys for Plaintiff 64142FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: November 19,2013 TO- CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS GEKAS,CONSTANTINE N.,a/k/a DEAN N.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 In the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY AS Common Pleas TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN of Cumberland County TRUST 2005-DO 1,ASSET-BACKED CERTIFICATES,SERIES 2005-DOT CIVIL ACTION-LAW 7105 Corporate Drive PTX C-35 Action of Plano,TX 75024 Plaintiff Mortgage Foreclosure vs. IRENE A.GEKAS No.08-3029 CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS (Mortgagor(s)and Record Owner(s)) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) TO: CONSTANTINE N.GEKAS atk/a DEAN N.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 IMPORTANT NOTICE YOU ARE IN DEFAULT BFCAIISE YOU HAVE'FAIIJ-D TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILL IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLLSS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A IUDGMLiNT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AI ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SF.T FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT AIRING A LAWYER. IF YOU CANNOT AFFORD 10 HIRL A LAWYER,THIS OFFICE MAY BE AHLF."110 PROVIDE YOU WI1I1 INFORMATION ABOUI AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RFDUCFD FEE;OR NO FEE. LEGAL.SFAVICI:S INC S Levine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 liberty,Avenue Carlisle,PA 17013 By. KNIL LAW GRO P,P.C. _Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 _Kristina Martha Pa.ID 61858 _David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill Jr.Jenkins Pa.ID 306588 �Alyk L.011a:ian Pa.ID 312912 _Salvatore Filippeao Pa.ID 313891 `Michael J.Coskey Pa ID 311835 215-627-1322 Altwneys for Plaintiff 6-4142FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: November 1.9,2013 TO: IlZENE A.GEKAS GEKAS,IRENE A. 12703 East Desert Cove Avenue Scottsdale,AZ 85259 In the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY AS Common Pleas TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN of Cumberland County TRUST 2005-DOI,ASSET-BACKED CERTIFICATES, SERIES 2005-DOT CIVIL ACTION-LAW 7105 Corporate Drive PTX C-35 Action of Plano,TX 75024 Plaintiff Mortgage Foreclosure vs. IRENE A.GEKAS No.08-3029 CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS (Mortgagor(s)and Record Owner(s)) 48 South Terrace Road Worinleysburg,PA 17043 Defendant(s) TO: IRENE A.GEKAS 12703 East Desert Cove Avenue Scottsdale,AZ 85259 1n1PORTANr NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FADED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AMU 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 ANN)YOU MAY LOSL'YOUR PROPLRIY OR OTHER IlAPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICF.Slit FORM BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE.'1`0 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO F.rIGD1I E PERSONS AT A REDUCED FEE OR NU FEE. LEGAL SERVICES INC B Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 fly: '' ML� '' // -— KML LAW GRt7YP,P.C. _Michael McKeever Pa.JD 56129 _Lisa I"Pa.ID 78020 _Kristin Murtha Pa.D?61858 David Fein Pa.ID 82628 Thomas Pulee Pa.1D 27615 Jill P.Jenkins Pa ID 306588 - Jill L.OOaAan Pa.ID 312912 "T Salvatore Filippelie Pa.10 313897 _Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 64142FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: November 19,2013 TO_ CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS GEKAS,CONSTANTINE N.a/k/a DEAN N.GEKAS 12703 East Desert Cave Avenue Scottsdale,AZ 85259 In the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY AS Common Pleas TRUSTEE.FOR THE HOLDERS OF SOUNDVIEW HOME LOAN of Cumberland County TRUST 2005-DO I,ASSET-BACKED CERTIFICATES,SERIES 2005-DOT CIVIL AC'T'ION-LAW 7105 Corporate Drive PTX C-35 Action of Plano,TX 75024 Plaintiff Mortgage Foreclosure vs. IRENE A.GEKAS No.08-3029 CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS (Mortgagor(s)and Record Owner(s)) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) TO: CONSTANTINE N.GEKAS alkla DEAN N.GEKAS 12703 East Desert Cove Avenue Scottsdale,AZ 85259 11*11PORTANT NOTICE: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND Fn.F.IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WnHN TEN(10)DAYS FROM THE DATE OF'lIIIS NOTICE,A JUDGMENT MAY RE 1:NfF.R1J)AGANST YOU WITHOUT A HEARING AND YOU MAY I.OSF.YOUR PROHXFY OR O'1II iR IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BFJ.OW. ''THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU W1111 INFORMATION ABOUT AGENCUiS THAT MAY OFFER LFGAI.SERVICFS TO FI.'GIB'F PERSONS AT A RFDUCIM 1'11.-Olt NO YL-E. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Cmfisle,PA 1'!013 Ay:_ KML LAW GR ,P.C. _Michael McKeever Pa.ID 56129 Lisa Lee Pa.Ill 78020 _Kristin Murtha Pa.ID 61858 _David Fein Pa.ID 82628 'Ibomas Puleo Pa.ID 27615 �AlykJill P.Jenkins Pa.ID 306588 _S L Oflazian Pa.ID 312912 alvatore Filippello Pa.ID 313897 _Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS C:: TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME ' - LOAN TRUST 2005-DO I,ASSET-BACKED CERTIFICATES,SERIES 2005-DO1 �''77) C-4 Plaintiff NO.08-3029 r i vs. r-1 r�-- IRENE A.GEKAS t CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): IRENE A. GEKAS, has a last known residence of 48 South Terrace Road, Wormleysburg, PA 17043 and 12703 East Desert Cove Avenue, Scottsdale AZ 85259. The following information was used to search the DMDC(check all that apply): • Last Name • First Name • Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date 02 I /� By: y KML LAW GROUP,P. . Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Dec-16-2013".56;43 SCRA 3.0 Staff Re0ort a nt to ervieemembers Civil Relief Act Last Name: GEKAS First Name: IRENE Middle Name: A Active Duty Status As Of: Dec-16-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Doty Erns Date Status service component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367.Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA I NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Dam -Order Notification End Date Status Service Component NA NA Na NA This response reflects whether the itrdividual or histher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Aaj �- Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fall to obtain this additional Service verification,punitive provisions of the SCRA maybe invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(9 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate 1D: J6BB8852006B370 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA, DEUTSCHE BANK NATIONAL TRUST COMPANY AS = TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I,ASSET-BACKED CERTIFICATES,SERIES 2005-DO1 Plaintiff NO.08-3029 E" vs. ;`Y —? ;7i- Y IRENE A.GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS Defendant(s) ` VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS, has a last known residence of 48 South Terrace Road, Wormleysburg, PA 17043 12703 East Desert Cove Avenue, Scottsdale AZ 85259. The following information was used to search the DMDC(check all that apply): • Last Name • First Name • Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. y Date j � f / f By: '. Y KML LAW GROUP,P.C. Michael McKeever Pa. 