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HomeMy WebLinkAbout08-3704GOLDBECK 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagors and Real Owners 137 Allendale Way Camp Hill, PA 17011 Defendants Term No. 08.3'7o4 Civil le'rk CIVIL ACTION: MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 http://www.phfa.orp-/consumers/homeowners/real.4Vx. 5). Call the Plaintiff (your lender) at 800-776-0100 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 1-866413-2311 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 67861FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. The names and addresses of the Defendants are THOMAS J. GIANNELLI, 137 Allendale Way, Camp Hill, PA 17011 and KAREN R. GIANNELLI, 137 Allendale Way, Camp Hill, PA 17011, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On April 19, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK OF INDIANA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1947, Page 2603. The mortgage has been assigned to: U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for February 01, 2008 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 ..................................................................................$259,792.67 Interest from 01/01/2008 through 06/30/2008 at 8.7500% .....................$11,334.96 Per Diem interest rate at $62.28 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................$12,989.63 Late Charges from 02/01/2008 to 06/30/2008 .............................................$473.59 Monthly late charge amount at $94.72 Costs of suit and Title Search ......................................................................$900.00 Property Inspections .......................................................................................$41.00 BPO's ...........................................................................................................$109.00 Suspense ..................................................................................................... -$490.52 $285,150.33 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $285,150.33, together with interest at the rate of $62.28, 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 Sheriffs Sale of the Property. By: GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, ?" f aw , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: 0 u h U.S. B National Association, as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates, Series 2006-BC4, by Wilshire Credit Corporation, its Attorney in Fact ** w( ? /authorized Agent 2681721 THOMAS J. GIANNELLI and KAREN R. GIANNELLI ExhibitA ALL THAT CERTAIN parcel known as Lot No. 55, Section 'tY Allendale, Lovmr Allen Township, Cumberland County, Pennsylvania, according to a Plan of Allendale for Mid State Develop- ment, inc., by William 8. Whittock, R.P.E., dated April 12, 1975, recorded in Plan Book 29, Page 105, bounded and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of-way line of Allendale Way, a 60 Coot right-of- way, at the southeast corner of Lot No. 56, Section *W Allendale, said point being, located and referenced a distance of 339.67 feet southeast of the intersection of the eastern right-of-way line of Allendale Wag, and the southern right-o&way line of Fieldstone Road, a 50 loot right- of-way-, thence by Lot No. 56, North 64 degrees 35 minutes 53 seconds ran, a distance of 9514 feet to a point at Lot No: 61, Section "L' Allendale; thence by the same and a portion of Lot No. 62, Section °E', Mouth 25 de"t 49 minutes 27 seconds East, a distance of 104.00 feet to a point at the northeast corner of Lot No. 54, motion "D" Allendale: thence by the same, South 64 degrees 35 minutes 53 seconds West, a distance of 96.90 fcet to a point on the eastern right-of-wiry line of Alkndalez Way; thence by the same, North 2S degrees 24 minutes 07 scamds West, a distance of 104.00 feet to a point, the place of BEGIRNING. SUBJECT to casements, restrictions and building lines of record. SUBJECT to Ptvtective Covenants recorded in Cumberland County Recorder of Deeds Of8c c in Miellarneous Book 1511, page 243, HAVING THEREM BREC MI) a dwelling house known and numbered as 137 Allende Way, Camp Hill, Pennsylvania. 3XING TRIG SAM P[tl!MUS WAICK Sydney M. 0rebman and Joyce Z. Grobman, husband and wife, by their deed dated April 14. 2006, and re:cozded April 20, 2006, in the office of the Recorder or Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Page 599, granted and conveyed unto Thomas J. Giannelli and Karen R. Giannelli, husband and wife, Mortgagors horein. Exhibit B ? Wilshire- January 01, 2008 GIANNELLI, THOMAS J 137 ALLENDALE WAY CAMPHILL, PA 17011 Wilshire Credit Corporation Payments P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence P.O. Box 8517, Portland, OR 97207-8517 L 178F ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Phone 888.917.1052 Fax 503.952.7476 Web Site www.wce.ml.com 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 prog m 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 yol r County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll-free at 1.800.342.2397. (Persons with impaired hearing can call 717.780.1969.) This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIGN EN ADJUNTO ES DE SUMA IMPORTANCI.A, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. Sl NO COM:PRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago.sim.co.us/cadeicadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 145233 S.W. Miflikan Way, Beaverton, OR. Wilshire's office hours are Monday- Friday 6:00 am to 5:00 pm Pacific time, holidays excluded L 178F W Wilshire January 01, 2008 GIANNELLI, KAREN R 137 ALLENDALE WAY CAMPHILL, PA 17011 Wilshire Credit Corporation Payments P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence P.O. Box 8517, Portland, OR 972074517 078F ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Pttons 888.917.1052 Fax 503.952.7476 Web Site www.wcc.mL.com This is an official notice that the mortgag on your home is in default, and the lender intends to foreclose. Scific 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 Agency toll-free at 1.800.342.2397. (Persons with impaired hearing can call 717.780.1869.) This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INWITAMENTE LLAMA.NDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL, BE USED TO COLLECT THIS DEBT HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE. COLLATERAL PROPERTY. COLORADO. FOR INFORMATION ABOUT THE COLORADO} FAIR DEBT COLLECTION PRACTICES ACT, SEE http:;lwww.ago. statc.ca.us/cadcr`cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed Try the Collection Service Board of the Department ofCortmcrce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way. Beaverton, OR W ilshire's office hours are Monday- Friday 6JX) am to 5:00 pm Pacific time, holidays excluded L 178F GIANNELLI, KAREN R Loan No.:2681721 Page 2 January 01, 2008 PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA, HOMEOWNERS' NAME : GIANNELLI, THOMAS J PROPERTY ADDRESS LOAN ACCT. NO. ORIGINAL LENDER CURRENT SERVICER 137 ALLENDALE WAY CAMP HILL, PA 170118401 2681721 NATIONAL CITY Wilshire Credit 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 a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS, IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MQRTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLANS, 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. