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Home My WebLink About08-3273UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 VCHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust :COURT OF COMMON PLEAS Company as Trustee for HSI :CIVIL DIVISION Asset Securitization Corporation 2006-OPT4 Mortgage :Cumberland Pass-Through Certificates, Series 2006-OPT4 6501 Irvine Center Drive Irvine, CA 92618-2118 Plaintiff V. Richard C. Hamilton County Jane M. Hamilton € NO. Q$- 3x73 209 East Winding Hill Road Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE ?iv; t7er%% YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 1 ? AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demanders en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IML EDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 I 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Option One Mortgage Corporation Assignments of Record to: Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 209 East Winding Hill Road MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Allen Township COUNTY: Cumberland DATE EXECUTED: 11/29/05 DATE RECORDED: 12/9/05 BOOK: 1933 PAGE: 4535 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said mortgage as of 5/17/08: Principal of debt due $121,475.57 Unpaid Interest at 10.25%* from 9/1/07 to 5/17/08 (the per diem interest accruing on this debt is $34.11 and that sum should be added each day after 5/17/08) 7,969.65 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $248.04 and that sum should be added on the first of each month after 5/17/08) 359.17 Late Charges ( hl mont yy late charge of $65.87 should be added in accordance with the terms of the note each month after 5/17/08) 481.15 Recoverable Balance 85.00 Attorneys Fees (anticipated and actual to 5% of principal) 6,073.78 TOTAL $137,049.32 *This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant (s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $137,049.32 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the mortgaged premises. UDREN LAW OFFICES, P.C. BY: VA Vili1 1 1I (t & f L6_ Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ALL THAT CERTAIN tract of land ninth the improvements thereon erected situate in the Township of Upper Allen, Cumberland County, Pennsylvania, bounded and desen'bed as follows, to grit: BEGINNING at a nail in the center line of West Winding Hill Road (L.R.21025) at line of land now or formerly of Mrs. Ellen Eberly; thence by the center Bare of said public road. North 87 degrees 10 minutes West 130 feet, to a nail in the same and at line of land. now or formerly of Evelyn Finnif thence by the latter'land, North 2 degrees 30 minutes East 166.5 feet, to an iron pipe on line of other land now or formerly of Carl A. Wentz and wife; thence by the latter land, South 87 degrees 10 minutes East 84 feet, to a stake at the Eberly land; thence by the latter, South 13 degrees 30 minutes East 173 feet more or less, to the PLACE OF RMUNNING. HAVING THEREON ERECTED a brick and frame dwelling known as 209 E. Winding Hill Road. TMDO 0 7DO o w -I O CD ao a o ' b Z) rL ?4 8°= fD y m y o N 0) (D m m? R pp rN? CD y ?p O CO ( D R N H a ID m m ? . =MR _ *a w Z E0 n°= _ r c?3 Lc S) a _ _ r ? r ru D 0 U-1 o = " ? rn N i O - On EXHIBIT A W ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROBRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 9 FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. December 19, 2007 Richard C Hamilton 209 E Winding Hill Rd Mechanicsburg, PA 17055-5621 Homeowners Name: Richard C Hamilton Jane M Hamilton Property Address: 209 E Winding Hill Rd, Mechanicsburg PA 17055 Loan Account No.: 0020033155 Original Lender: OPTION ONE MORTGAGE CORPORATION Current Lender/Servicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE 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 OP010 (Page 1 of 9) M 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, or you may find them by visiting the website at http://www.phfa.org/ applications/counseling_agencies.aspx. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions to schedule one face-to-face meeting. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. (Page 2 of 9) OP010 026 R31 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. (Page 3 of 9) OP011 017 R31 c Re: Loan No. 0020033155 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IF 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. 209 E Winding Hill Rd, Mechanicsburg PA 17055 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 payments: 3 MONTHS @ $ 1,091.40 MONTHS @ $.00 $ 3274.20 (b) Previous late charges; $ 151.80 (c) Other charges; Escrow, Inspection, NSF checks $ .00 (d) Other provisions of the mortgage obligation, if any $ 0.00 (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 3426.00 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): OP012 (Page 4 of 9) 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 $3426.