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Results as of:Dec-17-2013 07:27:47 Department of Defense Manpower Data Center SCRA 3.0 stagy RePoTt Pursuant to Servicememben Civil Relief Act Last Name: GEKAS First Name: CONSTANTINE Middle Name: N. Active Duty Status As Of: Dec-17-2013 On Active Duty On Active Duty Status Date - Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HislFler Unit Was Notified of a Future CalWp to Active Duty.on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Ohl fal- t Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 16ZE9C72U06F650 Results as of:Dec-17-2013 07:28:25 Department of Defense Manpower Data Center SCRA 3.0 status Repoli Pursuant to Servicememben Civil Relief Act Last Name: GEKAS First Name: DEAN Middle Name: N. Active Duty Status As Of: Dec-17-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Dale The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date - .Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Alhk� M. .� Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 76A1YCD23070Q70 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME IN THE COURT OF COMMON PLEAS LOAN TRUST 2005-DO I,ASSET-BACKED CERTIFICATES,SERIES 2005-DO 1 of Cumberland County 7105 Corporate Drive PTX C-35 Plano,TX 75024 CIVIL ACTION LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE IRENE A.GEKAS t CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS } (Mortgagor(s)and Record owner(s)) No.08-3029 M V 7 z 48 South Terrace Roads °� Wormleysburg,PA 17043 Defendant(s) "` + c-, n: ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE Hb DERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1,ASSET-BACKED CERTIFICATES,SERIES 2005-DOI,and against IRENE A: GEKAS and CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS for failure to file an Answer in the above action within(20)days from the date of service of the Complaint,in the sum of$700,959.85. n By: "'y' KML LAW GROUP, Michael McKeever Pa.I 56129 _Jay E.Kivitz Pa.ID 26769 _Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 _David Fein Pa.ID 82628 _Thomas Puleo Pa.ID 27615 _Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 of ney for PI t6 j �6 I hereby certify that the above names are correct and that the precise residence eress of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES,SERIES 2005-DO 17105 Corporate Drive PTX C-35 Plano,TX 75024 and that the name(s)and last known address(es)of the Defendant(s)is/are IRENE A.GEKAS,48 South Terrace Road Wormleysburg,PA 17043; 12703 East Desert Cove Avenue,Scottsdale AZ 85259 and CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS,48 South Terrace Road Wormleysburg,PA 17043; 12703 East Desert Cove Avenue,Scottsdale AZ 85259 By: KML LAW GROUP, Michael McKeever Pa. 56129 _Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 _David Fein Pa.ID 82628 _Thomas Puleo Pa.ID 27615 _Joshua 1.Goldman Pa.205047 _Jill P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $411,795.36 Interest from 09/01/2007 through $273,492.99 12/17/2013 Reasonable Attorney's Fee $1,300.00 Late Charges $14,371.50 $700,959.85 By: KML LAW GkOUYVIfC. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff J c� , ,AND NOW,this �`�' �day of I�J�� 2013 damages are assess�as above. 0'! .t= C3t ro Prothy 08-3029/64142FC SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Qy, Jody S Smith Chief Deputy a Edward L Schorpp Solicitor or ,F? s.`s=rb;= Deutsche Bank National Trust Company Case Number VS. 2008-3029 Constantine N Gekas(et al.) SHERIFF'S RETURN OF SERVICE 05/24/2010 07:33 PM-Gerald Worthington, Deputy Sheriff,who being duly sworn according to law,states that on May 24,2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant,to wit: Constantine N. Gekas a/k/a Dean N. Gekas,pursuant to order of court by posting the premises located at 48 South Terrace Road,Wormleysburg, Cumberland County, Pennsylvania 17043 with a true and correct copy according to law. GERALD DEPUTY 05/2412010 05:33 PM-Gerald Worthington, Deputy Sheriff,who being duly sworn according to law, states that on May 24,2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant,to wit: Irene A.Gekas, pursuant to order of court by posting the premises located at 48 South Terrace Road,Wormleysburg,Cumberland County, Pennsylvania 17043 with a true and correct copy according to law. 24&1�11 A lVtPJ.1� GERALD WORTHINGT DEPUTY SHERIFF COST:$70.40 SO ANSWERS, May 25,2010 RbNtrY R ANDERSON, SHERIFF fVj/.pun;'Suite Sharfr,T eleosoft,Inc. - ORDERED ACCORDINGLY. Dated:September 11,2012 J Russell Brown 3 CHAPTER 13 TRUSTEE George B.Nielsen,Bankruptcy Judge Suite 800 4 3838 North Central Avenue Phoenix,Arizona 85012-1965 5 602.277.8996 mail@chl3bk.com 6 UNITED STATES BANKRUPTCY COURT 7 DISTRICT OF ARIZONA 8 In Re Chapter 13 9 CONSTANTINE NICHOLAS GEKAS, Case No. 2-11-bk-25728 GBN 10 and ORDER DISMISSING CASE 11 IRENE ANGELIQUE GEKAS, 12 Debtors. 13 14 The Trustee having notified the Court that the Debtors failed to comply with the Trustee's 15 Recommendation as required by Local Rule 2084-10, the Court finds cause for dismissing the 16 case pursuant to 11 U.S.C. § 1307(c)(1). The Trustee states that the reason for lodging a 17 dismissal order is: Failure to provide the Trustee with item#1 and #1 of the Trustee's Recommendation; 18 all no later than August 17, 2012. The Debtor is $2,400.00 in default and has not made a plan payment since January 2012. 19 20 NOW,THEREFORE,IT IS ORDERED: 21 (A) This case is dismissed and the Clerk of the Court will give notice of the dismissal to all 22 parties in interest; 23 (B) A motion to reinstate the case may be granted without a hearing if the Trustee approves 24 the proposed reinstatement order. If the Trustee does not approve of reinstatement of the case, 25 the matter may be set for hearing upon the Debtors' motion. The Court may set a hearing on 26 any motion to reinstate on the request of an interested party who had joined the Trustee's request for dismissal; Case 2:11-bk-25728-GBN Doc 36 Filed 09/11/12 Entered 09/12/12 08:02:06 Desc Main Document- Trustee Plan Recommendation (batch) Page 1 of 3 I (C) Pursuant to 28 U.S.C. § 586(e)(2), the Trustee shall be paid his percentage fee from all 2 payments and property received, even if the case is reinstated and converted to another chapter. 3 After payment of the Trustee's percentage fee, subject to the provisions herein, the Trustee will 4 retain the funds in the case pending Court approval of the payment of administrative expenses 5 of the attorney for the Debtors. If the Chapter 13 Plan contains an application for payment of 6 administrative expenses and no party in interest filed an objection to the application, then the 7 counsel for the Debtors may lodge an order approving the application within ten days after the 8 Court enters this Dismissal Order. Alternatively, counsel for the Debtors has ten days after the 9 Court enters this Dismissal Order to file and notice out a separate fee application. The Trustee 10 is to pay from the funds on hand any adequate protection payments previously ordered by the 11 Court. If there is an insufficient amount of funds on hand to pay all allowed administrative 12 expenses and adequate protection payments, then the Trustee shall pay the administrative 13 expenses and adequate protection payments pro rata. Any remaining funds will be returned to 14 the Debtors. If the attorney for the Debtors fails to timely lodge such Order or file a fee 15 application,the Trustee may pay out the funds according to this Order; and 16 (D) If the Court has entered a payroll deduction order on the wages of the Debtors, then the 17 Court vacates that order. 