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMh fG FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT HOWEVER. IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST TIIE COLLATERAL PROPERTY. COLORADO: FOR. INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http:f/www.ago.state.ca.us/cadclca&main.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Pemvt 3840. TENNE.SSEF,: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corponsitm is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded L178F GIANNELLI, KAREN R Loan No.:2681721 Page 3 January 01, 2008 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. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after they receive your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE 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: 137 ALLENDALE WAY CAMP HILL, PA 170118401 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $6,607.11 Late Charges $367.24 Other Charges $0.00 Suspense Amount -$97.63 TOTAL 56,876.72 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 $6,876.72 PLUS (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT TIIE DEBT, BUT NOTICE' OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL: PROPERTY. COLOIL400: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://,vww.ago.state.ce.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3810. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR Wilshire's office hours are Monday- Friday 6:00 am to 5:00 pm Pacific time, holidays excluded L1 8F GIANNELL1, KAREN R Loan No.:2681721 Page 4 January 01, 2008 ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: Wilshire Credit Corporation, P.O. Box 7195, Pasadena, CA 91109-7195. IF YOU DO NOT 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 it's rights to accelerate the mortgage debt. This means that the entire outstanding balance of the 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 f HIRTY (30) DAYS, the lender also intends to instruct it's attorneys to start legal action to foreclose upon your mortgaged Property. IF THE MORTGAGE IS FQRECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay offthe.mortgage debt. If the lender refers your case to it's attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to actually incurred by the tender even if they exceed $50.00. 'The attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you care 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 and by oertorming_my 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 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 of action will be by contacting the lender. HOW TO CONTACT iE LENDER Name of Lender : Wilshire Credit Corporation Address Payments: P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence: P.O. Box 8517, Portland, OR 97207-8517 Phone To11-Free: 888.917.1052 Fax Number 503.952.7476 (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLEC'T THIS DEB'r HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN A'PrEMPT "r0 COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL: PROPERTY. COLORADO: FOR INFORMATION ABORT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT. SEE htip:Nwww.ago.state.co.us/cadcicadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Coltcction Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. Wilshire's office tn)urs are Monday - Friday 6'00 am to 5:00 pin Pacific time, holidays excluded L1 78F GIANNELLI, KAREN R Loan No.:2681721 Page 5 January 01, 2008 Contact : Loan Servicing 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 or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY 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 THE MORTGAGE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE'DEFA-ULT. (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. ATTACHED IS THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY If you have any questions, please contact us at our toil-free number above. Sincerely, Loan Servicing Enclosures: PA CCCS List, How to Avoid Foreclosure YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER 1S NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE. COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http:/Jwww.ago.statc.w,us/eadclcadcmain.chn. NEW YORK CrrV: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the DeparDnent of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Wav, Beaverton, OR Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded l ?8F O o? r b FIR co -c SHERIFF'S RETURN.- REGULAR CASE NO: 2008-03704 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCITAION VS GIANNELLI THOMAS J ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GIANNELLI THOMAS J the DEFENDANT at 1110:00 HOURS, on the 26th day of June at 137 ALLENDALE WAY CAMP HILL, PA 17011 by handing to THOMAS J GIANNELLI 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 Affidavit .00 Surcharge 10.00 Vb,Z /D 8 C?- 00 4 Sworn and Subscibed to before me this day of So Answers: . R. Thomas Kline 06/27/2008 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy S riff A. D. 2008 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03704 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCITAION VS GIANNELLI THOMAS J ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GIANNELLI KAREN R the DEFENDANT , at 1110:00 HOURS, on the 26th day of June 2008 at 137 ALLENDALE WAY CAMP HILL, PA 17011 by handing to THOMAS J GIANNELLI HUSBAND 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: So Answers: Docketing 6.00 Service .00 Affidavit 00 _ Surcharge 10.00 R. Thomas Kline .00 7?va fOS ??, 16.00 06/27/2008 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By; before me this day Deputy Sh iff of A.D. In the Court of Common Pleas of Cumberland County U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-13C4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-3704 CIVIL TERM 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 THOMAS J. GIANNELLI and KAREN R. GIANNELLI by default for want of an Answer. Assess damages as follows: Debt $288,889.73 Interest from 08/27/2008 to Date of Sale per diem at $62.28 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AWS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM T PLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to th aga' s hom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least t d s p ' r the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. eever Attorney f laintiff I.D. #56 9 AND NOW -/ , Judgment is entered in favor of U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 and against THOMAS J. GIANNELLI and KAREN R. GIANNELLI by default for want of an Answer and damages assessed in the sum of $288,889.73 as per the above certification. Prothonotary 67861FC 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: July 17, 2008 TO: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) TO: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-3704 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER RAPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 67861FC 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: July 17, 2008 TO: KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) TO: KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-3704 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER 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, THOMAS J. GIANNELLI, is about unknown years of age, that Defendant's last known residence is 137 Allendale