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Overnight Mail Address Western Union Quick Collect 4600 Touchton Rd E Pay to: Option One Mortgage Corporation Bldg 200 Ste 102 Code City: OptionJax, F1 Jacksonville, FL 32246 Mailstop: J1 CASH You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable.) (Page 5 of 9) OP012 024 R31 e Re: Loan No. 0020033155 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 Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage 02013 (Page 6 of 9) 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 Sheriff's Sale of the mortgaged property could be held would be approximately (6) SIX Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. (Page 7 of 9) 02013 021 R31 Re: Loan No. 0020033155 HOW TO CONTACT THE LENDER: Name of Lender: Option One Mortgage Corporation Address: 4600 Touchton Rd East Bldg 200 Ste 102 Attn: Trivonda Porter, Sara Haliko and Selena Moore Address: Jacksonville, FL 32246 Phone Number: 904-996-1730 or 1-800 -326-1500 ext.61730 Fax Number: 1-866-497-1263 Contact Persons: Trivonda Porter, Sara Haliko and Selena Moore office hours: Monday through Friday 8:00 a.m. to 5:00 p.m. EST Email Address: PHFA@OOMC.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's 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 or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO:- * 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 CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT 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. OP014 (Page 8 of 9) * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS DOES NOT IMPLY THAT OPTION ONE IS ATTEMPTING TO COLLECT MONEY FROM ANYONE WHOSE DEBT HAS BEEN DISCHARGED UNDER THE BANKRUPTCY LAWS OF THE UNITED STATES. (Page 9 of 9) OP014 039 R31 2 a?° co P6?o ° co ?o o ? ix I? a- 7 ? ?a. o , D 0 ?7 o m ? 7 r^ C'1 y b _ W T N N (P LTi OP? Q W ?? y N C -1 m ? W ? m fD Cp O~ U G7t S O L? 0 CD - LLj > C Z - 2 = e)- a) _ ru Ln W Z .+ CG) M 3: - ru D = 0 = cn ?s Ln 4 = C Ln = Ul N LL) a ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM meet with the Counseling Agency. LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROBRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. December 19, 2007 Jane M Hamilton 209 E Winding Hill Rd Mechanicsburg PA 17055 Homeowners Name: Richard C Hamilton Jane M Hamilton Property Address: 209 E Winding Hill Rd, Mechanicsburg PA 17055 Loan Account No.: 0020033155 Original Lender: OPTION ONE MORTGAGE CORPORATION Current Lender/Servicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE 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 OP840 (Page 1 of 9) FIA- 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 CURT 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, or you may find them by visiting the website at http://www.phfa.org/ applications/counseling agencies.aspx. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions to schedule one face-to-face meeting. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. (Page 2 of 9) 02840 017 R35 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. (Page 3 of 9) 02841 013 R35 TM Re: Loan No. 0020033155 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: 209 E Winding Hill Rd, Mechanicsbur PA 17055 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 payments: 3 MONTHS @ $ 1,091.40 MONTHS @ $.00 (b) Previous late charges; (c) Other charges; Escrow, Inspection, NSF checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 3274.20 $ 151.80 $ .00 0.00 3426.00 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): OP842 (Page 4 of 9) 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 $3426.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Overnight Mail Address Western Union Quick Collect 4600 Touchton Rd E Pay to: Option One Mortgage Corporation Bldg 200 Ste 102 Code City: OptionJax, FL Jacksonville, FL 32246 Mailstop: J1 CASH You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable.) (Page 5 of 9) OP842 019 R35 Re: Loan No. 0020033155 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the THIRTY (30) DAYS of the date of this Notice, the lender exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this considered due immedi t 1 debt will be a e y 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 re uured to ay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus ablate or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and an other costs connected with the Sheriff's Sale as specified in writing b the lender and by performing any other requirements under the mortgage. OP843 (Page 6 of 9) default within intends to 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 Sheriff's Sale of the mortgaged property could be held would be approximately (6) SIX Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. (Page 7 of 9) 02843 012 R35 Re: Loan No. 0020033155 HOW TO CONTACT THE LENDER: Name of Lender: Option One Mortgage Corporation Address: 4600 Touchton Road East Bldg 200 Ste 102 Attn: Trivonda Porter, Sara Haliko and Selena Moore Address: Jacksonville, FL 32246 Phone Number: 904-996-1730 or 1-800-326-1500 ext. 61730 Fax Number: 1-866-497-1263 Contact Persons: Trivonda Porter, Sara Haliko and Selena Moore Office hours: Monday through Friday 8:00 a.m. to 5:00 p.m. EST Email Address: PHFA@OOMC.