18 19 ORDER SIGNED AND DATED ON PAGE ONE 20 21 22 23 24 25 26 In re Gekas Case No.2-11-bk-j2s5s72g8 GBN Case 2:11-bk-25728-GBN Doc 36 Filed 09/11/12 Entered 09/12/12 08:(-udismjsseSgcase Main Document - Trustee Plan Recation (batch) Page 2 of 3 A copy of the proposed Order was mailed or emailed to: CONSTANTINE NICHOLAS GEKAS IRENE GEKAS IRENE ANGELIQUE GEKAS 12513 E. LUPINE AVENUE 12636 N. 68TH PLACE SCOTTSDALE,AZ 85259 SCOTTSDALE,AZ 85254 LAW OFFICE OF ALLEN D. BUTLER 406 E. SOUTHERN TEMPE,AZ 85282-2674 abutleraz @gmail.com Attorney for Debtors Dawn Smith 5 W 2012.08.20 10:34:04-07'00' Dawn Smith dsmith @ch13bk.com In re Gekas Case No.2-11-bk-j2s5s728 GBN Case 2:11-bk-25728-GBN Doc 36 Filed 09/11/12 Entered 09/12/12 08:&-.ff6SmU2SCase Main Document- Trustee Plan Re M*tion (batch) Page 3 of 3 FORM van—odc UNITED STATES BANKRUPTCY COURT DISTRICT OF ARIZONA In re: Case No.: 2:08—bk-08683—EWH CONSTANTINE N GEKAS Chapter: 13 9222 S 123RD ST SCOTTSDALE,AZ 85259 SSAN: xxx—xx-5805 EIN: IRENE A GEKAS 9222 S 123RD ST SCOTTSDALE,AZ 85259 SSAN: xxx—xx-5383 EIN: Debtor(s) ORDER DISMISSING CASE 1"' The debtor(s)having failed to file a list of creditors in the proper format as required by Local Bankruptcy Rule 1007-1. f The individual debtors having failed to file a Credit Counseling Certificate as required by Interim Rule 1007. The debtor(s)having failed to pay the filing fee as ordered by the court. The debtor(s)having failed to timely file the schedules and statements required by Fed. R. Bankr.P. 1007. 1- The debtor(s)having failed to timely file a Chapter 13 plan as required by Fed.R. Bankr.P. 3015. r. The debtor(s)having failed to timely submit the Statement of Social Security Number as required by Fed. R. Bankr.P. 1007(f). r- The individual debtors having failed to file a Statement of Current Monthly Income as required by Interim Rule 1007. r. The debtor(s)having failed to file a declaration regarding payment advices as required by Local Bankruptcy Rule 1007-1. Pr The debtor(s)having failed to appear and be examined at the meeting of creditors as required by 1 I U.S.C. Section 343. • An Order to Show Cause why this case should not be dismissed having been issued. • The trustee having moved to dismiss this case. • The debtor(s)having moved to dismiss this case. --Order continued on 2nd page-- Case 2:08-bk-08683-EWH Doc 17 Filed 09/15/08 Entered 09/15/08 11:35:32 Desc Order Dismissing Case Page 1 of 2 IT IS ORDERED that the above—captioned case be dismissed.Jurisdiction is retained over any matters arising under Section 110. IT IS FURTHER ORDERED that any pending hearings,including any final hearing set on a motion for relief from the automatic stay are vacated. IT IS FURTHER ORDERED that the Court shall not consider a motion for reinstatement of the case unless all fees are paid in full or all required documents are filed.To have the case reinstated in an individual debtor chapter 7 or 13 case,all documents required by 11 USC Section 521(a)(1)must be filed no later than 45 days from the date the bankruptcy was filed. NOTICE IS ALSO GIVEN that the order was entered on the docket this date. Date: September 15,2008 BY THE COURT Address of the Bankruptcy Clerk's Office: HONORABLE Eileen W. Hollowell U.S.Bankruptcy Court,Arizona United States Bankruptcy Judge 230 North First Avenue, Suite 101 Phoenix,AZ 85003-1727 Telephone number: (602)682-4000 www.azb.uscourts.gov Case 2:08-bk-08683-EWH Doc 17 Filed 09/15/08 Entered 09/15/08 11:35:32 Desc Order Dismissing Case Page 2 of 2 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1,ASSET-BACKED IN THE COURT OF COMMON PLEAS CERTIFICATES, SERIES 2005-DOI 7105 Corporate Drive of Cumberland County PTX C-35 Plano,TX 75024 CIVIL ACTION—LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE IRENE A.GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS No. 08-3029 ; Mortgagor(s)and Record Owner(s) 48 South Terrace Road r Wormleysburg,PA 17043 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: 0 Amount Due $700,959.85 *A8.50 Pb AT7-y Interest from 4q. 00 CBF, 12/18/2013 to Date of a 1. 00 ti Sale per diem at 50: 00 " $11.8.91 50.00 u `70, 4D " (Costs to be added) to f'n 10 00 la - 00 i . 00 BY 44,co 4 KML LAW GROUP, 8-c Michael McKeever Pa. ID 56129 16`.50 Jay E.Kivitz Pa.ID 26769 X534.68... P T'y Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 *a.s 8W�•'1 David Fein Pa.ID 82628 G Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 _Till P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 �(d Attorneys for Plaintiff flze' G .:.. 7 , , KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I,ASSET-BACKED IN THE COURT OF CERTIFICATES, SERIES 2005-DOI COMMON PLEAS 7105 Corporate Drive PTX C-35 of Cumberland County Plano,TX 75024 Plaintiff CIVIL ACTION-LAW vs. ACTION OF IRENE A. GEKAS MORTGAGE FORECLOSURE CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS ,W r Mortgagor(s)and Record Owner(s) 48 South Terrace Road Wormleysburg,PA 17043 NO. 08-3064 �._. Defendant(s) J _ CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: ' KML LAW GROUP, Michael McKeever Pa.V56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 Attorneys for Plaintiff i x, S I vA.4-of-e- F 3 f 3 °� i KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME IN THE COURT OF COMMON PLEAS LOAN TRUST 2005-DO1,ASSET-BACKED CERTIFICATES, SERIES 2005-DOI of Cumberland County 7105 Corporate Drive PTX C-35 Plano,TX 75024 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE IRENE A.GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS (Mortgagor(s)and Record Owner(s)) 48 South Terrace Road No.08-3029 Wormleysburg,PA 17043 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I,ASSET-BACKED CERTIFICATES,SERIES 2005-DO I,Plaintiff in the above action,by counsel,KML Law Group, P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 48 South Terrace Road Wormleysburg,PA 17043 1.Name and address of Owner(s)or Reputed Owner(s): IRENE A.GEKAS „r,. 48 South Terrace Road °'�Zj C—) Wormleysburg,PA 17043 IRENE A.GEKAS 12703 East Desert Cove Avenue ti Scottsdale AZ 85259 - CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 CONSTANTINE N.GEKAS wVa DEAN N.GEKAS 12703 East Desert Cove Avenue Scottsdale AZ 85259 2.Name and address of Defendant(s)in the judgment: IRENE A.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 IRENE A.GEKAS 12703 East Desert Cove Avenue Scottsdale AZ 85259 CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS 12703 East Desert Cove Avenue Scottsdale AZ 85259 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 REISMAN DAVID LAWN SERVICE,INC. 4705 Gettysburg Road Mechanicsburg,PA 17055 INTEGRITY BANK 3345 Market Street Camp Hill,PA 17011 DEUTSCHE BANK NATIONAL TRUST c/o PHELAN HALLINAN&SCHMIEG,LLP 1617 JFK Boulevard STE 1400 Philadelphia,PA 19103 DEUTSCHE BANK NATIONAL TRUST 7105 Corporate Drive Plano,TX 75024 PENNSYLVANIA STATE BANK c/o Thomas G.Klingensmith,Esquire,Gingrich, Smith,Klingensmith&Dolan 45 East Orange Street Lancaster,PA 17602 PENNSYLVANIA STATE BANK 2148 Market Street Camp Hill,PA 17011 INTEGRITY BANK c/o Clayton W.Davidson,Esquire/McNees,Wallace&Nurick,LLC 100 PINE ST PO BOX 1166 HARRISBURG,PA 17108 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER,ESQUIRE 22 S Duke Street Lancaster,PA 17602 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER,ESQUIRE 1570 Manheim Pike Lancaster,PA 17601 a ' 4.Name rdwddwss of the last recorded holder of every mortgage of record: PENNSYLVANIA STATE BANK 2148 Market Street P.O.Box 487 Camp Hill,PA 17011 ANDY KARTALIS 25505 Alberton Road Beechwood,OH 44122 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 48 South Terrace Road Wormleysburg,PA 17043 JOSEPH J.BARNES,ESQ. Two Gateway Center, 17 East 603 Stanwix Street Pittsburgh,PA 15222 1 verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED:J1 I hi By: KML LAW GROUP,PX Michael McKeever Pa.ID 56 29 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff X S"J vA P. R, c l I lc 3( 7'f�7 08-3029 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 (215)627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME IN THE COURT OF COMMON PLEAS LOAN TRUST 2005-DO1,ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 of Cumberland County 7105 Corporate Drive PTX C-35 Plano,TX 75024 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. C"`3 IRENE A.GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS Docket No. 08-3029 c 1 ^? ; Mortgagor(s)and Record Owner(s) _rrt - 48 South Terrace Road v�r Wormleysburg,PA 17043 'AW° Defendant(s) M THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS,WNE A. IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale,AZ 85259 Your house at 48 South Terrace Road,Wormleysburg,PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$700,959.85 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO 1,ASSET-BACKED CERTIFICATES, SERIES 2005-DO 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: 08-3029 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I,ASSET- BACKED CERTIFICATES, SERIES 2005-DO I,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(kkmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 6414217C. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 08-3029 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- IN THE COURT OF COMMON PLEAS DO1,ASSET-BACKED CERTIFICATES,SERIES 2005-DOI 7105 Corporate Drive of Cumberland County PTX C-35 Plano,TX 75024 CIVIL ACTION-LAW _ Plaintiff - =rn vs. ACTION OF MORTGAGE FORECLO1 ^y _z IRENE A.GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS Mortgagor(s)and Record Owner(s) Docket No.08-3029 ;. i 48 South Terrace Road 3 Wormleysburg,PA 17043 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS,IRENE A. IRENE A. GEKAS 48 South Terrace Road Wormleysburg,PA 17043 Your house at 48 South Terrace Road,Wormleysburg,PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$700,959.85 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO 1,ASSET-BACKED CERTIFICATES,SERIES 2005-DO 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: 08-3029 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO I,ASSET- BACKED CERTIFICATES, SERIES 2005-DO1,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.asnx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. f 08-3029 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 (215)627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME IN THE COURT OF COMMON PLEAS LOAN TRUST 2005-DO1,ASSET-BACKED CERTIFICATES, SERIES 2005-DO 1 of Cumberland County 7105 Corporate Drive PTX C-35 Plano,TX 75024 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE FORECLO3liRE 1:" vs. –0 U-3 IRENE A.GEKAS —� s.LL CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS Docket No. 08-3029 -<= �= Mortgagor(s)and Record Owner(s) 48 South Terrace Road Wormleysburg,PA 17043 _a r Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS,CONSTANTINE N.a/k/a DEAN N.GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale,AZ 85259 Your house at 48 South Terrace Road,Wormleysburg,PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$700,959.85 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO 1,ASSET-BACKED CERTIFICATES,SERIES 2005-DO 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: 08-3029 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DOI,ASSET- BACKED CERTIFICATES, SERIES 2005-DO I,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale.(See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 e 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http://www.phfa.org/consumers/homeowners/real.asRx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongkmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 6414217C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-3029 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- IN THE COURT OF COMMON PLEAS DOI,ASSET-BACKED CERTIFICATES,SERIES 2005-DO1 7105 Corporate Drive of Cumberland County PTX C-35 Plano,TX 75024 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE IRENE A.GEKAS CONSTANTINE N.GEKAS aWa DEAN N.GEKAS Mortgagor(s)and Record Owner(s) Docket No.08-3029 48 South Terrace Road _C:z Wormleysburg,PA 17043 �t:Ti Defendant(s) r"--„Z: 110 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING T( _ COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO 4 ; COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GEKAS,CONSTANTINE N.,&Wa DEAN N.GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg,PA 17043 Your house at 48 South Terrace Road,Wormleysburg,PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$700,959.85 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO 1,ASSET-BACKED CERTIFICATES, SERIES 2005-DO 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: 08-3029 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO 1,ASSET- BACKED CERTIFICATES, SERIES 2005-DO1,the back payments,late charges,costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hqp://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 08-3029 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.amx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention gkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64142FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 08-3029 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1,ASSET- BACKED CERTIFICATES,SERIES 2005-DO1, Plaintiff(s) From IRENE A. GEKAS and CONSTANTINE N.GEKAS a/k/a DEAN N. GEKAS (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: $700,959.85 L.L.: Interest from 12/18/13 to Date of Sale per diem @$118.91 Atty's Comm: Due Prothy: $2.25 Atty Paid: $534.68 Other Costs: Plaintiff Paid: Date: i2/19/13 Buell,Prot onotary Seal) By: Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone:215-627-1322 Supreme Court ID No.313897 KML Law Group, P.C. i €! �Pf?C�!HCi; ,. Suite 5000-BNY Independence Center L J 0 DEC 19 PM 12: 701 Market Street u ! Philadelphia,PA 19106-1532 COUNTY 215-627-1322 PENNS i LYA I Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF IN THE COURT OF COMMON SOUNDVIEW HOME LOAN TRUST 2005-DO1, PLEAS ASSET-BACKED CERTIFICATES, SERIES 2005- OF Cumberland COUNTY DO1 7105 Corporate Drive CIVIL ACTION-LAW PTX C-3 5 Plano,TX 75024 ACTION OF MORTGAGE FORECLOSURE vs. Term IRENE A. GEKAS and CONSTANTINE N. GEKAS No. 08-3029 a/k/a DEAN N. GEKAS Mortgagor(s) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) AMENDED CERTIFICATE OF SERVICE The undersigned,on behalf of Plaintiff,hereby certifies that on MAY 25";2010 he did serve upon Defendant(s)IRENE A. GEKAS and CONSTANTNNE N. GEKAS a/k/a DEAN N. GEKAS a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated July 7th 2008. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, By: KML Law Group,P.C. Nick Barone,Legal Assistant NBarone@Lunllawgroup.com 215-825-6365 (Direct Phone) , Form 3877 . Domestic l}3PS Firm Mailing Book -------------------------------------------------------------------------------- Name and Address of Sender: Permit Noodzez Sequence Number JOSEPH A GOLDBECK JR 3832A MELZ,ON INDEPENDENCE CENT 701 MARKET ST 8T3I 5000 }\ocezzt - MAC v7 ' 90 '8' 10'K PHILADELPHIA, PA 19106 -----------'-'-------------'---------------------------------'------ Piece zo Article o o°zive=r vud=""s oa ms r"°tavm v°z"° u°"u°= ua`qos xuaz Ins.,./Register n"e r"t°z ------------------------------ o^`^zrco-n: 7111434236300090 8505 2.80 1-39 5-29 12703 East Desert Co enue ERR 1-10 Scottsdale, AZ 852 64142rcn-u: nn^s*o 2.80 1'39 y ' 5'29 1.10 Scott- a«mzrco-cn.onnms4z313mooy x'no 1'39 5'29 48 South Terrace Road ERR 1'm ` Wormleysburg, PA 17043 64142vcn-IG.01711143423630009 8,536 GERAS IRENE A. C '3 IRENE ,'80 1'39 5.29 48 So.1th Terr e Road Ll gRR 1.m Wormleysburg, PA 17043 oo44pcp'mw n1ms*oemuoeuo�7 c 2.80 1.39 5.29 2105 re""i"gt"= Street // ERR 1'10 Harrisburg, PA 1710* - _____________________________________________________________________ Page Totals: 5 19.50 o.s a'm c"mplati.e Totals: , 19'50 o.os zo.