Way Camp Hill, PA 17011, and is engaged in the unknown business located at unknown 2. That Defendant is not in the Military or Naval Yer/ice of the United States or its Allies, or otherwise within the provisions of the Soldiers/a96 Sailor' Civil Relief Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, KAREN R. GIANNELLI, is about unknown years of age, that Defendant's last known residence is 137 Allendale Way Can3ja7Hill, PA 17011, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service./f tl k United States or its Allies, or otherwise within the provisions of the Soldiers' and Sj6lor,$' CXA Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record owner(s)) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3704 CIVIL TERM ORDER FOR JUDGMENT Please enter Judgment in favor of U.S. BANK NATIONAL ASSOCIATION, AS' SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE BACKED CERTIFICATES, SERIES 2006-BC4, and against THOMAS J. GIANNELLI GIANNELLI for failure to file an Answer in the above action within (20) days (or sixty C the United States of America) from the date of service of the Complaint, in the sum of 2V Michael T. McKeever Attorney for Plaintiff,4 I hereby certify that the above names are correct and that the pre9 residence creditor is U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE F THE SPEC UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN 11 CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Be, o 1 name(s) and last known address(es) of the Defendant(s) is/are THOMAS J. GIA L Camp Hill, PA 17011 and KAREN R. GIANNELLI, 137 Allendale Way Camp 1, y GOLDBECK N BY: Michael T. Attorney for Pk BE FOR THE ASSET- XN R. Fl*d'efendant is of the judgment -BACKED 005 and that the Allendale Way I; & McKEEVER ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 01/01/2008 through 08/26/2008 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 2 X $0.00 Property Inspections BPO's Suspense $259,792.67 $14,884.92 $12,989.63 $663.03 $900.00 $0.00 $41.00 $109.00 -$490.52 $288,889.73 GOLDBECK MCCAFFE Y & BY: Michael T. McKee r Attorney for Plaintiff AND NOW, this day of , 2008 damages are assessed as above. Pro Prothy cnn lc? T O C., t .. ?'Tl Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagors and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 No. 08-3704 CIVIL TERM 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-caption d niatter has beenye tered against you. /6L.4',4.1 urtLong ?JJ B? Prothonotary By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-3704 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 Plaintiff (s) From THOMAS J GIANNELLI KAREN R GIANNNELLI (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$ 288,889.73 L.L.$0.50 Interest FROM 08/27/2008 TO DATE OF SALE LPER DIEM AT $62.28 Atty's Comm % Atty Paid $179.00 Plaintiff Paid Due Prothy $2.00 Other Costs Date: August 29, 2008 (Seal) REQUESTING PARTY: Name MICHAEL T MCKEEVER ESQ A Curtis R. Long, Prothonotary- By: Deputy Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3704 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 08/27/2008 to Date of Sale per diem at $62.28 $288,889.73 (Costs to be added) GOLDBECK McCAF I?TY & McKEEVER BY: Michael T. Mc ever Attorney for Pla' iff U O o? W O d cn HW W Ho0 ?HU? W M ? d CIO O Q bSUj? wQ °V `d Z "' d Z H F Z p? ?' ?OAW v? u? Q O v a? ? i. W a M w y , u W O ? G H ? U Sty w O ? r-' W H ?l !n Q O 'O e w d D U d? Vt> ? ? " 3 N a°o a O Q 6J V tea °; r 3 ALL THAT CERTAIN parcel known as Lot No. 55, Section "D" Allendale, Lower Allen Township, Cumberland County, Pennsylvania, according to a Plan of Allendale for Mid State Development, Inc., by William B. Whitlock, R.P.E. dated April 12, 1976, recorded in Plan Book 29, Page 105, bounded and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of-way line of Allendale Way, a 60 foot right-of-way, at the southwest corner of Lot No. 56, Section "D" Allendale, said point being located and referenced a distance of 339.67 feet southeast of the intersection of the eastern right-of-way line of Allendale Way, and the southern right-of-way line of Fieldstone Road, a 50 foot right-of-way; thence by Lot No. 56, North 64 degrees 35 minutes 53 seconds East, a distance of 96.14 feet to a point at Lot No. 61, Section "E" Allendale; thence by the same and a portion of Lot No. 62, Section "E", South 25 degrees 49 minutes 27 seconds East, a distance of 104.00 feet to a point at the northeast corner of Lot No. 54, Section "D" Allendale; thence by the same, South 64 degrees 35 minutes 53 seconds West, a distance of 96.90 feet to a point on the eastern right-of-way line of Allendale Way; thence by the same, North 25 degrees 24 minutes, 07 seconds West, a distance of 104.00 feet to a point, the place of BEGINNING. SUBJECT to easements, restrictions and building lines of record. SUBJECT to Protective Covenants recorded in Cumberland County Recorder of Deeds Office in Miscellaneous Book 158, Page 243. HAVING THEREON ERECTED a dwelling house known and numbered as 137 Allendale Way, Camp Hill, Pennsylvania. BEING THE SAME PREMISES WHICH Sydney M. Grobman and Joyce 8, Grobman, husband and wife, by their deed dated April 14, 2006, and recorded April 20, 2006, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Page 599, granted and conveyed unto Thomas J. Giannelli and Karen R. Giannelli, husband and wife, Mortgagors herein. Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. THOMAS J. GLANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-3704 CIVIL TERM U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 137 Allendale Way Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 C3 na c ? :.? C` ?, c rr ? ` N :"r;?? r'. - ? ...{-t i 7 - n ?k"A C`J _ ? t ? + ? "? ??? y 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 137 Allendale Way Camp Hill, PA 17011 DAVID STONE, ESQUIRE 414 Bridge St. New Cumberland, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the be of y pers al knowledge or information and belief. I understand that false statements herein are made subject to p , alties 8 Pa. C. S. Section 4904 relating to unworn falsification to authorities. i DATED: August 26, 2008 GOLDBECK AFFERTY & McKEEVER BY: Michael . McKeever, Esq. Attorney fo laintiff :7 ?: CTti Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 THOMAS J. GIANNELLI vs. KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-3704 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the tiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complie all the provisions of the Act. d t Al Michael T.11 Attorney for °? ? _-? ,_,? C? {'t'S _?., ? ,i:` Y-+ ;. 4"? ?.? '. ?-? r ' .,.+ .. 5 .??.t' ?_ . y ? i ~ * x .. ? "?„ ~? ? f L 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 08-3704 CIVIL TERM U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINAr TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE VS. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) Term No. 08-3704 CIVIL TERM 137 Allendale Way Camp Hill, PA 17011 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: GIANNELLI, THOMAS J. THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Your house at 137 Allendale Way, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $288,889.73 obtained by U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 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: 08-3704 CIVIL TERM 1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, 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 STH,L BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 A 08-3704 CIVIL TERM 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.oriz/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 800-776-0100 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 67861FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-3704 CIVIL TERM 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINAL` TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) Term No. 08-3704 CIVIL TERM 137 Allendale Way Camp Hill, PA 17011 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: GIANNELLI, KAREN R. KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Your house at 137 Allendale Way, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $288,889.73 obtained by U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 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: 08-3704 CIVIL TERM 1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, 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. 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 08-3704 CIVIL TERM 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 htip://www.phfa.orgjconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 800-776-0100 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 67861 FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 'GOLDBEC•K McCAFFERTY & McKEEVER BI:: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 67861 FC CF: 06/23/2008 SD: 12/10/2008 $288,889.73 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3704 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ?e1 /ZDIOtt? V) Personal Service by the Sheriffs Office/ ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff Upme and Address of Sender GOLDBECK ' SUITE 5000 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Article Number 1. 2. 3. Check type of mail or service: , ? Certified ? Recorded Delivery (International) ? COD ? Registered ? Delivery Confirmation ? Retum Receipt for Merchandise O Express Mai ? Signature Cordirmafion _ p tnsured.._. Addressee (Name, Street, (31y. Slate. 8 ZIP OWL) Postage PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 - arrsbur9, PA f7105--2675_. DOMESTIC RELATIONS OF CUMBERLAND COUNTY P-0 Bstx 320. Carlisle, PA 17013 Affix Stamp Here (If issued as a oertificate of mailing, or for additional copies of this bil) Postmark and Date of Receipt Actual Value Fee ?Ahti?$RY R.eg4wed r_ ?' t Q SO AN TENANTS/OCCUPANTS Sp 137 Allendale Way $p,?? 4. -amp-i-lill,-PA 17011 -. ._..._... (v' m....' " ROWMEs 0 DAVID STONE, ESQUIRE 02 IM $01-600 0004241518 SEP 03 2008 414 Bridge St MAILED FROM ZIPCQDE 19106 New Cumberland, PA 17070 5. 7. 8. Total Number of Pi?b? I Tool Number of Pieces 1 Postmaster, Per (Name of receiving employee) Listed b Sender y Jj Received at Post Office PS Form 3877, February 2002 (Page 1 of 2) Complete by Typewriter, Ink, or Ball Point Pen 67861 FC Cumberland County Sale Date: 12/10/2008 THOMAS J. GIANNELLI & KAREN R. GIANNELLI Ir See Privacy Act State U.S. Bank National association, as Trustee for the In the Court of Common Pleas of Specialty Underwriting and Residential Finance Cumberland County, Pennsylvania Trust Mortgage Loan Asset-Backed Certificates, Writ No. 2008-3704 Civil Term Series 2006-BC4 VS Thomas J. Giannelli and Karen R. Giannelli ? tJ Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2008 at 1147 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: Thomas J_ Giannelli and Karen R. Giannelli, by making known unto Thomas Giannelli, personally and husband of Karen R. Giannelli, at 137 Allendale Way, Camp Hill, 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 0835 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 Thomas J. Giannelli and Karen R. Giannelli, located at 137 Allendale Way, Camp Hill, 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: Thomas J. Giannelli and Karen R. Giannelli, by regular mail to their last known address of 137 Allendale Way, Camp Hill, PA 17011. These letters were mailed under the date of October 7, 2008 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff BY Real Estate 4dtljz=? -GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3704 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 137 Allendale Way Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 137 Allendale Way Camp Hill, PA 17011 DAVID STONE, ESQUIRE 414 Bridge St. New Cumberland, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 7, 2008 46?1?-? T -071t 11 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff C ? .? ?- ?_, 'c;?r°. 2 -,? rx? ? y[` ' ? ' . "Fd may" . 1._ ?.? /"sF .' f ` ?. ? ? « y C.,> U.S. Bank National association, as Trustee for the In the Court of Common Pleas of Specialty Underwriting and Residential Finance Cumberland County, Pennsylvania Trust Mortgage Loan Asset-Backed Certificates, Writ No. 2008-3704 Civil Term Series 2006-BC4 VS Thomas J. Giannelli and Karen R. Giannelli Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2008 at 1147 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: Thomas J. Giannelli and Karen R. Giannelli, by making known unto Thomas Giannelli, personally and husband of Karen R. Giannelli, at 137 Allendale Way, Camp Hill, 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 0835 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 Thomas J. Giannelli and Karen R. Giannelli, located at 137 Allendale Way, Camp Hill, 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: Thomas J. Giannelli and Karen R. Giannelli, by regular mail to their last known address of 137 Allendale Way, Camp Hill, PA 17011. 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. Sheriff's Costs: Docketing 30.00 Poundage 21.76 Posting Bills 15.00 Advertising 15.00 Prothonotary 2.00 Mileage 32.00 Levy 15.00 Surcharge 30.00 Postpone sale 40.00 Law Journal 449.00 Patriot News Share of bills So Answers- - -- R. Thomas Kline, Sheriff i BY Real Estate Coor orator 444.71 14.92 ildF/v g 19 o q p a CO- ? t?9wq .7,2.3 -l.?S OF THE PFOT -`1"NOTARY 2009 APR - 8 AM g-- 5 7 Goldbeck McCaffdrty & 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-3704 CIVIL TERM U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 137 Allendale Way Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 137 Allendale Way Camp Hill, PA 17011 DAVID STONE, ESQUIRE 414 Bridge St. New Cumberland, PA 17070 (attach separate sheet if more space is needed) al knowledge or I verify that the statements made in this affidavit are true and corrkbj?ea ens information and belief. I understand that false statements herein are made s 8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Au-tst 26, 2008 GOLDBECMcKEEVER BY: MichaAttorney fo ALL THAT CERTAIN parcel known as Lot No. 55, Section "D" Allendale, Lower Allen Township, Cumberland County, Pennsylvania, according to a Plan of Allendale for Mid State Development, Inc., by William B. Whitlock, R.P.E. dated April 12, 1976, recorded in Plan Book 29, Page 105, bounded and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of-way line of Allendale Way, a 60 foot right-of-way, at the southwest corner of Lot No. 56, Section "D" Allendale, said point being located and referenced a distance of 339.67 feet southeast of the intersection of the eastern right-of-way line of Allendale Way, and the southern right-of-way line of Fieldstone Road, a 50 foot right-of-way; thence by Lot No. 56, North 64 degrees 35 minutes 53 seconds