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's 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 or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: * 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 CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT 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. OP844 (Page 8 of 9) * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS DOES NOT IMPLY THAT OPTION ONE IS ATTEMPTING TO COLLECT MONEY FROM ANYONE WHOSE DEBT HAS BEEN DISCHARGED UNDER THE BANKRUPTCY LAWS OF THE UNITED STATES. (Page 9 Of 9) OP844 033 R35 le OIL& V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE 17 V J i? sic 0?0 e i w SHERIFF'S RETURN - REGULAR CASE NO: 2008-03273 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS HAMILTON RICHARD C ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HAMILTON RICHARD C the DEFENDANT , at 0020:26 HOURS, on the 2nd day of June 2008 at 209 EAST WINDING HILL ROAD MECHANICSBURG, PA 17055 by handing to RICHARD C HAMILTON DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit `/d 9/0f, 18.00 Surcharge 13.00 .00 10.00 .00 ? 41.00 So Answers: Sworn and Subscibed to before me this day of , R . "Thomas Kline t 06/03/2008 UDREN LAW OFFICES By: A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-03273 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS HAMILTON RICHARD C ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon uZ1MTT.'T(1TT .7A'KTR M the DEFENDANT , at 0020:26 HOURS, on the 2nd day of June , 2008 at 209 EAST WINDING HILL ROAD MECHANICSBURG, PA 17055 by handing to JANE HAMILTON DEFENDANT 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 6 lb 4 lot -- 6.00 .00 .00 10.00 .00 16.00 So Answers: R. Thomas Klin 06/03/2008 UDREN LAW OFFICES Sworn and Subscibed to By: before me this day of A.D. T41DREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID STUART WINNEG, ESQUIRE - ID LORRAINE DOYLE, ESQUIRE - ALAN M. MINATO, ESQUIRE - CHANDRA M. ARKEMA, ESQUIRE WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ID ID #04302 #45362 #34576 #75860 ID #203437 200 Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass- Through Certificates, Series 2006-OPT4 6501 Irvine Center Drive Irvine, CA 92618-2118 Plaintiff V. Richard C. Hamilton Jane M. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-3273 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Richard C. Hamilton and Jane M. Hamilton for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 5/18/08 to 7/8/08 Late charges per Complaint From 5/18/08 to 7/8/08 Escrow payment per Complaint From 5/18/08 to 7/8/08 $137,049.32 1,773.72 131.74 496.08 TOTAL $139,450.86 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDRENLAW OFFICE A, P. C. BY rMIV4 Al )1 17 P" /2 / Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : ( L? g._ 1S1 !.(?ij" T' ?.?Y?Ils• 41-1 411 PRO PROTHY ?? ?? ro co i _ g UDREN LAN OFFICES, P. C. MARK J. UDREN, ESQUIRE - ID #04302 STUART NINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN K. 1LINATO, ESQUIRE - ID #75860 CMMRA K. ARSEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY EII,L, NJ 08003 856-669-5400 ATTORNEY FOR.PLAINTIFF Deutsche Bank National Trust Company as Trustee for COURT OF COMMON PLEAS HSI Asset Securitization Corporation 2006-OPT4 1 CIVIL DIVISION Mortgage Pass-Through Certificates, Series 2006-OPT4 = Cumberland County Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant(s) NO. 08-3273 Civil Term TO: Richard C. Hamilton 209 East WindinK' ill Road Mechanicsburg, 17055 DATE of Notice: June 24, 2008 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WR=G WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 14be" Avenue Carlisle, A 17013 717-249-3166 800-990-9108 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMP ECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS DRORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO RvWEDIATAM5H SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Li Avenue Carlisle, A 17013 717-249-3166 800-9990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ar Stuart Winn Esquire Lorraine Do7 Esquire Alan M. Minato, Chandra M. ArkemaF, wire Woodc rest Corporate Center i 11 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 I UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust :COURT OF COMMON PLEAS Company as Trustee for HSI :CIVIL DIVISION Asset Securitization ;Cumberland County Corporation 2006-OPT4 Mortgage Pass-Through Certificates, :MORTGAGE FORECLOSURE Series 2006-OPT4 6501 Irvine Center Drive p nn Irvine, CA 92618-2118 N0. 