^u ___--______--_-_--_-____-_-_-'_-_-__-__-__-___'_----_--_-`__----______'__-__- - USPS CERTIFICATION Total Number of Pieces Received: . . Round Stamp: Signature of Receiving Employee Form 3877 (I,aosiod'le) Date of Manifest: 05/25/201 8 Page 1 _ ��LL O m O � � u_ F. n rn U-: d } m ii 2�.5� -S O O (( � G��'S Y N' m aO c m w U Q k�s a rn Lr > v to L y<a " C] CD ISV�l u < O ZE Y m9 m j, ,, •-• E ..1 Y m U m � u Q m c m m ro 0 �°U M :� m m E E c v Ems° X � N�oy Em m Q 2D .. m � 0 c d 0 O a � a E °1 M U S 0 cd s m �Um Z � � ¢ m O r w Q o 0. C 4'f Q z lz m 0' Cf N r F_ o w 4) o � - V) ' z co m .17 w o 3 ° E z co P W CD N E ` Y fn o m w ° I LU 1 N m + O m X N a N 1 d 3 T U U O WE 00000 x m air m Q > E X cL) >> ° ll1 w Q O C/) i > U N N m Z O L °� : Ln m.''"- w j Z in N ao a o Do LO co w Q Q 9a m O Z _ m _ m Q 0' v U) w m 8 N z cr) O O a`� E c� ¢ 0 p �--it N O [n Zw co w U m Q N w 5 C' U r C13 o w!L r ; LtJ ti O U) F. ¢ N U m U N CO m m U)Q v i _ Ul! 0 QU6 C) `mE ao Ew r> UU- Q mowa<CL Z� € N w EJI—�_Jo W ZO u3.��ro a T� r N r7 uj co ti co L7 r- GOLDBECK WCAFFERTY& WKEEVER A Professional Corporation ATTORNEY FOR PLAINTIFF By: Thomas I. Puleo,Esquire Attorney I.D. #: 27615 Suite 5000—Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215 627-1322 DEUTSCHE BANK NATIONAL TRUST IN THE COURT OF COMMON PLEAS COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN OF CUMBERLAND COUNTY TRUST 2005-DO1,ASSET-BACKED CERTIFICATES,SERIES 2005-DOI CIVIL ACTION-LAW 7105 Corporate Drive PTX C-35 AMENDED ACTION OF MORTGAGE Plano,TX 75024 FORECLOSURE Plaintiff VS. Term No.08-3029 IRENE A.GEKAS and CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 Defendants AFFIDAVIT OF SERVICE I hereby certify that Plaintiff's Amended Complaint relative to the above captioned matter was served pursuant to Rule 440 by first class mail on pro se Defendants,IRENE A. GEKAS &CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS at 12703 East Desert Cove Avenue, Scottsdale,AZ 85259 on March 31, 2010. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsifications to authorities. GOLDBEC c AFFERTZ-& kEEVER A/ f Date: A. ." Thomas .Puleo,Esqui Attorney for Plaintiff $' KML LAW GROUP, P.C. 64142FC r Suite 5000 r- - -,: -CF-r,,, CF: 05/13/2008 r r ,- • BNY Mellon Independence Center i 1/4), i f,I -ROTHON',PI SD: 06104/2014 701 Market Street rA. $700,959.85 Philadelphia, PA 19106-1532 2dlifilAY 23 At 1 0, 3,z 215-627-1322 Attorney for Plaintiff CUt'llorEk Rill- AND rout,-.. DEUTSCHE BANK NATIONAL TRUST . "nliTS YL VA 'NI AN THE COURT OF COMMON PLEAS• COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUND VIEW HOME LOAN TRUST 2005- , of Cumberland ounty D01, ASSET-BACKED CERTIFICATES, SERIES 2005-D01 CIVIL ACTION — LAW 7105 Corporate Drive ' PTX C-35 ACTION OF MORTGAGE FORECLOSURE Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 08-3029 Veronica Cosme, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants Of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. (X) Premises was posted by Sheriffs Office/competent adult (copyof return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). (X) • Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, BY: Veronica Cosme Legal Assistant • IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DOl; et seq. Plaintiff (Petitioner) V. IRENE A. GEKAS; et al. Defendant (Respondent) CASE and/or DOCKET No.: 08-3029 Sheriff's Sale Date: 6/4/2014 AFFIDAVIT OF SERVICE (_,I Complaint El Summons g Other: NOTICE OF SALE I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served IRENE A. GEKAS the above process on the 16 day of January, 2014, at 12:40 o'clock, PM, at 48 South Terrace Road Wormleysburg, PA 17043 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: I) 2) 3) Commonwealth/State of P 41 V&A. County of 130--5 r ) SS: Before me, the undersigned notary public, this day%ersonally, appeared duly sworn according to law, deposes the fo o A g 1 hereby swear or affirm that. fac- in the foregoing Affidavit of Service are true and correct. I.ic ks (Si File Number:64142F• Case ID #:3866048 re of Affiant) to me known, who being Subscribed and sworn to before me this I +—day of TA -N , 20 I . COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Teresa Minzola, Notary Public Washington Township, Barks County MY Commission Expires December 05, 2017 Notary Public ---------1 1 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DOI, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1; et seq. Plaintiff (Petitioner) V. IRENE A. GEKAS; et al. Defendant (Respondent) CASE and/or DOCKET No.: 08-3029 Sheriffs Sale Date: 6/4/2014 AFFIDAVIT OF SERVICE n Complaint 1E1 Summons Q Other: NOTICE OF SALE I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served CONSTANTINE N. GEKAS A/K/A DEAN N. GEKAS the above process on the 16 day of January, 2014, at 12:40 o'clock, PM, at 48 South Terrace Road Wormleysburg, PA 17043 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) (�2) 3) PQ I Commonwealth/State of n 4L I Y VoLiA .oL- County of ) SS: Before me, the undersigned notary public, : day, personally, appeared duly sworn according to law, depose + ; - . owing: I hereby swear or affir 'ths ti s .et forth in the foregoing Affidavit of Service are true and correct. ignature of Affiant) File Number:641 FC Case ID #:38660 8 to me known, who being - Subscribed and sworn to before me this 13—day of TA -N . , 20 I' . Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Teresa Minzola, Notary Public Washington Township, Barka County My Commission Expires December 06, 2017 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUND VIEW HOME LOAN TRUST 2005-D01, ASSET-BACKED CERTIFICATES, SERIES 2005-D01 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. IRENE A. GEKAS and CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY 08-3029 ORDER AND NOW, this 174-hday ofJLL\ y 2008, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants, by posting a copy of the Complaint upon the premises 48 South Terrace Road, Wormleysburg, PA, 17043, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 12703 East Desert Cove Avenue, Scottsdale, AZ 85259, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants, by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE COURT: fc/A A Ueil Distribution list: Michael T. McKeever, Esquire, Suite 5000 — Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 IRENE A. GEKAS, 12703 East Desert Cove Avenue Scottsdale, AZ 85259 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS, 12703 East Desert Cove Avenue Scottsdale, AZ 85259 r tint:Your Documents:: age3of6.` USPS; Mani f est. Nlailin,g::System Iylaitef s Neme 8 Address _ KML Law Group 701` f✓farket;Street. Suite 500b RMladelphia PA 19106 • • :. Article Y Pto'oe 16 fid1rbssee.Nanie' Delivery Address Permit Number 123:,.:_ Sequence Number: 1783-2 ES Type: Posia06: MAC Ver. Number.: Connr=cfShiq Firo'gistics fi`5: lass of l.Aail . Mixed ES Insurance_ . Fee Amou11: Oue/' a, Sender roia1 Chai9e. • 97719999017033§0064759 9.17i9999s1703360o64760. 0171999991793360064773 9177099991703360064780 :291 WYATTROAD. 'Fiarra4urg :PA 7104: SLOANE:JENNIFER R. .P O; Bax 60214 Rtirfi�'burg pA:1711. 0 ERR ERR . 'SL0A10!:JONt FEE R� 260 WasfnnOfon Ayende- Api C10' . 13roolAyn NY 1.1205214: YANBEKOd PAVEL.RI PEtdcasllury PA:19385 y� 9171999991703380pB479T • 9171§9999170336.0064803 9171999991703360084810; 9,1119999917.0.336006,4627 9171999991.703360064.834` .9.17.1999991703360064841 917'f999991703360084.858 9171499907033600496,5 YMBEKgV; PAVt .R� . 