East, a distance of 96.14 feet to a point at Lot No. 61, Section "E" Allendale; thence by the same and a portion of Lot No. 62, Section "E", South 25 degrees 49 minutes 27 seconds East, a distance of 104.00 feet to a point at the northeast corner of Lot No. 54, Section "D" Allendale; thence by the same, South 64 degrees 35 minutes 53 seconds West, a distance of 96.90 feet to a point on the eastern right-of-way line of Allendale Way; thence by the same, North 25 degrees 24 minutes, 07 seconds West, a distance of 104.00 feet to a point, the place of BEGINNING. SUBJECT to easements, restrictions and building lines of record. SUBJECT to Protective Covenants recorded in Cumberland County Recorder of Deeds Office in Miscellaneous Book 158, Page 243. HAVING THEREON ERECTED a dwelling house known and numbered as 137 Allendale Way, Camp Hill, Pennsylvania. BEING THE SAME PREMISES WHICH Sydney M. Grobman and Joyce 8, Grobman, husband and wife, by their deed dated April 14, 2006, and recorded April 20, 2006, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Page 599, granted and conveyed unto Thomas J. Giannelli and Karen R. Giannelli, husband and wife, Mortgagors herein. 08-3704 CIVIL TERM 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINAr TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE VS. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) Term No. 08-3704 CIVIL TERM 137 Allendale Way Camp Hill, PA 17011 Defendant(: 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: GIANNELLI, THOMAS J. THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Your house at 137 Allendale Way, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $288,889.73 obtained by U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 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: 08-3704 CIVIL TERM 1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 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 08-3704 CIVIL TERM 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. og_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 hqp://www.phfa.org/consumers/homeowners/real.amx. 5). Call the Plaintiff (your lender) at 800-776-0100 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 homeretentioncr?.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 67861FC. Para informacion en espanol puede communicarse con Loretta at 215-825-6344. 08-3704 CIVIL TERM 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINAT TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-13C4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) Term No. 08-3704 CIVIL TERM 137 Allendale Way Camp Hill, PA 17011 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: GIANNELLI, KAREN R. KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Your house at 137 Allendale Way, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $288,889.73 obtained by U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 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: 08-3704 CIVIL TERM 1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To 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 08-3704 CIVIL TERM 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.goy 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 hqp://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 800-776-0100 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 homeretentionayoldbecklaw.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 67861FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N008-3704 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 Plaintiff (s) From THOMAS J GIANNELLI KAREN R GIANNNELLI (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$ 288,889.73 L.L.$0.50 Interest FROM 08/27/2008 TO DATE OF SALE LPER DIEM AT $62.28 Atty's Comm % Due Prothy $2.00 Atty Paid $179.00 Other Costs Plaintiff Paid Date: August 29, 2008 (Seal) REQUESTING PARTY: Name MICHAEL T MCKEEVER ESQ I ,I? /? h I urtis R. Long, Prothono ary By: (;? d „_, Deputy Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale #81 On September 9, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 137 Allendale Way, Camp Hill more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 9, 2008 By: Real Est to Sergeant ,,.he 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 Patr1*ot*#Xews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown (below: 10/29/08 11/05/08 11/12/08 Sworn to an scribed before me this'5 day oaf November, 2008 A.D. \ ! 4 Notdry Publi - °'C7+ MQNW LT•11Ot _O6NNSYL?/ ?ttat3 a! Seal '"?ANI O Sherri _ Y?; , r. 'aryPublic ?5 O?ttar ura[)ar;phin YComrrkce,?COU 'M Wov. 26, 2011 Member, u 4,.,anra AssC)Giation of Notaries4 Real Estate Salo No. 81 Writ No. 2008-3704 Civil Term U.S. Bank National Association as Trustee for the SPeciafty Underwriting and Residential swim 200 v'S Thomas J. Gianneill and Karen R. Gianneili Attorney Michael McKeever LEGAL DESCRIPTION ALL THAT CERTAIN parcel known as Lot No. 55, Section "D" Allendale, Lower Allen Township, Cumberland County, Pennsylvania, according to a Plan of Allendale for Mid State Development, Inc., by William B. Whitlock, R.P.E. dated April 12, 1976, recorded in Plan Book 29, Page 105, bounded and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of- way line of Allendale Way, a 60 foot right-of- way, at the southwest comer of Lot No. 56, Section "D" Allendale, said point being located and referenced a distance of 339.67 feet southeast of the intersection of the eastern right- of-way line of Allendale Way, and the southern right-of-way line of Fieldstone Road, a 50 foot right-of-way; thence by Lot No. 56, North 64 degrees 35 minutes 53 seeds East, a distance of 96.14 feet to a point at Lot No. 61, Section "E" Allendale; thence by the same and a portion of Lot No. 62, Section "E", South 25 degrees 49 minutes 27 seconds East a distance of 104.00 feet to a point at the noatheast corns of Lot No. 54, Section ' U" Allendale; thence by the same- Squib Squib 64 degrees 35 minutes 53 seconds West, a distance of 96:96 feet to point on the eastern right-of-way line of Allendale Way; thence by the same; North 25 degrees 24 mutes, 07 seconds West, a distance of 104.00 feet to a point, the place of BEGINNING. SUBJECT to easements, restrictions and building lines of record. SUBJECT to Protective Covenants recorded in Cumberland County Recorder of Deeds Office in Miscellaneous Book 158, Page 243. 