00-3p` 3 QVI )M Plaintiff V. Richard C. Hamilton Jane M. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF MA COUNTY OF SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by Plaintiff herein and that the above De endant(s) are not in the Military or Naval Service of the Unit,ed States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age a.-id last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Richard C. Hamilton over 18 As captioned above Unknown Jane M. Hamilton over 18 As captioned above Unknown Sworn to nd subscribed before e this It day of , 2001 . otary Public Name : S+tnu-j Title: Company: Option One Mortgage Corporation as attorney in fact for Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Matthew Allan Banaszewskl NOTARY PUSUC . MINNESOTA MY COMMISSION EXPIRES JAN. 31, 2011 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass- Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant (s) I HEREBY CERTIFY THAT: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-3273 Civil Term CERTIFICATE TO THE SHERIFF I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: X -A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. BY :/? ?N 1 P6 A n4l) Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County :MORTGAGE FORECLOSURE :NO. 08-3273 Civil Term C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY .C f/A ,f )A1'(D Attorneys for Praintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE c UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-3273 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due Interest From 7/9/08 to Date of Sale December 10, 2008 Ongoing Per Diem of 34.11 to actual date of sale including if sale is held at a later date (Costs to be added) $139,450.86 5,287.05 UDREN LAW OFFICES, P C . BY :r? A ( la h'71k rneys Tor Plaintiff Atto MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE r4 All - co r\ a cn s ?fi WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-3273 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 HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006- OPT4 Plaintiff (s) From Richard C. Hamilton Jane M. Hamilton (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$139,450.86 L.L.$.50 Interest from 7/9/08 to date of sale December 10, 2008 ongoing per diem of $34.11 to actual date of sale including if sale is held at a later date $5,287.05 Atty's Comm % Due Prothy $2.00 Atty Paid $176.00 Other Costs Plaintiff Paid Date: July 8, 2008 (Seal) REQUESTING PARTY: Name Chandra M. Arkema, Esq. Address: Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Curtis R. Long, Prothonotary By: ` o_ 'e T- Deputy Attorney for: Plaintiff Telephone: 856-669-5400 Supreme Court ID No. 203437 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 i STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company :COURT OF COMMON PLEAS as Trustee for HSI Asset :CIVIL DIVISION Securitization Corporation 2006-OPT4 €Cumberland County Mortgage Pass-Through Certificates, Series 2006-OPT4 :MORTGAGE FORECLOSURE Plaintiff V. Richard C. Hamilton :NO. 08-3273 Civil Term Jane M. Hamilton Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 209 East Winding Hill Road, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Richard C. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 Jane M. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of of record: Name the last recorded holder of every mortgage Address Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 6501 Irvine Center Drive Irvine, CA 92618-2118 Option One Mortgage Corporation, 3ADA, Irvine, CA 92618 A California Corporation 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 209 East Winding Hill Road Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 8, 2008 UDR(E?NLnAWh OFFICES, P.C. ??BY :'?1 A! IL?1 A Y//I ? DQ l ®' Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE r cf: c Ln UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingeoudren.com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass- Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-3273 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Richard C. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 Your house (real estate) at 209 East Winding Hill Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 10, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $139,450.86, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 Goa t F 00 c-n UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass- Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 08-3273 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Richard C. Hamilton Jane M. Hamilton PROPERTY: 209 East Winding Hill Road Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 10. 