73 prexetbrook Qn4 00 Dmx4t H01 PA,19025 tQTZ:;$UZETTE , 91 asemon1 Avbnue�. • M0.1erri,PA;19335 iURtCHi;AMYS. 2523:$Renck:Read' 446.4lin; PA 17545 `OLEWILERiTIN M, 5544 Moreland Court • Mechpn(cs0urg,;P.A 17050 :i(ULP; KRIS E, 242 W Columbia ;Rc i : ,Enola,PA17925� . • kUiP, wiiss,. X20 W tz�lie Road: _Lnola';:PA:17025, • ERR ERR e' ERR ERR G ERR ERR e 6EiCAS,° COh15TM171NE.N:,.a� 1?E/iN li_ Gf:ISAS' R.. 48 Sbufh Terrace, oadl ERR 1Normiey2(iyirg,,PA17043; G .. St QANE, JENNIFER 5455 Pond Road Jiarris647$.1'A;11111 ERR 0 . 0;7Op: 9;700; 0.700 0;700. -ONO 0;700. 0:790 Q:700' 0.100. .1j00 .:700 1..35 3.3U 1,35 : 1.35:. x.30. 1.35' 330 3,30 _35 3,30. 1,35 3.30 1,35 3,30 1.35 3.30. 1:35, 1,3.5 3.30. 1.35 3.30. '545 5.55 ,. • 5;55 5:55 5:55 ;5:05 5;55 :555 Pa.'ge,T6tafs' CLUnulative.Totais 36: http.:1/00*-nOtiiit6V020live/pi:pjeq,s/imAg6.aspx?pcb-1.: 8.40 • 25.20. 55;80, 167,40 6.6.60; 2/4/201:4. - Page:1 of 5>"; • USPS Mai fest Mailing System. Mailers Name':& Address KMLLawGroup' 701,Marl etSi'reet. Swte:5000 Phil'aiielphla PA..19106, Permit Number 123 Sequence Number 1783 2:; MAC Ver; ('lumber:. ConnectSf ip Proglstics 6.5 Glass of Mail Mixed • i.4616:0: •Atidreseea.NarRe; 1:!le4e JD. Oeliyery Address" ES Typo Postage. Insurance Amount,.; Duel Sender Ttital: Charge' 9171999991703360064513'' s ti."6, 9991305 0i564,V0 • WAISLEY DANIELJ. 21 Carlisle Lane; 94;neen 5020020, ;_21 CadlsteLand Ogmdon SC 29029 91.7108999170336006453''., 9171999991703360064551 917.1:99999170336U064558 917: 199999170336005457:5 1.71999991103360064582: • 9171999991703360064599• Vi-r,1009.0.1103'3606.46o5 017.1989991703369064612 9110999,917033640fi4529 P...age Totals CGrriolahvo7ot0I .VORGANG LORi:At41,i 239 Oeer Rqn D.r.(4 Honey BrooK PA.19144' WASSONi:IRII4A:0, 73Diezelbraok DAve ApLB' 'brace!.i1151 SPA?19026, ERR. 0 ERR: C' ERR; C. 'ERR C.;. x;100: 3.30: • 1.30.:.. 5:55 0:700 0.700: 91 Rosemont Avenue . ; lelvem;:P.A 10335; .0 CE!(L+Si 1,12€44. .48tSuth Tolraeg Road WonnloysbLrg 'PA;57041. ERR C 'OEXAS',:0:1$TAIThNE N. a/Wa 06'0 .-GEKAS: 1270' East Dosertl'bv4 Avenue ERR Seollsdale AZ 115259„ :C :GEKAS, IRENC A:. 12103 East Eyeseil Crive: A4enue: .'Sdotisdale AZ 3.52.,59;; PECit SONORA Ki .55 Red Sned Road: Shlppensburg );f2.,5 •-• • SPECK ,. BRIAN K., 85 Red'Shod Rpod' 0:00/1ensburg,PA172.57 • • I.OWRIE; T.M ti C.: 1.633 Marhe SI 4el.' ..HeYris6, rg,PA j l.o3 LQWRIFTAMRA'C,; • 5258. Wynnewood Road 'Aparimem :Hdnisb:ur9, PA 11:109. . 'ERR: C 0;790: p;700 0;700 0:700.• 0700 ERR' C ERR` C..... 0;700 0.700 ERR: C- ERR: C- 8;40i 3-30. 1;35:' 1:15: 3,30• 1135; 3130.: 3130:: -55.80 55,80 5,65 5.55 5.55. $ ;55 5.55' 5.55. 68:.60 http %%pbpc/sendsuu to%201ive/projecfis/.'image aspx?pd I Name and Address of Sender AML LAW GROUP, P.C. iUITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified ❑ Recorded Delivery (International) ❑ COD ❑ Registered E Delivery Confirmation 0 Return Receipt for Merchandise 0 Express Mail 0 Signature Confirmation 0 Insured Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt*r4. {'� •.i• %'• {F 1 •L:�;. ` ' ,p' ESRC „p5 3 98,71,,_. 0 2 00n .- MAILED ROM j1 tm—imit",-ftaaziallecrmigraist,z, ZiPCOpE4 <" r„tiE �7• AOVVFS �40 9 106 • T Article Number m Addressee (Nae, Street, City, State, & ZIP Cade) Postage Fee Handling Charge Act !,‘,i63,4;147 if F : 1. GEKAS, IRENE A. 48 South Terrace Road Wormleysburg, PA 17043 TF'.. r . 2. GEKAS, CONSTANTINE N., a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 GEKAS, IRENE A. 3. . ,t ` 12703 East Desert Cove Avenue Scottsdale, AZ 85259 GEKAS, CONSTANTINE N. a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue '-+f 4. y 2 !J ". R Scottsdale, AL Sb2b9 5. 6. 7. 8. Total Number of Pieces Listed by Sender t J Number of Pieces? Received/at Post Off Postmaster, Per (Name of r ceivin employee) 7i See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Pag4 oft i Complete by Typewriter, Ink, or Ball Point Pen 64142FC Cumberland County Sale Date: 06/04/2014 IRENE A. GEKAS & CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Name and Address of Sender :ML LAW GROUP, P.C. ;UTE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified ❑ Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail E Signature Confirmation ❑ Insured Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt , t'f• •T� .;�y'�G� �'—� f, O 1... .A • ;<"'w' 0 ,•, 0004285957 +i • MAILED p c '• � 2 IPA FROM ® � marammv PITNEY $ FEB04 ZIP BOWLSp 03.600 CODE 2014 19106 , , Article Number Addressee (Name, Street, City, State, & ZIP Cade) Postage Fee Handling, Charge g RR Fee 1. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of 2. Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 3. - l; REISMAN DAVID LAWN SERVICE, INC. 4705 Gettysburg Road Mechanicsburg, PA 17055 INTEGRITY BANK ct 4. r:. 3345 Market Street Camp Hill, PA 17011 DEUTSCHE BANK NATIONAL TRUST c/o PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK cul STE 4460 5. Philadelphia, PA 19103 DEUTSCHE BANK NATIONAL TRUST 7105 Corporate Drive Plano, TX 75024 6. PENNSYLVANIA STATE BANK c/o Thomas G. Klingensmith, Esquire, Gingrich, Smith, Klingensmith & Dolan 45 East Orange Street 7 Lancaster, PA 17602 PENNSYLVANIA STATE BANK 2148 Market Street Camp Hill, PA 17011 8. Total Number of PiecesOTotal Listed by Sender Q Number of Pieces Received at Post Offce/, Postmaster, r (N me of receiving employee) , See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Pagq/ of) 64142FC Cumberland County Sale Date: 06/04/2014 IRENE A. GEKAS & CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Complete by Typewriter, Ink, or Ball Point Pen �$J Name and Address of Sender 'ML LAW GROUP, P.C. iUITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified CI Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt i'+� •. t',:• :^.'.',.�; �-t:!'b 11 'f• ,�gPCS O�. �'t ` 02 AA 0004285957 FROM zip .e E" $ 03.22 FE804 cODE 5 2p14 19108 0 , Article Number Addressee (Name, Street City, State, & ZIP Code) Postage Fee Handling Charge $c : • • RR Fee 1. INTEGRITY BANK do Clayton W. Davidson, Esquire/McNees, Wallace & Nurick, LLC q 100 PINE ST PO BOX 1166 — �- :.. •�: , 2 : .. / l r�� 9 . q.>1 o a "; HARRISBURG, PA 17108 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER, ESQUIRE 22 S Duke Street } ,rte.. 3, r !` s 1 i r_ti ;w t Lancaster, PA 17602 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER, ESQUIRE 1570 Manheim Pike 4• •– » , - _.` Lancaster, PA 17601 PENNSYLVANIA STATE BANK 2148 Market Street 5 P.O. Box 487 Camp Hill, PA 17011 ANDY KARTALIS 25505 Alberton Road 6. Beechwood, OH 44122 TENANTS/OCCUPANTS 48 South Terrace Road 7. Wormleysburg, PA 17043 JOSEPH J. BARNES, ESQ. Two Gateway Center, 17 East 8' .• - wx -e Pittsburgh, PA 15222 Total Number of Pieces,....,,Total Listed by Sende Number of Pieces Received at Post office Postmaster, P r Name of receiving employee) �/ See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page)o) 64142FC Cumberland County Sale Date: 06/04/2014 IRENE A. GEKAS & CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Complete by Typewriter, Ink, or Ball Point Pen $� Name and Address of Sender :ML LAW GROUP, P.C. i UITE 5000 UElCOD 01 MARKET STREET EET 9106-1532 Check type of mail or service; ❑ Certified ❑ Recorded Delivery (International) CIRegistered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here (If issued as a . certificate of mailing, , or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee 1. ANDREW KARTALIS 25505 Halburton Road Beachwood, OH 44122 •• 0 r 0 gz�d O 0 _a.t . l � to n�C 2. BOROUGH OF WORMLEYSBURG 20 Market Street Wormleysburg, PA 17043.0:"-;7"I• \r• : le, `'`1 i c,", 3. CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013-3387 to ) N - -.A Z. '9'01\ 5. � 7.9106 vr- } A f 4 6. 