14AVING THEREON ERECTED a dwelling house known and numbered as 137 Allendale Way, Camp Ilill, Pennsylvania. BEING THE SAME PREMISES WHICH Sydney M. Grobman and Joyce 8, Grobman, husband and wife, by their deed dated April 14, 2006; and recorded April 20, 2006, in the Office 4 the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Page 599, granted and conveyed unto Thomas J. Giaonelli and Karen R. Giannelli, husband and 41fe, Mortgagors herein. ?V, 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. SWORN TO AND SUBSCRIBED before me this 14 day of November, 2008 C Notary . NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY MY Commission Expires Apr 28, 2010 11AL MATS awa le. a 1 Writ No. 2008-3704 Civil U.S. Bank National Association as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates, Series 2006-BC4 VS. Thomas J. Giannelli and Karen R. Giannelli Atty.: Michael McKeever ALL THAT CERTAIN parcel known as Lot No. 55, Section "D" Allendale, Lower Allen Township, Cumberland County, Pennsylvania, according to a Plan of Allendale for Mid State Devel- opa t, Inc., by William B. Whitlock, R.P.E. dated April 12, 1976, recorded in Plan Book 29, Page 105, bounded' and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of-way line of Allendale Way, a 60 foot right-of-way, at the southwest corner of Lot No. 56, Sec- tion "D" Allendale, said point being located and referenced a distance of 339.67 feet southeast of the intersec- tion of the eastern right-of-way line of Allendale Way, and the southern right-of-way line of Fieldstone Road, a 50 foot right-of-way; thence by Lot No. 56, North 64 degrees 35 minutes 53 seconds East, a distance of 96.14 feet to a point at Lot No. 61, Section "E" Allendale; thence by the same and a portion of Lot No. 62, Section "E", South 25 degrees 49 minutes 27 seconds East, a distance of 104.00 feet to a point at the northeast corner of Lot No. 54, Section "D" Allendale; thence by the same, South 64 degrees 35 minutes 53 seconds West, a dis- tance of 96.90 feet to a point on the eastern right-of-way line of Allendale Way; thence by the same, North 25 degrees 24 minutes, 07 seconds West, a distance of 104.00 feet to a point, the place of BEGINNING. SUBJECT to easements, restnc- tions and building lines of record. SUBJECT to Protective Covenants recorded in Cumberland County Recorder of Deeds Office in Miscel- laneous Book 158, Page 243. HAVING THEREON ERECTED a dwelling house known and numbered as 137 Allendale Way, Camp Hill, Pennsylvania. BEING THE SAME PREMISES WHICH Sydney M. Grobman and Joyce 8, Grobman, husband and wife, by their deed dated April 14, 2006, and recorded April 20, 2006, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Pie 5519, granted and conveyed unto Thomas J. Giannelli and Karen R. Giannelli, husband and wife, Mort- gagors herein. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3704 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 08/27/2008 to Date of Sale per diem at $62.28 $288,889.73 (Costs to be added) G LDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff c?. LIJ W Qd z.L i IT EC7 qy a?¢H W O Ho0 ¢y"w? H H o 2 ¢ ¢ W ?z ZO QNaQ x zw?? z z ?oQw Lon? w z O H r ,? W ? as Q W ? Q C? v W p. ? ? O .--? U r?+ by W H o `~ ? W 9 a v o ? c 1 ? a v 7-. N U U U 0 ¢ v? U rV 5 / N ?45 Y°N N L N x ? V Q ,? o o. -., 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-3704 CIVIL TERM U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 137 Allendale Way Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 137 Allendale Way Camp Hill, PA 17011 DAVID STONE, ESQUIRE 414 Bridge St. New Cumberland, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: September 9, 2009 ,ef GO DBECK McCAFFERTY & McKEE TER BY: Michael T. McKeever, Esq. Attorney for Plaintiff PLED-Ors ICE OF THE F; OTH'ONOTARY 2009 SEP 17 Pty S: 10 J IN Ty w % 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 08-3704 CIVIL TERM U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINAI TRUST MORTGAGE LOAN ASSET-BACKED IN THE COURT OF COMMON PLEAS of Cumberland County CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) Tenn No. 08-3704 CIVIL TERM 137 Allendale Way Camp Hill, PA 17011 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: GIANNELLI, THOMAS .I. THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Your house at 137 Allendale Way, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $288,889.73 obtained by U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 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: 08-3704 CIVIL TERM 1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, 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.ore/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION .1 . 08-3704 CIVIL TERM 2 Liberty Avenue Carlisle, PA 17013 . ow 08-3704 CIVIL TERM 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 800-776-0100 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67861 FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. FILED-C;-F CE 110"IaC)TAPY 3 C OF THEE F-3.,i V 2009 SEP {7 PM 3: 10 ?4 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-3704 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is sub iect to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Michael T. McKeever Attorney for plaintiff -?+ICE OF THE OTAPY 2009 SEP 17 PH 3; 1 ? CUPYrr.4 ....: t ?r tLJ t ,1iJi?l.?, SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 137 Allendale Way Camp Hill, PA 17011 SOLD as the property of THOMAS J. GIANNELLI and KAREN R. GIANNELLI TAX PARCEL #13-25-0010-204 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-3704 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 Plaintiff (s) From THOMAS J. GIANNELLI AND KAREN R. GIANNELLI (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 $288,889.73 L.L. Interest FROM 08/27/2009 TO DATE OF SALE PER DIEM AT $62.28 Atty's Comm % Due Prothy $2.00 Atty Paid $1286.39 Other Costs TO BE ADDED Plaintiff Paid Date: 9/17/09 Curtis R. Le *'01 (Seal) By: REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQ Address: SUITE 5000- MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 ary Deputy Supreme Court ID No. 56129 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 67861FC CF: 06/23/2008 SD: 05/05/2010 $288,889.73 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET- BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3704 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) c? =D 50 Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/c Noentadnlt-(copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Keith C. Halili Legal Secretary ¢; L o mm p ? ir L o0 o N Ol x ?N W NL o WS L y N N ? U in O OL 0) a t a1 y N LL ?y1 N ( d O `? ` 'J?3iden o o 4 0 t a C ? ro c c ? C R Q S w f, ? ?- L) z a sn?o C,) a E?i ??3 a? A ? U y? r LLi c Lo E x?• o ?? a So LL U p Na -5 ' zcn 0 N irs U) D_ m? ? Z (D Q C rn a j m U z m w M M 1- .- U Q 0 z 4 c Q ' w z s. c O m U ? Q Q J vE? E a J C N a w m? w m a??vi ? U v p U O O W cm N co U- 0-0 z E CL 0 O w~ ? 10 Q c'7 T O i0 u .•-- .0 w J O 5 O x.N Q"- CN 21 x U N? Cl U 0 o= a j m O ? in d ? H Q m t O LOCO a- oumo o E d W z wQ UQ Q `l0lJdcy c woYw?n M to <O- 'D E_jF-?JO zO5 o=rn c7cn?n N M f 4 ..4 to (b fl. 00 d C ca z d a 0- a a? o pa Z5 um ny z? R v 1- J m M m 7 m C O V C d E W N w N V Q V IL` 0 a c 0 m m Y C z r r m O G C) o U O N C) 0 0 O J (4 w z CD cn C7 N z O C w 7 of m U Y a. _0 N a at3 ? J g W z E Z LL Z Q LL co UL Q L LL o O U) rl- Ronny R Anderson Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Jody S Smith ?9nptr of ",io rrf44a Chief Deputy ts: , . > Edward L Schorpp __ Solicitor OFPCE GF THO SPERIFF U S Bank National Association I vs. Thomas J Giannelli Case Number 2008-3704 SHERIFF'S RETURN OF SERVICE 12/18/2009 06:45 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2009 at 1842 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 Thomas J. & Karen R. Giannelli, located at, 137 Allendale Way, Camp Hill, Cumberland County, Pennsylvania according to law. 1223/2009 07:14 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1910 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Karen R. Giannelli, by making known unto, Thomas J. Giannelli, husband of defendant, at, 137 Allendale Way, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 1223/2009 07:14 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1910 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Thomas J. Giannelli, by making known unto, Thomas J. Giannelli, personally, at, 137 Allendale Way, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. (c) C-#ySulte Shenft. Te)eow*. inc. GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3704 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, 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: 137 Allendale Way Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 137 Allendale Way Camp Hill, PA 17011 DAVID STONE, ESQUIRE 414 Bridge St. New Cumberland, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 12, 2010 fil GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i'00'tr of climb OFFICE vF vHr S-ER1?:F FI Jody S Smith Chief Deputy Richard W Stewart Solicitor +, r U S Bank National Association Case Number vs. Thomas J Giannelli (et al.) 2008-3704 SHERIFF'S RETURN OF SERVICE 12/18/2009 06:45 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2009 at 1842 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 Thomas J. & Karen R. Giannelli, located at, 137 Allendale Way, Camp Hill, Cumberland County, Pennsylvania according to law. 12/23/2009 07:14 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1910 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Karen R. Giannelli, by making known unto, Thomas J. Giannelli, husband of defendant, at, 137 Allendale Way, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/23/2009 07:14 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1910 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Thomas J. Giannelli, by making known unto, Thomas J. Giannelli, personally, at, 137 Allendale Way, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 02/09/2010 Property sale postponed to 5/5/2010. 04/21/2010 Property sale postponed to 7/7/2010. 07/06/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Michael McKeever on 7/2/10 SHERIFF COST: $991.07 July 06, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF 46:0.7 7 OF. (c) CounfySuite Sheriff. Teieosoft. Inc. Goldbeck McCafferty & McKeever BY: Michael "I'. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 IN THE COURT OF COMMON PLEAS Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI (Mortgagor(s) and Record Owner(s)) 137 Allendale Way Camp Hill, PA 17011 No. 08-3704 CIVIL TERM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 137 Allendale Way Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 3. Name end last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 137 Allendale Way Camp Hill, PA 17011 DAVID STONE, ESQUIRE 414 Bridge St. New Cumberland, PA 17070 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: September 9. 2009 GO DBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 08-3'704 CIVIL TERM C:Oi.,DBECK 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINAN TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) Term No. 08-3704 CIVIL TERM 137 Allendale Way Camp Hill, PA 17011 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: GIANNELLI, KAREN R. KAREN R. GIANNELLI 137 Allendale Way ,Camp Hill, PA 17011 Your house at 137 Allendale Way, Camp Hill, PA 17011 is scheduled to be sold at Sheriff's Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $288,889.73 obtained by U.S. BANK NATIONAL ASSOCIATION. AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES. SERIES 2006-13C4 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: 08-3704 CIVIL TERM 1. The'sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the frill 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 08-3704 CIVIL TERM 2 Liberty Avenue Carlisle, PA 17013 08-3704 CIVIL TERM 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 800-776-0100 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention a goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215=825-6418. Please reference our Attorney File Number of 67861 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN parcel known as Lot No. 55, Section "D" Allendale, Lower Allen Township, Cumberland County, Pennsylvania, according to a Plan of Allendale for Mid State Development, Inc., by William B. Whitlock, R.P.E. dated April 12, 1976, recorded in Plan Book 29, Page 105, bounded and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of-way line of Allendale Way, a 60 foot right-of-way, at the southwest corner of Lot No. 56, Section "D" Allendale, said point being located and referenced a distance of 339.67 feet southeast of the intersection of the eastern right-of-way line of Allendale Way, and the southern right-of-way line of Fieldstone Road, a 50 foot right-of-way; thence by Lot No. 56, North 64 degrees 35 minutes 53 seconds East, a distance of 96.14 feet to a point at Lot No. 61, Section "E" Allendale; thence by the same and a portion of Lot No. 62, Section "E", South 25 degrees 49 minutes 27 seconds East, a distance of 104.00 feet to a point at the northeast corner of Lot No. 54, Section "D" Allendale; thence by the same, South 64 degrees 35 minutes 53 seconds West, a distance of 96.90 feet to a point on the eastern right-of-way line of Allendale Way; thence by the same, North 25 degrees 24 minutes, 07 seconds West, a distance of 104.00 feet to a point, the place of BEGINNING. SUBJECT to easements, restrictions and building lines of record. SUBJECT to Protective Covenants recorded in Cumberland County Recorder of Deeds Office in Miscellaneous Book 158, Page 243. HAVING THEREON ERECTED a dwelling house known and numbered as 137 Allendale Way, Camp Hill, Pennsylvania. BEING THE SAME PREMISES WHICH Sydney M. Grobman and Joyce 8, Grobman, husband and wife, by their deed dated April 14, 2006, and recorded April 20, 2006, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Page 599, granted and conveyed unto Thomas J. Giannelli and Karen R. Giannelli, husband and wife, Mortgagors herein. TAX PARCEL 413-25-0010-204 08-3704 CIVIL TERM r. e 0 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 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINAN TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI Mortgagor(s) and Record Owner(s) 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3704 CIVIL TERM 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: GIANNELLI, THOMAS J. THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Your house at 137 Allendale Way, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $288,889.73 obtained by U.S. BANK NATIONAL ASSOCIATION. AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 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: 08-3704 CIVIL TERM 1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL'FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4, 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 frill 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 tiled 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: littp://www.12hiladelpliiafed.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 08-3704 CIVIL TERM 2 Liberty Avenue Carlisle, PA 17013 08-3704 CIVIL TERM 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 800-776-0100 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67861FC. Para infonnacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN parcel known as Lot No. 55, Section "D" Allendale, Lower Allen Township, Cumberland County, Pennsylvania, according to a Plan of Allendale for Mid State Development, Inc., by William B. Whitlock, R.P.E. dated April 12, 1976, recorded in Plan Book 29, Page 105, bounded and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of-way line of Allendale Way, a 60 foot right-of-way, at the southwest corner of Lot No. 56, Section "D" Allendale, said point being located and referenced a distance of 339.67 feet southeast of the intersection of the eastern right-of-way line of Allendale Way, and the southern right-of-way line of Fieldstone Road, a 50 foot right-of-way; thence by Lot No. 56, North 64 degrees 35 minutes 53 seconds East, a distance of 96.14 feet to a point at Lot No. 61, Section "E" Allendale; thence by the same and a portion of Lot No. 62, Section "E", South 25 degrees 49 minutes 27 seconds East, a distance of 104.00 feet to a point at the northeast corner of Lot No. 54, Section "D" Allendale; thence by the same, South 64 degrees 35 minutes 53 seconds West, a distance of 96.90 feet to a point on the eastern right-of-way line of Allendale Way; thence by the same, North 25 degrees 24 minutes, 07 seconds West, a distance of 104.00 feet to a point, the place of BEGINNING. SUBJECT to easements, restrictions and building lines of record. SUBJECT to Protective Covenants recorded in Cumberland County Recorder of Deeds Office in Miscellaneous Book 158, Page 243. HAVING THEREON ERECTED a dwelling house known and numbered as 137 Allendale Way, Camp Hill, Pennsylvania. BEING THE SAME PREMISES WHICH Sydney M. Grobman and Joyce 8, Grobman, husband and wife, by their deed dated April 14, 2006, and recorded April 20, 2006, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Page 599, granted and conveyed unto Thomas J. Giannelli and Karen R. Giannelli, husband and wife, Mortgagors herein. TAX PARCEL #13-25-0010-204 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) L.L. TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 Plaintiff (s) From THOMAS J. GIANNELLI AND KAREN R. GIANNELLI (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 $288,889.73 Interest FROM 08/27/2009 TO DATE OF SALE PER DIEM AT $62.28 Atty's Comm % Due Prothy $2.00 Atty Paid $1286.39 Other Costs TO BE ADDED Plaintiff Paid Date: 9/17/09 Curtis R. AL , ro on tar (Seal) REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQ Address: SUITE 5000- MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 By: N008-3704 Civil CIVIL ACTION - LAW Deputy TRUE COPY FROM RECORD in Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ...17?n".... day of.....4w....... r%. - /` Pro o y ota On October 1, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as 137 Allendale Way, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 1, 2009 By: Real Estate Coordinator 0 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22 January 29, and February 5 2010 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 sa Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this 5 day of February, 2010 Notary ? NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 writ No. 2008-3704 C" - U S Bank National Association as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates, Series 2006-BC4 VS. Thomas J. Giannelli Karen R. Giannelli Atty: Michael McKeever ALL THAT CERTAIN parcel known as Lot No. 55, Section "D" Allendale, Lower Allen Township, Cumberland County, Pennsylvania. according to a Plan of Allendale for Mid State Devel- opment, Inc., by William B. Whitlock, R.P.E. dated April 12, 1976, recorded in Plan Book 29, Page 105, bounded and described in accordance with said Plan as follows: BEGINNING at a point on the eastern right-of-way line of Allen- dale Way, a 60 foot right-of-way, at the southwest corner of Lot No. 56, Section 'Allendale, said point being located and referenced a distance of 339.67 feet southeast of the intersec- tion of the eastern right-of-way line of Allendale Way, and the southern right-of-way line of Fieldstone Road, a 50 foot right-of-way; thence by Lot No. 56, North 64 degrees 35 minutes 53 seconds East, a distance of 96.14 feet to a point at Lot No. 61, Section ` Allendale; thence by the same and a portion of Lot No. 62, Section "F", South 25 degrees 49 minutes 27 seconds East, a distance of 104.00 feet to a point at the northeast corner of Lot No. 54. Section "D" Allendale; thence by the same, South 64 degrees 35 minutes 53 seconds West, a dis- tance of 96.90 feet to a point on the eastern right-of-way line of Allendale Way; thence by the same, North 25 degrees 24 minutes, 07 seconds West, a distance of 104.00 feet to a point, the place of BEGINNING. SUBJECT to easements, restric- tions and building lines of record. SUBJECT to Protective Covenants recorded in Cumberland County Recorder of Deeds Office in Miscel- laneous Book 158, Page 243. HAVING THEREON ERECTED a dwelling house known and numbered as 137 Allendale Way. Camp Hill, Pennsylvania. BEING THE SAME PREMISES WHICH Sydney M. Grobman and Joyce 8, Grobman, husband and wife, by their deed dated April 14, 2006, and recorded April 20, 2006, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 274, Page 599, granted and conveyed unto Thomas J. Giannelli and Karen R. Giannelli, husband and wife, Mort- gagors herein. TAX PARCEL #13-25-0010-204. PROPERTY ADDRESS: 137 Allen- dale Way, Camp Hill, PA 17011. or . The Patriot-News Co. 812 Market St. Harrisburg,.PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the Patr1*otwXews Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/22/10 01/29110 02/05/10 of February, 2010 A.D. rvutary ruunc COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisner, Notary Public City Of Harrisburg; Dauphin County MY Commission E*w Nov. 28, 2011 Member, Pennsylvania Assoolatlon of Notaries l ? L ? ?, w GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FILED-OFFICE OF THE PROTHONOTARY 2011 MAR 28 AM 10: 31 CUMBERLAND COUNTY PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Defendant(s) No. 08-3704 CIVIL TERM PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. IIA, 4, j ?%ll 6zt) 0 115 -7.3 By G IL C CCAFFE & MCKEEVER Michael Mc eever a. ID 561,29 Gary McCafferty Pa. ID 42386 .? Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY .&/,W I/) 7 / 3.? GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff VS. THOMAS J. GIANNELLI KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3704 CIVIL TERM CERTIFICATE OF SERVICE Natasha Perez, hereby certifies that he/she did serve true and correct copies of Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on ?? of l THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 B• Goldbeck McCafferty & McKeever Natasha Perez, Legal Assistant NPerez@goldbecklaw.com 215-825-6384 (Direct Phone) . . GOLDBECK McCAFFERTY & MCKtEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. Plaintiff Defendant(s) OF THELPROTHONOTAR'Y 1011 MAR 28 AM IQ: 31 CUMBERLANn rni?uT), IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 08-3704 CIVIL TERM PRAECIPE TO DISCONTINUE AND END THOMAS J. GIANNELLI KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. By: GOL (?; ECK M FFERTY & CKEEVER Michael 9 Gary McCafferty Pa. ID 42386,9,---" 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 GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. THOMAS J. GIANNELLI KAREN R. GIANNELLI ]37 Allendale Way Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3704 CIVIL TERM CERTIFICATE OF SERVICE Natasha Perez, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on I 0-)d t' THOMAS J. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 KAREN R. GIANNELLI 137 Allendale Way Camp Hill, PA 17011 Bye - ?P Goldbeck McCafferty & McKeever Natasha Perez, Legal Assistant NPerez@goldbecklaw.com 215-825-6384 (Direct Phone)