2008, at 10:00 am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ALL THAT CERMN tract of land with the imps a vements tbmon erected o tuaft in the TownshW of Upper Mien, C:u=baiand Omntlr; Pbaasylvauia, bounded and desm1wd as "am, to wit: . 18E4T1 W4 at a nsR in the oeator lice of West Winding Hitt Road {L. U 1035) at lice of lend now or &=a* of Mn. El1an. EbeeTi thrice by the c: pry, eac htu of said public road, "87 degmes 10 zWmtrs West 130 Set,- to a man is the same and sx Nat of 12 d. w cc fad of Ev tM PYntni then by the latterlaz4 Notch a degrees 30 minutes East 166.5 60. to as hm pipe on Una of other land now or foarawAy of Carl A. Weaft and wits; thence by the Luber land, South 87 degrees 10 minutes Fast 84 beet, to a staloe at the Mwl r land; then by the. latter, South 13 degrees 34 minutes Fast 173 Let mo?x or less, to the PLACE OF BEGUOM. HAVIN0. nMREON ERECTED a brick and frame dweUing lmovm an 209 E, Winding = Road. BEING KNOWN AS: 209 East Winding Hill Road Mechanicsburg, PA 17055 PROPERTY ID NO.: 42-26-0243-007 TITLE TO SAID PREMISES IS VESTED IN RICHARD C. HAMILTON AND JANE M. HAMILTON, HUSBAND AND WIFE BY DEED FROM EDWARD M. JASEN AND LINDA BAIRD JANSEN, HUSBAND AND WIFE DATED 11/28/2005 RECORDED 12/09/2005 IN DEED BOOK 272 PAGE 1420. r Co 1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as :COURT OF COMMON PLEAS Trustee for HSI Asset Securitization :CIVIL DIVISION Corporation 2006-OPT4 Mortgage Pass- :Cumberland County Through Certificates, Series 2006-OPT4 Plaintiff €:NO. 08-3273 Civil Term V. Richard C. Hamilton Jane M. Hamilton Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: July 8, 2008 UDREENj?L/}A? W OFFICES, ,, P.C. BY :1 iY V.11M/V?[.! /1 A 11A Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE V E R I F I C A T I O N The undersigned, an officer of Option One Mortgage Corporation as attorney in fact for Plaintiff, and being author zed to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint alp' taken from records maintained by Plaintiff in the ordinary course: of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 491,,4 relating to unsworn falsification to authorities. Date : ?g Q$ Richard C. Hamilton Jane M. Hamilton Loan #0024033155 MJU #08050402-1 Name : G? Title: Up Company: Option One Mortgage Corporation as attorney in fact for Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-0PT4 r r? tr te ? 37 r ,., w ' t y` {ma%3 ,, j f fr V ! '??yyy 1 c-n 1 f UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust COURT OF COMMON PLEAS Company as Trustee for HSI Asset :CIVIL DIVISION Securitization Corporation 2006- Cumberland County OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton ENO. 08-3273 Civil Term Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: October 23, 2008 UDR LAW OFFIC , P.C. Attorneys-for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company COURT OF, COMMON PLEAS as Trustee for HSI Asset Securitization CIVIL DIVISION Corporation 2006-OPT4 Mortgage Pass- € Cumberland County Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant(s) NO. 08-3273 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Richard C. Hamilton and Jane M. Hamilton PROPERTY: 209 East Winding Hill Road, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 10. 2008, at 10:00 am, in the Commissioners Hearing Room 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that,you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A $ ? m ? a m m yF a?? od m d p6??? E 0i U. ;or o e?'g_?m?5 ?iT-0 Co C u t L' LtS OU ? L wm E ? ? m - ' rgc ?j0 a ov m 3 o ? po m ? o r -V Q o H g m o.N0 cc u?i "o 5 8 N 9 H N °E$?8 m c m » « p c Ni 14 c CL Q7 $ OF CL 0 w?? cm? r app ?? _ ? ?. ?3 ??$ a O LL. X00$ > S? sge? o - °-_- e U ?s c u'l ? r a ?a .v b a a a? ? A ?' a p =°' ? a= Ya ? °? OM ESQ a W 04 ? w ?oZ `$ab? ?4. H r ` a-- U- 7 M d o g Q°W O a3 0 r o p N to Lu dON Q U ?tE ?r v?o CL J4VSmmg° 4 CL at?l7? SU N,>MKO Q o r- 12 3- U. ? E? {?6 V N OdO torL0, Z ? ? g ? 016-%! c vwugi '?vt?? ?`WZ i w ZtnpG44N4?U me w at 50- 0 ZOW Z 4 wrusWOcocTi?p c°D ? c- OOv q E ?7Dul? prn c°' O$ ? v? crrc?ar g ? N c+) °? a w ti a N ce) E O J ti ,o, 1g1T A Z ° XH E?? J r N ? Za o N v N 0 0 LO 0 co 0 N t0 a C tC U .d V ? t-`? ? j T, rTt Fla a UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust =COURT OF COMMON PLEAS Company as Trustee for HSI ':CIVIL DIVISION Asset Securitization :Cumberland County Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 =NO. 08-3273 Civil Term Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE. DATED: December 19, 2008 UDR ES, P.C. BY Attornefs for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE `"LOUIS A. SIMONI, ESQUIRE '? r 1..` Deutsche Bank National Trust Company as In the Court of Common Pleas of Trustee for HIS Asset Securitization Corporation Cumberland County, Pennsylvania 2006-OPT4 Mortgage Pass-Through Certificates Writ No. 2008-3273 Civil Term Series 2006-OPT4 VS Richard C. Hamilton and Jane M. Hamilton Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2008 at 0905 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Richard C. Hamilton and Jane M. Hamilton by making known unto Richard Hamilton, personally and husband of Jane M. Hamilton, at 209 E. Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2008 at 1139 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard C. Hamilton and Jane M. Hamilton, located at, 209 E Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Richard C. Hamilton and Jane M. Hamilton, by regular mail to their last known address of 209 E. Winding Hill Road, Mechanicsburg, PA 17055. These letters were mailed under the date of October 7, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request form Attorney Mark Udren. Sheriffs Costs: Docketing $30.00 Poundage 17.83 Advertising 15.00 Posting Handbills 15.00 Mileage 26.00 Levy 15.00 Surcharge 30.00 Law Library .50 Prothonotary 2.00 Postpone Sale 20.00 Law Journal 355.00 Patriot News 368.24 Share of Bills 14.92 /z3?or ? / $909.49 So Answers: R. Thomas Kline,' Sheriff BYE Real Estate rgeant L cam- ?? z8 ,, $ UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE ID #75860 CHANDRA M. ARKENA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingeoudren.com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-3273 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 209 East Winding Hill Road, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Richard C. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 Jane M. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address V Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Option One Mortgage Corporation, A California Corporation 6501 Irvine Center Drive Irvine, CA 92618-2118 3ADA, Irvine, CA 92618 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 209 East Winding Hill Road Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 8, 2008 UDREN LAW OFFICES, P.C. BY f V, MA QJOA11 Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKENA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton Jane M. Hamilton Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-3273 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jane M. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 Your house (real estate) at 209 East Winding Hill Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 10, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $139,450.86, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OW= 10 RIGSTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LILWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT i1HER8 YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as Trustee for HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass- Through Certificates, Series 2006-OPT4 Plaintiff V. Richard C. Hamilton. Jane M. Hamilton Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-3273 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Richard C. Hamilton 209 East Winding Hill Road Mechanicsburg, PA 17055 Your house (real estate) at 209 East Winding Hill Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 10, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $139,450.86, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF 0MM I S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's.fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARS 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 by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid.to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons,why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAKrZR AT ONCE. IF YOU DO NOT HAVE A LAMM OR CAMTOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. . LMPYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 . • ALL THAT CERTAIN vaet of landimith twin; ts dmeom encted skm2e in the Taarae31 of Uppes AUM C=baliad Con W; PM&=rt taia. bounded and deem Owd es follows, to % ft ' a at a nail in the centw bw of Weet Windft Hilt PAad g R21025) at The of Imad now or fanswIr of True. Zba Rbe ft thsaoe by the aomw llaa cf add pub* t+oA "th 67 406"m 10 oblu a West 190 feet; to a AMR in the aftmie and. at Hm et h aL v wr ec oIr Flnza thecae by the Iatow land, Na dh a duress 30 minutee R" 116.6 tilt. to em im pips an 3ne at attar land now or Amne* of Carl A. Wags imd wlfs; dmm by the Law lead. 6outth 17 die 10 n ftntm Rut 84 tMo to a vWw at the Xboft lmd; dwo m by **- latter. Soafh 13 degrees 94 watts ft e 173 feat mass or WW to the FLA= OF MGMM- HAVVIO ' MMEC M-D a.bd* and 6 dweMnd known as 204 E. Winding Hm Road. BEING KNOWN AS: 209 East Winding Hill Road Mechanicsburg, PA 17055 PROPERTY ID NO.: 42-26-0243-007 TITLE TO SAID PREMISES IS VESTED IN RICHARD C. HAMILTON AND JANE M. HAMILTON, HUSBAND AND WIFE BY DEED FROM EDWARD M. JASEN AND LINDA BAIRD JANSEN, HUSBAND AND WIFE DATED 11/28/2005 RECORDED 12/09/2005 IN DEED BOOK 272 PAGE 1420. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-3273 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 HSI Asset Securitization Corporation 2006-OPT4 Mortgage Pass-Through Certificates, Series 2006- OPT4 Plaintiff (s) From Richard C. Hamilton Jane M. Hamilton (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$139,450.86 L.L.$.50 Interest from 7/9/08 to date of sale December 10, 2008 ongoing per diem of $34.11 to actual date of sale including if sale is held at a later date $5,287.05 Atty's Comm % Due Prothy $2.00 Atty Paid $176.00 Other Costs Plaintiff Paid Date: July 8, 2008 (Seal) REQUESTING PARTY: Name Chandra M. Arkema, Esq. Address: Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attorney for: Plaintiff Telephone: 856-669-5400 Curtis R. ,Long, Prothonota By: Deputy Supreme Court ID No. 203437 Real Estate Sale #49 On August 28, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA Known and numbered as 209 E. Winding Hill Rd., Mechanicsburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 28, 2008 By: \11 6 Real Esta Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 31, November 7 and November 14, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r Marie Coyne, SWOIN'TO AND SUBSCRIBED before me this 14 day of November, 200 C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 RRAL NOTAW "A& NO. 49 Writ No. 2008-3273 Civil Deutsche Bank National Trust Company as Trustee for HIS Asset Securitization Corporation 2006- OPT4 Mortgage Pass-Through Certificates, Series 2006-OPT4 VS. Richard C. Hamilton and Jane M. Hamilton Atty.: Mark Udren ALL THAT CERTAIN tract of land with the improvements thereon erect- ed situate in the Township of Upper Allen, Cumberland County, Penn- sylvania, bounded and described as follows, to wit: BEGINNING at a nail in the cen- ter line of West Winding Hill Road (L.R.21025) at line of land now or formerly of Mrs. Ellen Eberly; thence by the center line of said public road, North 87 degrees 10 minutes West 130 feet, to a nail in the same and at line of land now or formerly of Evelyn Finniff; thence by the latter land, North 2 degrees 30 minutes East 166.5 feet, to an iron pipe on line of other land now or formerly of Carl A. Wentz and wife; thence by the latter land, South 87 degrees 10 mutes East 84 feet, to a stake at the Eberly land; thence by the latter, South 13 degrees 30 minutes East 173 feet more or less, to the PLACE OF BEGINNING. HAVING THEREON ERECTED a brick and frame dwelling known as 209 E. Winding Hill Road. BEING KNOWN AS: 209 East Winding Hill Road Mechanicsburg, PA 17055. PROPERTY ID NO.: 42-26-0243- 007. TITLE TO SAID PREMISES IS VESTED IN Richard C. Hamilton and Jane M. Hamilton, husband and wife by deed from Edward M. Jasen and Linda Baird Jansen, husband and wife dated 11/28/2005 recorded 12/09/2005 in Deed Book 272 Page 1420. • The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 0' PUBLICATION COPY This ad ran on the date(s) shown below: 10/29/08 11/05/08 11/12/08 r, 2008 A. D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Klsner, Notary Public City Of hhrrisburg, Dauphin County My Corm*sion Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries Re41 Estars $Na N0.49 Wit Moo 2008-32" t Term Deutsche. Bank Na#onal Trust Company as Thm tpe for H Assat Securttization Corporation 2006-OPT4. Mo tgaste Pass-'Through Certtkttn Series 2006-OPT4 VS Richard C. HOmNton and Jane iN. HamUton Attorney Mark Udren LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Tbwi&p of Upper Allen, Cumberland County, Pennsylvania,' bounded and described as follows, to wit: BEGINNING at a nail in the center line of West Winding Hill Road (L.R. 21025) at line of land now or formerly of Mrs. Ellen ly; thence by the center line of said public road, North 87 degrees 10 minutes West 130 feet, to a nail in the same and at line of land now or formerly of Evelyn Ems, thence by the later land, North 2 s! E" 16" %K m an iron pit os iec ot'a6kt Iasd aaro€"?aetty of Carl A. WOW. and **; thence by the I WA Soft 87 dww It ei0ft IW 84 fees. Pu a stake at the Eberly land; tbeme by the latter, South 13 degrees 30 minutes East 173 feet more or less, to be-PLACE OF BEGINNING. HAVING THERFtON-EREC IW a brick frame dwelling known as 20913. Winding Hill Road. BEING KNOWN AS: 209 East Winding Hill Road Mechanicsburg, PA 17055 PROPER'IT ID NO.: 42-26-024307 TITLE TO SAID MMES IS VESTED IN RICHARD C. HAMILTON AND JANE M. HAMILTON, HUSBAND AND WIFE BY DEED FROM EDWARD M. _ JASEN AND LINDA BAIRD .IANSEN, HUSBAND AND WIFE DA'Z'ED 11128f2005 RECORDED 121191 2005 IN DEED BOOK 272 PAGE 1420.