7. 8. Total Number of PiecesTotal Listed by Sender n Number of Pi s Received at Post a Postmaster, Per of ceiving employee) See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) omplete by Typewriter, Ink, or Ball Point Pen 64142FC Cumberland County Sale Date: 06/04/2014 IRENE A. GEKAS & CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005- DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3029 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 48 South Terrace Road Wormleysburg, PA 17043 1.Name and address of Owner(s) or Reputed Owner(s): IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 2. Name and address of Defendant(s) in the judgment: IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 REISMAN DAVID LAWN SERVICE, INC. 4705 Gettysburg Road Mechanicsburg, PA 17055 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 DEUTSCHE BANK NATIONAL TRUST do PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK Boulevard STE 1400 Philadelphia, PA 19103 DEUTSCHE BANK NATIONAL TRUST 7105 Corporate Drive Plano, TX 75024 PENNSYLVANIA STATE BANK c/o Thomas G. Klingensmith, Esquire, Gingrich, Smith, Klingensmith & Dolan 45 East Orange Street Lancaster, PA 17602 PENNSYLVANIA STATE BANK 2148 Market Street Camp Hill, PA 17011 INTEGRITY BANK do Clayton W. Davidson, Esquire/McNees, Wallace & Nurick, LLC 100 PINE ST PO BOX 1166 HARRISBURG, PA 17108 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER, ESQUIRE 22 S Duke Street Lancaster, PA 17602 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER, ESQUIRE 1570 Manheim Pike Lancaster, PA 17601 BOROUGH. OF WORMLEYSBURG 20 Market Street Wormleysburg, PA 17043 CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013-3387 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA STATE BANK 2148 Market Street P.O. Box 487 Camp Hill, PA 17011 ANDY KARTALIS 25505 Alberton Road Beechwood, OH 44122 ANDREW KARTALIS 25505 Halburton Road Beachwood, OH 44122 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 48 South Terrace Road Wormleysburg, PA 17043 JOSEPH J. BARNES, ESQ. Two Gateway Center, 17 East 603 Stanwix Street Pittsburgh, PA 15222 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 20, 2014 KML Law Group, P.C. BY: Veronica Cosme Legal Assistant KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s) and Record Owner(s) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3029 NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for June 04, 2014 at 10:00 AM in the above captioned matter has been continued until July 02,2014 at 10:00 AM Date: By: KML LAW G11OUP, P.C. 701 Market Street, Suite 5000 Philadelphia, PA 19106 (215) 825-6332 Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 ./ Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff ) • KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 ' -'a' �(, ' E . Attorney for Plaintiff fJf :Eft r r 'ENNsYLVva°iu' '� DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS IN THE COURT OF COMMON PLEAS OF SOUNDVIEW HOME LOAN TRUST 2005- DO1,ASSET-BACKED CERTIFICATES, SERIES of Cumberland County 2005-DOI 7105 Corporate Drive CIVIL ACTION—LAW PTX C-35 Plano, TX 75024 ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. Term No. 08-3029 IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS Mortgagor(s)and Record Owner(s) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) CERTIFICATE OF SERVICE I hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of Continued Sheriffs Sale in the above upon the following parties on the date listed below: IRENE A.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS 48 South Terrace Road Wormleysburg,PA 17043 Defendants SHERIFF OF CUMBERLAND COUNTY Sheriff's Office 1 Courthouse Square Carlisle,PA 17013 (via facsimile 717-240-6397) PROTHONOTARY OF CUMBERLAND COUNTY Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 (via e-filing if applicable) Date: (PI(011 By: PaA,-40Ce-cdt KML LAW GROUP,P.C. 701 Market Street, Suite 5000 Philadelphia,PA 19106 (215)825-6332 Paul Boccuti 1 KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST IN THE COURT OF COMMON PLEAS COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, of Cumberland County ASSET-BACKED CERTIFICATES,SERIES 2005- DO1 7105 Corporate Drive CIVIL ACTION-LAW PTX C-35 Plano,TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. No. 08-3029 IRENE A.GEKAS CONSTANTINE N.GEKAS a/k/a DEAN N.GEKAS Mortgagor(s)and Record Owner(s) 48 South Terrace Road Wormleysburg,PA 17043 Defendant(s) NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for July 02,2014 at 10:00 AM in the above matter has been continued until August 06,2014 at 10:00 AM Date: (AO 1By: 1�/ KML LA GROUP,P.C. 701 Market Street, Suite 5000 Philadelphia,PA 19106 (215)825-6332 Michael McKeever Pa.ID 56129 David Fein Pa. ID 82628 Jill P.Jenkins Pa. 1D 306588 Alyk L.Oflazian Pa. ID 312912 vatore Filippello Pa.ID 313897 Jennifer Lynn Frechie Pa.ID 316160 Attorneys for Plaintiff 4: Wand- ss -of the lftst recorded holder of every mo gage of record: PENNSYLVANIA STATE BANK 2148 Market Street P.O. Box 487 Camp Hill, PA 17011 ANDY KARTALIS 25505 Alberton Road Beechwood, OH 44122 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 48 South Terrace Road Wormleysburg, PA 17043 JOSEPH J. BARNES, ESQ. Two Gateway Center, 17 East 603 Stanwix Street Pittsburgh, PA 15222 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: / 17'13 By: AW GROUP, P.0 Michael McKeever Pa. ID 56 29 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff X S1vr( %,` ,�1, Jl' 3( Ti97 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 'SHERIFF'S OFFICE OF CUMBERLAND COUNTY r«. PF f,� 2x14 OOT 24 4H g:.. 2 CUMBER,LANI) PENNSYLVANIA TY M1l of Cit F OP ThE SliEWiFF Deutsche Bank National Trust Company vs. Case Number Constantine N Gekas (et al.) 2008-3029 SHERIFF'S RETURN OF SERVICE 03/28/2014 06:52 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 48 South Terrace Road, Wormleysburg - Borough, Wormleysburg, PA 17043, Cumberland County. 06/02/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 7/2/2014 06/18/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 8/6/2014 08/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $6,279.27 October 22, 2014 c) C,ourdySu:re S?,eritf,'t'el oscft. ,,c SO ANSWERS, RONIVY R ANDERSON, SHERIFF ib-te 304' er- u� c) U. r C, i cD c_.) U - �• ,`, CD U-.. c.3 On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA, Known and numbered 48 South Terrace Road, Wormleysburg as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 3, 2014 By: Real Estate Coordinator a LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2008-3029 Civil Term Deutsche Bank National Trust Company vs. Constantine N. Gekas Irene A. Gekas Atty.: Michael McKeever ALL that certain piece or parcel of land, situate in the Borough of Worrn- leysburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and de- scribed as follows, to wit: BEGINNING at a point on the western line of Greenwood circle at the Southern line of lands now or late of Harold A. Herre and Jane M. Herre, his wife; thence along the western line of Greenwood Circle, in a southwardly direction, a distance of one hundred fifty (150) feet to a point to line of other lands now or late of Robert M: Mumma and Barbara M. Mumma, his wife; thence along said other lands now or late of Robert M. Mumma and Barbara M. Mumma, his wife, in a westwardly direction by a line parallel to the southern line of lands now or late of Harold A. Herre and Jane M. Herre, his wife, a dis- tance of two hundred fifty (250) feet, more or less, to a point on the eastern line of Lot No. 45 on said hereinafter mentioned Plan of Lots, the line of lands now or late of Edwin B. Romig and Virginia Romig, his wife; thence along said eastern line of Lot No. 45 in said hereinafter mentioned Plan of Lots and the eastern line of Lot No. 44 on said Plan, in a northwardly direc- tion, a distance of one hundred fifty (150) feet to a point on the southern line of lands now or late of Harold A. Herre and Jane M. Here, his wife; and thence along said southern line of Harold A. Herre and Jane M. Herre, his wife, in an eastwardly direction a distance of two hundred fifty (250) feet, more or less, to a point on the western line of Greenwood Circle, the place of BEGINNING. BEING the southern one-half (1/2) of Lot No. 47 and the northern part of Lot No. 48 on the Revised Plan of Pennsboro Manor as recorded in the Office for the Recording of Deeds in and for the County of Cumberland in Plan Book 3, Page 6. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Borough of Worm- leysburg. BEING PREMISES: 48 South Ter- race Road Wormleysburg PA 17043. SOLD as the property of CON- STANTINE N. GEKAS a/kJa DEAN N. GEKAS and IRENE A. GEKAS, TAX PARCEL # 47-20-1856-032. BEING the same premises which Dean N. Gekas a/k/a Constantine N. Gekas and Irene A. Gekas, husband and wife by deed dated 2/18/2005 and recorded 3/7/2005 in Cumber- land County in Deed Book Volume 267 at Page 4178 granted and con- veyed unto Constantine N. Gekas and Irene A. Gekas, husband and wife. 58 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: April 18, April 25 and May 2, 2014 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. SWORN TO AND SUBSCRIBED before me this 2 da of May, 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A GOWNS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. 2020°Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the patriotNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds lin in Miscellaneous Book "M", Volume 14, Page 317. Irene A. �. Atty: Michael McKeever AL that certain piece or parcel of nd, situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth d subscribed before me his This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 .................... of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western line of Greenwood circle at the Southern line of lands now or late of Harold A. Herre and Jane M. Herre, his wife; thence along the .�_. _ __ _,.c r_,,,,«..�..,� rirr10. day of May, 2 . 14 A. Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES KML Law Group, P.C> Suite 5000 — BNY Ind.-.ip indence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DOI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record Owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 08-3029 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 48 South Terrace Road Wormleysburg, PA 17043 1.Name and address of Owner(s) or Reputed Owner(s): IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale AZ 85259 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale AZ 85259 2. Name and address of Defendant(s) in the judgment: IRENE A. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 IRENE A. GEKAS 12703 East Desert Cove Avenue Scottsdale AZ 85259 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 48 South Terrace Road Wormleysburg, PA 17043 CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS 12703 East Desert Cove Avenue Scottsdale AZ 85259 t 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 REISMAN DAVID LAWN SERVICE, INC. 4705 Gettysburg Road Mechanicsburg, PA 17055 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 DEUTSCHE BANK NATIONAL TRUST do PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK Boulevard STE 1400 Philadelphia, PA 19.103 DEUTSCHE BANK NATIONAL TRUST 7105 Coiporate'Drive' • - Plano, TX 75024 PENNSYLVANIA STATE BANK do Thomas G. Klingensmith, Esquire, Gingrich, Smith, Klingensmith & Dolan 45 East Orange Street Lancaster, PA 17602 PENNSYLVANIA STATE BANK 2148 Market Street Camp Hill, PA 17011 INTEGRITY BANK do Clayton W. Davidson, Esquire/McNees, Wallace 100 PINE ST PO BOX 1166 HARRISBURG, PA 17108 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER, ESQUIRE 22 S Duke Street Lancaster, PA 17602 SUSQUEHANNA BANK PA C/O BARRY HANDWERGER, ESQUIRE 1570 Manheim Pike Lancaster, PA 17601 Nurick, LLC ALL that certain piece or parcel of land, situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western line of Greenwood circle at the Southern line of lands now or late of Harold A. Herre and Jane M. Herre, his wife; thence along the western line of Greenwood Circle, in a southwardly direction, a distance of one hundred fifty (150) feet to a point to line of other lands now or late of Robert M. Mumma and Barbara M. Mumma, his wife; thence along said other lands now or late of Robert M. Mumma and Barbara M. Mumma, his wife, in a westwardly direction by a line parallel to the southern line of lands now or late of Harold A. Herre and Jane M. Herre, his wife, a distance of two hundred fifty (250) feet, more or less, to a point on the eastern line of Lot No. 45 on said hereinafter mentioned Plan of Lots, the line of lands now or late of Edwin B. Romig and Virginia Romig, his wife; thence along said eastern line of Lot No. 45 in said hereinafter mentioned Plan of Lots and the eastern line of Lot No. 44 on said Plan, in a northwardly direction, a distance of one hundred fifty (150) feet to a point on the southern line of lands now or late of Harold A. Herre and Jane M. Here, his wife; and thence along said southern line of Harold A. Herre and Jane M. Herne, his wife, in an eastwardly direction a distance of two hundred fifty (250) feet, more or less, to a point on the western line of Greenwood Circle, the place of BEGINNING. BEING the southern one-half (1/2) of Lot No. 47 and the northern part of Lot No. 48 on the Revised Plan of Pennsboro Manor as recorded in the Office for the Recording of Deeds in and for the County of Cumberland in Plan Book 3, Page 6. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Borough of Wormleysburg BEING PREMISES: 48 South Terrace Road Wormleysburg PA 17043 SOLD as the property of CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS and IRENE A. GEKAS, TAX PARCEL # 47-20-1856-032 BEING the same premises which Dean N. Gekas a/k/a Constantine N. Gekas and Irene A. Gekas, husband and wife by deed dated 2/18/2005 and recorded 3/7/2005 in Cumberland County in Deed Book Volume 267 at Page 4178 granted and conveyed unto Constantine N. Gekas and Irene A. Gekas, husband and wife. 1 KML LAW GROUP, P.C... - - Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6312 Attorney for Plaintiff n� Ji uuLit'i L'!i NIf, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DO1 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 IN THE COURT OF COMMON PLEAS of Cumberland County No. 08-3029 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. By: i(VJ KML LAW GR I ' , ' .C. Michael Mc -ever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Attorney ID 313897 Attorneys for Plaintiff fun Wit):3\cts0o Tct C)LVT) 1) IML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE HOLDERS OF SOUNDVIEW HOME LOAN TRUST 2005-DO1, ASSET-BACKED CERTIFICATES, SERIES 2005-DOl 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IRENE A. GEKAS CONSTANTINE N. GEKAS a/k/a DEAN N. GEKAS (Mortgagor(s) and Record owner(s)) 48 South Terrace Road Wormleysburg, PA 17043 IN THE COURT OF COMMON PLEAS of Cumberland County PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Settled, Discontinued and Ended with prejudice upon payment of your costs only. By: KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 /Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff